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The US announces National Strategy for Global Supply Chain Security.
The Secretary of Homeland Security, Janet Napolitano, announced at Davos the USA's outline for Global Supply Chain Security.
"We must continue to strengthen global supply chains to ensure that they operate effectively in time of crisis; recover quickly from disruptions; and facilitate international trade and travel, said Secretary Napolitano. As a part of this effort, we look forward to working closely with our international partners in the public and private sector to build a more resilient global supply chain."
The full press release can be found at www.dhs.gov/ynews/releases/20120125-national-strategy-global-supply-chain-security.shtm
Links to the full document can be found, within the article, in a pdf format.
Guarantee requirements for the future
Many companies within the UK and the EU use different types of Customs procedures to help run their operation and to help with cashflow not being tied up in Bonds etc.
An extract from the HMRC webpages hghlights changes that will be in place, within a couple of years, that may have a drastic effect on how they operate.
"Businesses should be aware that the new Modernised Customs Code Draft Implementing Provisions (MCCIP), which will come into effect in mid 2013, will require a guarantee to be in place if you hold a customs authorisation for a special procedure, for example, Temporary Storage, Inward Processing, Customs Warehouse. To be entitled to a guarantee waiver a business will either need to hold AEO status or meet the AEO criteria.
HMRC are working on the details and implementation of how this will work in practice.
If your business is already authorised for a Customs Special Procedure, or intends to seek authorisation in the near future, consideration should be given to applying for AEO to ensure your application is processed within the timeframe allowed."
Many EU countries already have these types of Guarantee requirements in place and although the MCCIP timeline may have slipped these will hit UK companies shortly. Why not start the process to become an AEO now to save tying up valuable cashflow?
Customs Information Paper 11 - 53
A new CIP has been issued with regard to Plastic Kitchenware originating in China & Hong Kong annoucing new controls on these products into the EU.
AEO and C-TPAT
A recent article in the Global Trade News, entitled C-TPAT and AEO - The Same Yet Different, reproduced below, showed a quick comparision between the two systems employed on either side of the Atlantic identifying key differences between the two programs.
"Being familiar with US Customs-Trade Partnership Against Terrorism (C-TPAT) and Authorized Economic Operator (AEO) goes beyond more than knowing both are safety programs. What about the similarities, differences, significances, etc.?
While both are voluntary programs developed in response to the threat of terrorist organizations and with the central goal of securing and facilitating global trade through secure international supply chains, and benefits are similar, there are several key differences between the two programs.
The main difference between the US’s C-TPAT program and the AEO framework developed by the WCO is that since going into effect in 2001, C-TPAT is an import only safety program, while AEO covers both imports and exports since going into effect in 2008. There exists 30 different programs in 56 different countries based upon the AEO framework laid out by the WCO. Those AEO programs are divided into three types: operational AEO programs, AEO programs to be launched in the near future, and Customs compliance programs. The US C-TPAT program currently has over 10,000 members, and has mutual recognition with about 5 countries. The C-TPAT accreditation is a 3-step process of certification, validation and formalization, whereas the AEO accreditation is an 8-step process.
However, each program is still independent, meaning that being a C-TPAT member is not the same as being an AEO member because the necessary security measures that are in place for one program may not meet those required by another country – unless there is mutual recognition between C-TPAT and a specific AEO program.
Despite the differences, the risk based approach taken by C-TPAT and AEO provides reduced risk in the supply chain, improved marketability and asset utilization, and stronger brand equity while also giving members flexibility in the effective use of their resources. These programs are intended to enhance security along all points of the supply chain.
Have you considered becoming certified in either an AEO or in the US C-TPAT program?"
For any further information please contact
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to see if these programs could help your company.
MMCIP Update
A recent speech by Algirdas Šemeta, the EU Commissioner for Taxation and Customs Union, Audit and Anti-Fraud given on the 19th of May issues with the implementation of the MCCIP were covered. The section covering this topic is covered within this message and I would like to draw your attention to the deadline date of 24th of June 2013.
"Intentions for MCC
Now, let me end my remarks on a "last but not least" item: the Modernised Customs Code.
As you must be aware, your representatives in the MCC Implementation Ad Hoc High Level Steering Group were recently informed about the various challenges in the implementation of the Modernised Customs Code. The Commission also explained what the available options to move forward are.
Today, I can confirm that, by the end of this year, I intend to submit to the College a proposal for the European Parliament and the Council to amend the Modernised Customs Code.
Such a proposal should serve three purposes:
First, it should postpone the date of application of the Code. This postponement should allow a phased, binding but realistic implementation of new, electronic-based processes. This would allow the main benefits expected from the modernisation to be implemented;
Second, it should align the Code with the provisions of the Lisbon Treaty. This alignment is needed in particular as regards the use of either delegated or implementing powers by the Commission.
And thirdly, we should use the occasion to correct some provisions of the Code. These corrections would involve elements which are either no longer in line with the changes introduced since 2008 to current EU legislation, or elements that have revealed too difficult or unworkable to be implemented.
It will not be a straightforward exercise, especially as we are bound by the deadline of 24 June 2013. Whether we succeed, will to a large extent depend on the emergence of a common understanding amongst the parties involved. We will need to develop a shared understanding of the objectives and scope of the initiative.
There is little sense in relaunching a debate on the purpose and principles of the modernisation of the customs legislation, repeating the discussions that took place between 2005 and 2008. It would also be a waste to undo the comprehensive work done to draft legislation matching the reality of our economic operators and our administrations.
Instead, I would recommend a limited and targeted intervention in the Code and sustained efforts to finalise the draft implementing legislation as quickly as possible. This way, jointly, the Commission, the European Parliament, the Council and national customs administrations can implement and conclude this chapter in the modernisation of the Customs Union."
We will keep you informed!
Mutual Recognition with Japan
Implementation of mutual recognition of AEO's between the EU and Japan will begin on 24th May 2011.
The European Commission states that “Trade that is coming from EU AEO exporters or going to EU AEO importers will benefit at the stage of the Japanese import / export declaration.” See the EC statement
Agreements with China and USA will follow soon and a two tier system will start to become noticeable – for non AEO's!
MCCIP Delay
It is widely expected that a delay to the implementation of the MCCIP will be announced shortly due to some Member States not having all the correct systems in place. We will be keeping you advised of this when we have more news.
AEO Training?
Before you commit to spending large sums of your trainng budget on "AEO Trainng", stop and ask yourself the following questions:-
What am I trying to achieve?
Is the information freely available? i.e. www.hmrc.gov.uk
How relevant is it to my business?
Attending training courses, or having inhouse courses, does not always mean a smooth path to AEO accredditation as each company is different in how they operate.
Here at BCC Ltd we offer an inital free consultation to see if the process is right for you and give you a better understanding of the requirements of AEO.
For details please contact us on
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PIP and C-TPAT Harmonization
The Canada Border Services Agency (CBSA) and US Customs and Border Protection (CBP) are working towards harmonization of the Partners-in-Protection (PIP) and Customs-Trade Partnership Against Terrorism (C-TPAT) programs. Representatives of both programs met twice in 2010 for discussions, including defining what exactly harmonization would mean.
According to the PIP Fall 2010 Newsletter, harmonization of PIP and C-TPAT is defined as the alignment of both programs in the areas of policies, processing and documentation practices, where applicable and desirable, while retaining sovereignty. While PIP and C-TPAT will remain separate programs, there will be a common application process allowing applicants who are eligible to join both programs to complete one application (with supplementary information requirements).
Here is a quick glance at what is coming:
- If eligible, PIP members who are not already members of C-TPAT will be able to apply for C-TPAT certification by only providing supplementary information
- There will be only one application form for new applicants wishing to apply to both programs
- Each program will retain the right to render their own judgments but only one site validation will be required for both programs
Source Global Trade News
AEO ACCREDITATION LEADS TO CASH FLOW BENEFIT
If your business has to provide Community Transit Guarantees and:
• has 2 years experience in the transit procedures; &
• meets the criteria in the Regulation 2454/93 Customs Code Implementing Regulations Article 380 & Annex 46B,(specifically para 3)
applying for AEO Customs Simplifications (AEOC) or Full status (AEOF) may be of interest to your business.
HMRC have advised us that if you are now getting 50% or 70% waivers, once you obtain AEO status you can apply for a 100 per cent waiver.
In line with waivers available in other EU member states, who already require guarantees ahead of the adoption of the MCCIP in 2013, AEO accreditation could mean that your business is one of the early beneficiaries.
It should be noted that when the new MCCIP comes into effect in 2013 businesses holding, or wishing to apply for, a customs simplifications that hold AEOC or AEOF status would be eligible for a guarantee waiver.
HMRC are about to issue a Customs Information Paper (CIP) setting out the terms of these waivers. It will be an immediate cash flow benefit to Freight Agents, particularly those around the UK airports who move goods under CT guarantees, and ERTS or Bonded Warehouse operators.
If you would like to know more and how AEO accreditation might help your business contact Business Change Consultancy Limited or its business partner Veracis Limited.
Denis O'Sullivan, Managing Director of Business Change Consultancy Limited &
Stephen Plowman, Managing Director of Veracis Limited
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