The following data is the basis of both import and export customs declarations as well as transit declarations. The parts of the data relevant to safety and security are used to make the entry summary declaration to the state of import and the exit summary declaration in the state of export. These latter declarations relate principally to safety and security issues and risk assessment.
The same data is also used for the manifest. This is a list of items on board the ship with full details about them. They must be completed both inwards and outwards on a shipping movement between a non-EU state and an EU state (including UK and Ireland post-Brexit). They gather in the relevant part of the data for all of the goods being moved.
The below list of items used to appear together in a single page so-called single administrative document with up to 56 entries which were populated by codes. Formerly there were 8 carbonated sheets which might be used in imports and exports and various types of movement. Using carbon copies of manual entries is no longer necessary given the fact that they can be replicated by the software.
As mentioned above the codes are now far easier and intuitive as the software which is used to show the wording associated with each code and is much more intuitive than before.
We have mentioned in the previous chapter that the UK temporary simplified procedures may make it unnecessary to do full import declarations for sales into the UK for a period of up to a year and a half or more after a hard Brexit. This is an important concession which we believe traders’ UK counterparty should apply for.
On each of traders’ exports to the United Kingdom post-Brexit fulfilling a sales order by traders’ UK counterparty, there will be a UK import declaration requirement (subject to the above about the temporary simplified procedure) and an Irish export declaration. There will also be the exit summary declaration on the Irish side while on the UK side the UK is waving the entry summary declaration for a period in the event of a hard Brexit.
Equally, when traders import from the UK to Ireland the reverse applies. Each such importation will require completion of the import declaration on the Irish side and the export declaration on the UK side. We have set out separately the options as to who might do the export and the UK side. This might be a UK supplier. Traders could in theory route the purchase through traders’ UK counterparty if the suppliers were unable to do customs or would not do so at an economic cost.
In the case of an Irish import, there are no temporary simplified procedures as Ireland is bound by EU customs law which is very definite as to the requirements and leaves no space for concession, at least unless the EU law is changed.
Import Declaration Data Set (EU (incl Ireland) and UK Post Brexit)
The various codes referred to below published by revenue. They are available here http://brexitlegal.ie/codes-for-export-and-transit-declarations/. Using software, traders will not need to engage with these codes as the software will make sense of the relevant returns and items to be inserted.
Box 1: Declaration Type (Mandatory)
The form can be used for imports exports and transit movements. This box identifies which type of cases involved. In the manual version, the code IM is used for an import
Box 2: Consignor/Exporter
Box 2 identifies the consignor of the goods, i.e. the sender. Enter the full name and address of the last seller of the goods prior to their importation into the Union.
Where an identification number is required, the Member States may waive provision of the full name and address of the person concerned.
Where an identification number is required, enter the EORI number. If an EORI number has not been assigned to the consignor/exporter, enter the number requested by the legislation of the Member State concerned.
In the case of groupage consignments, the Member States may provide that the word ‘various’ be entered in this box and the list of consignors/exporters attached to the declaration.
In the case of export, the exporter is the person who at the time when the declaration is accepted, contracts with the consignee in a third country and have the power to determine that the goods are brought to a destination outside the EU.
Box 5: Items (Mandatory)
Box 5 sets out the total number of items, the subject of the declaration.
Enter in figures the total number of items declared by the person concerned in all the forms and continuation forms (or loading lists or commercial lists) used. The number of items must correspond to the number of boxes 31 to be completed. Box 31 relates to the calculation of tax.
Box 7: Reference number
Box 7 allows entry of a reference number if desired. The entry concerns the commercial reference number assigned by the person concerned to the consignment in question. It may take the form of a Unique Consignment Reference Number.
Box 8: Consignee (Mandatory)
Enter the EORI number (Economic Operators Registration and Identification number; the traders’ Revenue issued reference number). Where the consignee does not have an EORI number, the customs administration may assign him an ad hoc number for the declaration concerned.
Box 12 Value Details
Set out valuation details, See sections on valuations.
Box 14: Declarant/Representative (Mandatory)
Box 14 identifies the type of representative if any involved and contact details. The representative may be indicated, and the person on whose behalf declaration is also indicated. An additional information sheet may be required in the case of a paper return.
Enter the EORI number. Where the declarant/representative does not have an EORI number, the customs administration may assign him an ad hoc number for the declaration concerned.
Box 15: Country of dispatch/export (Mandatory)
If neither a commercial transaction (e.g. sale or processing), nor a stoppage unrelated to the transport of goods has taken place in an intermediate country, enter in box 15a the relevant Union code from the published list of codes for the country from which goods were initially dispatched to the Member State in which the goods are located at the time of their release into the customs procedure. As in other contexts, software will populate this readily.
Box 17: Country of destination (Mandatory)
Enter in box 17a the Union code from the published list of codes as follows:
For the formalities for release for free circulation including end-use, or for home-use, enter the Union code for the Member State where the goods are located at the time of release into the customs procedure. As in other contexts, software will populate this readily.
Box 18: Identity and nationality of means of transport on arrival
Box 18 identifies the means of transport on which goods are loaded.
Enter the identity of the means of transport on which the goods are directly loaded at the time of presentation at the customs office where the destination formalities are completed. If a tractor and trailer with different registration numbers are used, enter the registration number of both the tractor and the trailer.
Depending on the means of transport concerned, the following details concerning identity may be entered:
Means of transport Method of identification
Sea and inland waterway transport – Name of vessel
Air transport – Number and date of flight (where there is no flight number, enter the aircraft’s registration number)
Road transport – Vehicle registration number
Rail transport -Wagon number
Box 20: Delivery terms (Mandatory)
Using the relevant Union codes and headings from the published list of codes, give particulars of the terms of the commercial contract. This relates to the Incoterms which are set out in a separate chapter. They define whether it is the importer or exporter takes responsibility for the relevant customs process.
Box 21: Identity and nationality of active means of transport crossing the border
Box 21 set out the name and nationality for the means of transport at the point of crossing the EU border.
Using the relevant Union code from the published list of codes, enter the nationality of the active means of transport crossing the Unions external frontier.
In the case of combined transport or where several means of transport are used, the active means of transport is the one which propels the whole combination. For example, in the case of a lorry on a seagoing vessel, the active means of transport is the ship. In the case of a tractor and trailer, the active means of transport is the tractor.
Box 22: Currency (Mandatory) and total amount invoiced
Box 22 sets out the currency and total amount for customs valuation purposes for currencies other than the domestic currency (/euro or sterling as the case may be)
Using the relevant code from the published list of codes, enter in the first subdivision the currency in which the commercial invoice was drawn up.
Enter in the second subdivision the invoiced price for all goods declared.
Box 24: Nature of transaction
Using the relevant codes from the published list of codes, enter the type of the transaction concerned.
Box 25: Mode of transport at the border (Mandatory)
Box 25 sets out the one-digit code for the mode of transport used at the border.
Using the relevant Union code from the published list of codes, enter the mode of transport corresponding to the active means of transport with which the goods entered the customs territory of the Union.
Box 26: Inland mode of transport
Box 26 sets out the mode of transport at the traders’ inland facilities where applicable.
Using the relevant Union code from the published list of codes, enter the mode of transport upon arrival.
Box 29: Office of entry (Mandatory)
Using the relevant Union code from the published list of codes, enter the customs office by which the goods entered the customs territory of the Union.
Box 30: Location of goods (Mandatory)
Box 30 sets out the location of the goods by country code by location code and by sheds/identity code. The codes are set out in the Tariff Volume 3
Enter the precise location where the goods may be examined.
Box 31: Packages and description of goods; (Mandatory/ Optional as to parts)
Box 31 describes the goods in any packaging to enable identification. It should give the identification number of a freight container where applicable.
Marks and numbers — Container No(s) — Number and kind
Enter the marks, numbers, quantity, and kind of packages or, in the case of unpackaged goods, enter the number of such goods covered by the declaration, together with the particulars necessary to identify them. The description of the goods means the normal trade description. Except for non-Union goods placed under the customs warehousing procedure, this description must be expressed in terms sufficiently precise to enable immediate and unambiguous identification and classification. This box must also contain the particulars required by any specific rules (e.g. VAT, excise duties). Using the relevant Union code from the published list of codes, enter the kind of the packages.
If containers are used, their identifying marks should also be entered in this box.
Box 32: Item number (Mandatory)
Box 32 enters the declared number of goods in sequence.
Enter the number of the item in question in relation to the total number of items declared in the forms and continuation forms used, as described in the note to box 5.
Box 33: Commodity Code (Mandatory)
Box 33 sets out the commodity code from the online tariff. An additional four digits apply to agricultural goods subject to CAP variable charges or anti-dumping duties.
Enter the code number corresponding to the item in question, as described in the published list of codes. The Member States may provide for entry of a specific nomenclature concerning excise duties in the fifth subdivision.
Box 34: Country-of-origin code (Mandatory)
Box 34 sets out the country of origin if a common agricultural policy export refund is being given if applicable it must set out the last country of substantial processing
Enter in box 34a the relevant Union code from the published list of codes for the country of origin, as defined in Title II of the Code.
The relevant EU code should be used to enter the country of origin. The country codes are published by the EU and are available on the above website GEONOM
Box 35: Gross mass (kg) (Mandatory)
Box 35 sets out the gross mass of goods and packaging.
Enter the gross mass, expressed in kilograms, of the goods described in the relevant box 31. The gross mass is the aggregate mass of the goods with all their packing, excluding containers and other transport equipment.
Where a declaration covers several types of goods, Member States may decide that, for the procedures referred to under columns H to J of the table in (ex-Title I, B), the total gross mass only be entered in the first box 35, the remaining boxes 35 being left blank.
Where a gross mass greater than 1 kg includes a fraction of a unit (kg), it may be rounded off in the following manner:
— from 0.001 to 0.499: rounding down to the nearest kg,
— from 0.5 to 0.999: rounding up to the nearest kg,
— a gross mass of less than 1 kg should be entered as 0.xyz (e.g. 0.654 for a package of 654 grams).
Box 36: Preference (Mandatory)
Box 36 contains information on the tariff treatment of goods. This includes preferences and various other measures such as tariff quotas. It is to be completed when goods are entering to free circulation from outside the EU.
Box 37: Procedure (Mandatory)
Box 37 identifies the Customs procedure code under the declaration. This could be for example release to free circulation and payment of duty if applicable.
Using the relevant Union code from the published list of codes, enter the procedure for which the goods are declared.
The codes to be entered in the first division are four-digit codes consisting of two digits representing the customs procedure requested and two digits representing the previous procedure.
The codes to be entered in the second subdivision are three-digit codes consisting of a letter followed by two alphanumeric characters. They must be used in relation to the procedure referred to in the first two characters
The codes for the first division and the possible combinations for the second division as set out in notes. The possible combinations are complex and depend on the particular procedure and are explained in detail in explanatory notes.
Box 38: Net mass (kg) (Mandatory)
Box 38 is usually obligatory. It sets out the weight in kilograms of goods without packaging.
Enter the net mass, expressed in kilograms, of the goods described in the relevant box 31. The net mass is the mass of the goods without any packaging.
Box 39: Quota
Box 39 sets out relief from duty against the tariff quota. The three-digit code determines whether any relief applies.
Enter the order number of the tariff quota for which the declarant is applying.
Box 40: Summary declaration/Previous document (Mandatory)
Using the relevant Union codes from the published list of codes, enter the reference particulars of any summary declaration used in the Member State of import or of any previous document.
Box 41: Supplementary units
Box 41: Where more than one of quantity is shown against a commodity code box 41 is to set out to 3 decimal places the quantity for which duty is paid. Otherwise, it is rounded up to the nearest whole number.
Where necessary, enter the quantity of the item in question, expressed in the unit laid down in the goods nomenclature.
Box 42: Item price
Box 42 sets out the item price. Enter the price of the item in question.
Box 42 requires the item price. This is the part of the invoice price relating to the item concerned. It may be the part of the invoice price from box 22 that relates to the item in accordance with the terms of delivery.
The item price must be indicated in the currency indicated in the first subdivision of box 22 and may have two decimal places. If box 22 is not used, an equivalent method of completion of box 42 applies.
If the invoice contains more than one item and the invoiced amount contains additional expenses which are comprised together for all items shown separately in the invoice the additional expenses must be divided to all items, e.g. freight costs by weight or volume. Insurance costs by price et cetera.
Box 43: Valuation method
Box 43 sets out the method of valuation used. Using the relevant Union code from the published list of codes, enter the valuation method used.
Box 44: Additional information/Documents produced/Certificates and authorisations
Box 44 is required for most types of procedures. It covers additional information, documents produced certificates and authorisations, as particular circumstances required. The box shows information about the documents certificates and authorisations concerned.
The relevant codes are to be used. The documents required to depend on any specific rules for the particular goods.
Where a quota is claimed other documentation required to support the application must be set
Using the relevant codes from the published list of codes, enter the details required by any specific rules applicable together with reference particulars of the documents produced in support of the declaration.
When goods are the subject of a VAT-exempt supply to another Member State, the information required the VAT Directive 2006/112/EC shall be entered in box 44, including when required by a Member State, the evidence that the imported goods are intended to be transported or dispatched from the Member State of importation to another Member State.
Box 45: Adjustment
Box 45 sets out the terms on which the invoice has been raised to allow for adjustments of value.
This box contains information of any adjustments when no DV1 form is produced in support of the declaration. Any amounts to be entered in this box are to be expressed in the currency unit the code for which may appear in box 44, or, in the absence of such a code in box 44, in the currency of the Member State where the import formalities are completed.
Box 46: Statistical value (Mandatory)
Box 46 sets out the statistical value of the goods in the domestic currency
Enter the statistical value expressed in the currency unit the code for which may appear in box 44, or, in the absence of such a code in box 44, in the currency of the Member State where the import formalities are completed, in accordance with the Union provisions in force.
There are codes for the currencies entered in box 44. The statistical value is to be entered as a whole number without decimal places in this currency. Box 46 is mandatory for several of the most important procedures including a release for free circulation export and dispatch.
Box 47: Calculation of taxes
Box 47 has five columns which must be completed for each duty or tax on goods that are declared
Box 47 comprises the calculation of taxes. The tax base applicable such as value weight or others should be entered.
Enter the tax base applicable (value, weight or other). Using, where necessary, the relevant Union codes from the published list of codes, the following should be shown on each line:
— the type of tax (e.g. import duty, VAT),
— the tax base,
— the rate of tax applicable,
— the amount of tax payable,
— the method of payment chosen (MP).
The amounts in this box must be expressed in the currency unit the code for which may appear in box 44, or, in the absence of such a code in box 44, in the currency of the Member State where the import formalities are completed.
The amount must be expressed in the currency of the state where the import or export formalities are completed or if a currency code is entered in box 44 in the currency thereby entered.
Completion of the columns for the type of tax and tax base is mandatory in the case of release for free circulation and end-use placing under a special procedure other than transit
Box 48: Deferred payment
Box 48 sets out the codes for deferment of payment at importation.
Enter, where applicable, the reference particulars of the authorisation in question; deferred payment here refers both to deferred payment of customs duties and to tax credit.
Box 49: Identification of warehouse
Box 49 sets out the codes for identification of warehouses
Using the relevant Union code from the published list of codes, enter the reference particulars of the warehouse.
Box 54: Place and date, signature and name of the declarant or his representative
Enter the place and date of the completion of the declaration.
Information Required by Logistics Provider or Customs Agent
If they provide the customs service to traders, traders’ logistics providers (or another third-party provider) should be able to identify what information they will require from traders to complete the R declarations mentioned above. They should be able to identify and designate the channel through which this information is to be communicated.
Traders should consider how traders’ existing order system can be supplemented on traders’ side to provide the requisite additional details. The majority of entries would apply on a routine basis and will be capable of being established and set up in standard terms. The key variables should be apparent.
It may be that traders’ logistics provider enjoys simplifications which reduce the number of the above items required on the ultimate entry. It may be that traders’ logistics provider can gather the information from basic information supplied by traders plus physical inspection of the goods. Much of the relevant information refers to the way the goods are transported and other matters within the control of the logistics provider.
Other Documents and Requirements
In addition to completing the declaration, traders need to retain certain documentation including the commercial invoice, packing list, identification documents, licensing where applicable et cetera. This is part of the basic paper trail required in the event of an audit. Traders’ existing systems would need this data for sales VAT and other tax purposes.
It may be that the tariff lines for goods involve additional requirements. This would be relatively unusual. Identification of any such requirements should be undertaken by way of a manual review of the tariff categories which can be done in the context of checking the duties. Some categories of products might involve some special handling considerations or be likely of their nature to have the relevant requirements.
Traders’ suppliers should be able to collate the information and inform traders whether there are any special tariff requirements applicable to categories of goods which impact upon the way traders’ system or traders’ personnel communicate with logistics provider’s system for collecting traders’ customs controls data.