WSC position on the reform of the Union Customs Code
The Customs Union Acting as One: WSC supports the proposed UCC Customs Data Hub with a Shared Trader Interface. The current mosaic of divergent national customs systems generates significant costs, duplicate IT developments, additional functional data sets, contradictory submission processes and uncoordinated system deployments. This represents a significant economic drag for Europe.
A Stable Legal Transition: Until deployment of the EU Customs data hub, the existing UCC secondary legislation and data annexes need to be maintained to enable the core UCC IT Entry Systems, including ICS2 to function. The EC draft proposal lacks adequate transitional provisions for the Entry Processes.
Cargo Security: New importer/exporter obligations, including provision of advance cargo security data are an important step forward. But powers to prevent a carrier from unloading the goods, in case of missing data could severely disrupt trade.
Provision of Advance Cargo Data on Arrival: Parties other than the carrier also need to be legally required to provide missing advance cargo data once the goods have arrived. This would mirror the current UCC and the new proposal’s pre-loading ENS filing requirements.
Port of Arrival vs Port of Discharge: The reform proposal does not distinguish between cargo remaining on board a vessel and cargo to be unloaded in a specific EU port. Cargo should only be placed in temporary storage or under a customs procedure at the intended port of discharge not the first EU port in a vessel rotation.
Temporary Storage: Proposed reduction of temporary storage from 90 days to 3 days is likely to have serious negative implications for import and transhipment processes in EU ports. The objectives of this change remain unclear.