It’s official! Re-export requirements are effective from 1st May 2016 and things are going to change! As a consequence, Customs will introduce an additional re-export declaration for bonded goods which are to be exported outside the EU. In the past it was sufficient to just submit an NCTS declaration for these goods, however this will no longer be the case.
For owners of a bonded warehouse this means that their processes will need to change. Where an NCTS declaration is currently created for an export (often done with a simple click of the button), it will now become necessary to submit an additional re-export declaration first (and receive a positive response) and then submit the NCTS message.
Even though it’s been stated that this declaration will be mandatory from the 1st of May 2016, it is not quite clear how the declaration should be created. In our view, there are only two paths Customs can choose:
- If you have migrated from DSU to AGS Export prior to the 1st of May, the re-export declaration will also have to be submitted through AGS.
- For companies migrating from DSU to AGS after the 1st of May, the re-export declaration will most likely have to be submitted through DSU.
Should you choose to transport the goods to the place of exit without the coverage of the re-export declaration, the goods will remain in the bonded warehouse regime (and your records) until a DMSEOG / NLEC03 message is received from the final recipient.
In short, the obligation to declare the re-export will cause a change in your business processes. For those who now use a fully automated outbound process for their bonded warehouse it will also require a change in the software. To report the new details a change in the GPA reporting will also be required.
If you have any questions about the introduction of the re-export declaration, or about the potential consequences for you, contact us via firstname.lastname@example.org or schedule an appointment to discuss how this might affect you in more detail.