Risk and responsibility

When allocating risk and responsibility for origin, a distinction must be made between the public law position and the contractual relationship between VTTI and the customer.

Where VTTI lodges a customs declaration or issues or makes out origin documentation, VTTI may bear responsibilities towards the customs authorities regarding the accuracy and completeness of the information provided and the authenticity, accuracy and validity of supporting documents submitted or used.

VTTI is not the producer or owner of the goods and generally has limited visibility of the supply chain, production process and sourcing of the materials before they arrive at the terminal. VTTI therefore relies on origin information and supporting documentation provided by the customer. Under the contractual arrangements between VTTI and the customer, the customer is responsible for providing accurate and complete information and all documentation required to record, determine or substantiate the origin of the goods.

VTTI supplements the information provided by the customer with the operational, inventory and movement data recorded in its own systems. CS and the relevant customs specialists perform the checks and assessments prescribed by this procedure. Where the available information gives rise to doubt or appears incomplete or inconsistent, VTTI will request clarification or correction before using the information for a customs declaration, an origin determination or a proof of origin.

VTTI will not claim preferential tariff treatment or issue, make out or facilitate a proof of preferential origin where material concerns regarding originating status or the supporting documentation remain unresolved.