The Modernisation and Simplification of the European Customs Environment

The current Commission proposals for amendments of the Community Customs Code are of the highest importance for the European Engineering industries since its competitiveness depends highly on its ability to trade on the immediate availability of imported inputs for the manufacture of its products.

While Orgalime fully supports the objective of simplifying and modernising customs legislation and procedures in the EU and worldwide, prior to the meeting of the EU Customs Committee Orgalime expressed its concerns on a number of practical consequences that certain articles of the above-mentioned document would imply and asked the Commission to consider Orgalime’s comments on the status of an Authorised Economic Operator (AEO), the required set of data for the prior declarations and on the 24-hours rule.

Orgalime believes that for companies the status of an AEO should lead to a real simplification of the administrative burden and a meaningful relief. Companies will only be willing to bear the efforts and costs of obtaining the status of an AEO if they receive in exchange sufficient advantages. We are therefore of the opinion that AEOs should be exempted from the pre-arrival and pre-departure declarations as well as from the physical control. Looking at the international context, it is furthermore essential that the EU negotiates with its trade partners and obtains a full acceptance and recognition of the AEO.

In the attached position paper we also argue that the required set of data for the prior declarations should be decreased for both AEOs and others, since we fear that the requirement of too many data elements would in practice mean the end of the simplified custom clearance procedure.