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Outline of Business Activities: NL vs. NL/BE Bunkering
The application of the “Zeevaartbunkerprocedure 2019” is driven by the objective of enabling bunkering activities in both Belgium and the Netherlands. If bunkering activities were to take place exclusively in the Netherlands, a different procedure would apply....
Import ban petroleum 2710 obtained from Russian crude 2709
Article 3ma 1. It shall be prohibited, as of 21 January2026, to purchase, import or transfer, directly or indirectly into the Union, petroleum products falling under CN code 2710 obtained in a third country fromcrude oil falling under CN code 2709 00 originati...
Scope definition import
6851f7e0-acf7-4275-8626-d18d3fc15bb9_en The Regulation itself does not define “import”. In the above passage from the Commission guidance (FAQ, 21 Dec 2022) it can be concluded that “Import” for sanctions purposes is assessed at the moment goods are physical...
Y693 - Net Exporter Countries of Crude Oil (2024)
Below is the official list of third‑country net exporter countries of crude oil (based on 2024 data) that benefit from the presumption that petroleum products (CN 2710) imported from them into the EU were obtained from domestic crude oil, not from Russian crud...
Y694 - Partner Countries listed in Annex LI
Below the official list of partner countries in Annex LI of Council Regulation (EU) No 833/2014 — i.e., the countries whose petroleum product imports into the EU are exempt from the obligation to provide evidence of the origin of the crude oil used to produce ...
Process flow - Import ban fuel 2710 coming from Russian Crude 2709
It should be noted in general that all statements on origin should be substantiated by proof. With regard to any documentation it should carefully be considered what the documentation says and proves. For example, a Certificate of Origin issues by a government...
What is “CertEX” and how does the system work?
In NL/EU day‑to‑day practice, people often use “CertEX” as an umbrella term for the digital certificates/official controls workflow around (pre‑)notification and border controls. The core is:TRACES NT is the EU system where consignments that fall under SPS/off...
What does “write‑off/consumption” of CHEDs / GGBs mean?
partial deliveries (splitting a lot),partial clearance or phased arrivals,mismatches between commercial documents (B/L, invoice, packing list) and actual received quantity,re‑allocation due to repacking, blending, or resale before physical discharge.How it wor...
What is the impact (aimed at the energy product)?
Because the energy products sector is broad, the impact is highly product‑ and route‑dependent. There are 3 relevant groups.A) “Mainstream” energy products (crude, gasoline, diesel, jet, fuel oil, naphtha, LNG/LPG)Usually no CHED/GGB is required, because these...
Practical do’s & don’ts for trading/ops (where write‑off issues often appear)
Do'sEnsure quantities (B/L/manifest vs CHED) are realistic and aligned with tolerance policy. Customs systems are known to have not implemented these tolerances in their system. To raise with Vemobin/NCO-NCW industry associations. In contracts, explicitly defi...
“Best-effort standard” HS/CN list for commodities
Quick “screening rule” (practical)Ch. 27 (2709/2710/2711) → CHED/GGB usually NoCh. 15 (1502, 1511–1514, 1518) and Ch. 12 (oilseeds) → CHED/GGB often Depends/Yes2207 (ethanol), 3826 (biodiesel) → Depends (fuel vs food/feed/ABP chain)Below is a best‑effort list ...
Detailed considerations
A) Mainstream energy products (typical CHED/GGB consideration: NO)Product familyLikely EU CN / HS headingsCHED/GGB (CertEX consideration)Crude oil2709 00 (petroleum oils, crude)No (not SPS/food/feed)Refined petroleum products (broad bucket)2710 (petroleum oils...
Recources
The EU Single Window Environment for Customs - Taxation and Customs Union
Standard procedure in BE
Overview of standard procedure for bunker deliveries in Belgium Below is a summary of the key requirements and steps involved when applying the standard procedure: A (re-)export transaction, including an export e-AD, must be filed for each bunker ...
Work instruction (commercial incentive)
In practice, there are two types of documents that refer to non-preferential origin:An official Certificate of Origin (CoO), which exporters can obtain by applying to the competent Chamber of Commerce or the relevant customs authorities; andA commercial docume...
Work instruction (simplified process)
In practice, there are two types of documents that refer to non-preferential origin:An official Certificate of Origin (CoO), which exporters can obtain by applying to the competent Chamber of Commerce or the relevant customs authorities; andA commercial docume...
Antidumping wel of geen Handelspolitieke maatregelen
Ja. Anti-dumpingrechten zijn handelspolitieke maatregelen, omdat ze niet bedoeld zijn als “normale” douanerechten voor tariefbescherming, maar als Trade Defence Instrument: een maatregel van de EU om de interne markt te beschermen tegen dumping (invoer tegen o...
Reach
ReachREGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/4...
Methane
MethaneAny legal entity can be appointed as responsible for carrying out acts and formalities required under Chapter 5 of the Methane Emissions Regulation. The Importer definition is not linked to the Customs definition as such perse.REGULATION (EU) 2024/1787 ...
CBAM
CBAMREGULATION (EU) 2023/956 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 10 May 2023 establishing a carbon border adjustment mechanismArticle 3 Definitions For the purposes of this Regulation, the following definitions apply:(4) 'importation’ means releas...