Inbound
3.1 Non-preferential origin
3.1.1 Registration of non-preferential origin uponfor receiptinbound parcels
When sending a nomination for an inbound shipment, the customer must provide the non-preferential country of origin of the product. This information is required before the goods can be accepted at the terminal. VTTI does not acceptpermit the discharge of product for which the non-preferential country of origin is unknown.
When CS registers the incoming parcel in the terminal’s ERP system, the non-preferential country of origin stated in the nomination is recorded with the relevant parcel. The recorded origin remains linked to the parcel and forms part of the origin audit trail maintained in the ERP system.
CS performs a reasonableness check to assess whether the country of origin provided by the customer is consistent with the other information and documentation available for the shipment. This includes, where relevant, the product information, transport documentation and any origin-related supporting documentation provided by the customer. The check is based on the information available to VTTI and does not constitute an independent determination of the origin of the goods.
If the non-preferential country of origin has not been provided, or if the origin information gives rise to doubt or appears inconsistent with other information or documentation available, CS will request clarification and, where necessary, correction or additional supporting documentation from the customer. The product will not be accepted at the terminal until the non-preferential country of origin has been identified and any material concerns have been adequately addressed.
3.1.2 Purpose and use of non-preferential origin information registered upon receipt
The non-preferential origin recorded for an inbound parcel forms part of the customs data maintained by VTTI for the goods. The information remains linked to the relevant parcel in the ERP system for as long as the goods remain at the terminal. This enables VTTI to trace the origin information received from the customer throughout the storage period and to use it, where relevant, for customs declarations, reporting and statistical purposes, and in connection with audits or controls by the customs authorities.
The recorded inbound origin may also be relevant when goods are subsequently processed or blended at the terminal. In such cases, the origin information relating to the individual input materials is used, together with the operational and inventory data available in VTTI’s systems, to determine or substantiate the origin of the resulting outbound product.
The origin recorded for an inbound parcel does not automatically determine the origin of a product resulting from processing or blending. The origin of the outbound product must be determined separately by applying the relevant preferential or non-preferential origin rule. Depending on the applicable rule, the origin of the inbound materials may be one of the factors taken into account in that determination.
3.1.3 Receipt and storage of supporting documentation
Where the customer provides supporting documentation in relation to the non-preferential origin (such as a certificate of origin or a supplier's declaration) for an incoming shipment, CS stores that document in the Document Management System (part of VTTI's ERP) with a reference to the respective parcel. TheCS data inrecords the relevant document that is needed in VTTI's business process is registered by CSdata in the Cargo Documents module in ERP.
3.1.4 Reasonableness check
CS performs a reasonableness check on the origin-related supporting documentation received from the customer. This check is performed using the applicable checklist and is intended to assess whether the documentation appears complete, meets the applicable formal requirements and can reasonably be linked to the goods concerned.
The reasonableness check is based on the information and documentation available to VTTI and does not constitute an independent origin determination or audit of the origin of the goods.
The checklist for reviewing origin-related supporting documentation is available here.
3.1.65 Follow-up and escalation
If the reasonableness check gives rise to any doubt, ambiguity or apparent error, CS will request clarification, correction or additional supporting documentation from the customer. The documentation will not be relied upon for customs purposes until any material concerns have been adequately addressed.
Where the matter cannot be resolved by CS or requires further customs expertise, CS will involve the terminal’s customs specialist. Depending on the complexity, potential financial impact or wider compliance implications of the matter, the terminal’s customs specialist may request support from CGT.
VTTI will not userely on the origin information or supporting documentation concerned for a customs declaration, origin determination or proofcompliance of originpurposes while material concerns remain unresolved.unresolved.
3.2 Preferential origin
3.2.1 Receipt and storage of supporting documentation
Where the customer provides supporting documentation in relation to the non-preferential or preferential origin (such as a certificate of origin, supplier's declaration,an origin statement or an origin declaration) for an incoming shipment, CS stores that document in the Document Management System (part of VTTI's ERP) with a reference to the respective parcel. The data in the document that is needed in VTTI's business process is registered by CS in the Cargo Documents module in ERP.
3.2.2 PreferentialReasonableness origin upon release for free circulationcheck
PreferentialUpon tariff treatment may result in a reduced or zero ratereceipt of the goods, CS verifies the normally applicable import duty whenrate, referred to as the “MFN rate”, and whether a proof of preferential origin has been provided. If the MFN rate is 0%, the goods are released for free circulation.circulation Preferentialwithout treatmentclaiming maypreferential onlytariff betreatment.
If the goodsMFN qualifyrate asexceeds originating under an applicable preferential arrangement0% and the requireda proof of preferential origin is availableavailable, andCS meetsperforms thea conditionsreasonableness check. As part of thatthis arrangement.
The customer is responsible for informing VTTI that preferential tariff treatment is to be claimed and for providing the required origin information and supporting documentation.check, CS follows the steps below before processing a claim for preferential tariff treatment in an import declaration.
Step 1: Determine whether preferential treatment is available
CS first establishesassesses whether a preferential arrangement applies between the European Union and the stated country or territory forof which preferential origin is claimed. It must also be establishedorigin, whether the product concerned falls within the scope of that arrangement and is eligible for preferential tariff treatment.
CS also verifies whether claiming preferential treatment is relevant in view of the normally applicable import duty rate. Where the standard import duty rate is already zero, a claim for preferential tariff treatment generally provides no immediate financial benefit. However, the preferential origin information and any supporting documentation provided by the customer must still be recorded and retained where relevant.
Step 2: Confirm the preferential origin claimed
The customer must confirm that preferential tariff treatment is to be claimed and indicate:
the preferential arrangement under which the claim is made;the country or territory of preferential origin; andthe product and shipment to which the claim relates.
VTTI relies on this information when determining the applicable proof requirements. If the information provided is incomplete or inconsistent, CS will request clarification from the customer before proceeding.
Step 3: Identify the required proof of origin
CS determinestreatment, which form of proof of origin is permittedrequired under the applicable preferential arrangement. The required formarrangement and conditions may differ between arrangements and may depend on factors such as the value of the originating products included in the shipment.
The assessment must take into account, where relevant:
the types of proof permitted under the arrangement;any applicable value thresholds;the prescribed wording or other formal requirements;- whether
the exporter is permitted to make out the proof; and whether the exporter must hold a specific authorisation or registration.
The customer is responsible for providing the required proof and any information or supporting documentation needed to establish that it may be used for the shipment concerned.
Step 4: Perform the reasonableness check
CS performs a reasonableness check on the proof of origin provided by the customer. The purpose of this check isappears to assess whether the proof:
is available at the time preferential treatment is claimed;appears complete and meetsmeet the applicableformal requirements;has been issued or made out by an eligible person;remains usable for the intended import declaration;sufficiently describes or identifies the goods concerned;requirements and- can reasonably be linked to the
relevantgoodsshipmentconcerned.and parcel.
The reasonableness check is based on the information and documentation available to VTTI.VTTI Itand does not constitute an independent audit of the exporter’s production processprocess, supply chain or an independent verification of the originating status of the goods.good.
AnyThe doubt,checklist ambiguityfor orreviewing apparentorigin-related errorsupporting mustdocumentation beis followedavailable uphere.
3.2.3 in accordance with section 3.5, Follow-up and escalation.
StepIn 5:principle, DecideVTTI whetherdoes preferentialnot treatmentstore maygoods be claimed
CS may process the claimeligible for preferential tariff treatment where:
- under the customs warehouse procedure. Where the proof of origin passes the reasonableness check, VTTI claims preferential tariff treatment and the goods are
eligiblereleased forpreferentialfreetreatmentcirculation.underIf
the applicable arrangement; the customer has confirmed the relevant preferential origin;the requiredno proof of origin isavailable;available,and- the proof
has passed the reasonableness check.
Where the required proof is unavailable, does not appear to meet the applicable requirements or givesmaterial riseconcerns toremain unresolved, preferential tariff treatment will not be claimed.
Any doubt, ambiguity or apparent error identified during the reasonableness check is followed up with the customer. CS requests clarification, correction or additional supporting documentation as appropriate and does not rely on the proof of origin while material concerns thatremain haveunresolved.
Where the customermatter subsequentlycannot providesbe anresolved acceptableby proofCS or requires further customs expertise, CS involves the terminal’s customs specialist. Depending on the complexity, potential financial impact or wider compliance implications of origin,the matter, the possibilityterminal’s ofcustoms claiming preferential treatment after importationspecialist may be assessed separately in accordance with the applicable preferential arrangement and customs legislation. VTTI will onlyrequest support suchfrom a claim where the required information and documentation are available and any material concerns have been resolved.CGT.