Making the Declaration
Either the trader or its agent, which might be a customs agent or a freight forwarder, logistics provider/carrier acting as customs agent must make the return to revenue and receive a green routing in order to proceed without any checks.Putting the customs information together involves time and resources. Stock management systems and processes may need to change.
The export declaration must be lodged within certain time limits prior to the goods leaving. This can vary from 30 minutes in the case of air traffic to 2 hours in most cases and in some cases, which probably will not apply to UK trade, 24 hours
The length of time required to complete the return can vary from a few minutes where it is routine, and a previous template is being used to considerably longer where the relevant information required to do the return must be gathered and ascertained.
Once the return is made it is either accepted or rejected by the revenue system. The return will be accepted if it is correctly completed in the sense of entering the correct format of data. Acceptance in the sense in no way verifies the document and the onus is on the exporter to ensure all information is correct and valid.
Risk Analysis
Revenue and customs authorities use the information declared for the purpose of risk assessment to consider whether to permit the movement (green routing) to make a documentary check (orange routing) or make a physical check of the goods (red routing). This is done automatically by computer algorithms.
The customs office of export, in this case, the Irish Revenue, undertakes risk analysis by automated computer process and issues clearance to exit in almost all cases. The exporter must receive notice of acceptance and approval from the EU office of exit.
The customs office of export undertakes a risk analysis on the basis of the full declaration and decides whether controls are necessary prior to export. The assessment is made by computer program analysis based on input from revenue authorities throughout Europe. The risk issues depend on the nature of the goods, the traders, the carrier and the circumstances of the movement. These factors may make a documentary or physical check more or less likely in the circumstances.
In practice checks on exports are unusual. They do sometimes occur to verify the zero rate VAT claims. In some sectors, where goods are subject to licensing and control they would be more common. This may occur because of the nature of the goods or, for example, their destination, where sanctions apply,
Apart from checks arising from risk factors based on the information returned, Revenue is obliged to make a certain amount of random checks for basic enforcement and confirmation purposes. What is declared must conform with what moves. There is the risk that the returns made may not be accurate or complete. There is the risk that consignments may include other undeclared or wrongly declared goods.
Exceptionally some issues require further clarification so that a requirement for presentation arises. Licensing requirements may apply to the export of particular types of goods, which must be held and can be requested. Where the goods are released for exports an appropriate message is sent to the exporter.
Revenue may alternatively decide to perform additional risk analysis. The goods are released on the condition that they exit the territory of the EU. The carrier informs the customs office of exit which informs the customs office of export if different from the office of exit.
Routing
Upon acceptance of the declaration by the revenue system, they will be allocated green routing orange routing or red routing. Green routing means the goods have been cleared on the basis of the declaration received. Green routing issues in almost all cases. Documentary or physical checks are rare in the case of exports.
Orange routing means goods so that they require a documentary check. The documents must be presented before the goods may be cleared. Red routing means the goods have been selected for a physical examination and a documentary check. For example, an export licence might be inspected, where this is a requirement This must take place before the export occurs.
In the case of an export, the routing message issues when the declaration is accepted. However, in principle, the goods can be inspected by Revenue at any time prior to when they leave the jurisdiction. In practice, export interventions and checks are relatively rare outside of certain less typical types of cases where particular risks arise.
