The match between departure and destination
The Central Clearing Office of Dutch Customs – which is based in Heerlen – has no fewer than one hundred staff members, spread over five teams. Two of them, Saskia Bosch and Rob Beekman, tell about their work. “Each shipment of goods must be properly checked out upon arrival. If not, we will do everything we can to find out what happened to it.”
“Clearing is an important task, which has aspects in common with several processes – such as Temporary Import, Inward Processing and Customs Transit,” Beekman begins. “In addition, its fiscal importance is considerable – for the Netherlands and the other EU Member States, as well as for businesses. For we want to ensure fair competition within the EU. This is only possible if everyone meets their obligations.”
In principle, clearing comes down to comparing the data from the customs office of departure with the data from the customs office of destination. For instance, all goods stated in the declaration must be presented to an office of destination or authorised consignee, and the transit period must not be exceeded. If all these conditions are met, the customs transit procedure will be cleared in the customs systems.
Difference in weight or number
“But there are also cases where declarations are not cleared,” Beekman explains. “For example, when the office of departure is located in the Netherlands, and there is no message from the office of destination that the goods have arrived correctly. Or if the office of departure asks us as the office of destination to check whether the goods have arrived and been presented in the Netherlands. A third possibility is that a difference in the weight or number of packages emerges when goods declared for transit are unloaded in the Netherlands. For example, a container weighing 1,000 kilograms arrives in Rotterdam, containing 100 packages. This container has been declared for customs transit. As the container is sealed, we do not check it in the port. It is put on a lorry and transported to its final destination, let’s say an importer in Maastricht. This importer then establishes that the number of packages differs from the original number of packages and reports this in the Transit customs system. This example shows that such difference sometimes only becomes clear at the place of destination.”
“When we receive such a signal, my Enquiry cluster comes into action,” Bosch says. “The party declaring the goods must then convince us that the difference already existed before the shipment was sent. And there may be a good explanation for this. Sometimes, the container in question was not fully loaded in China, but was only half full. That is inherent to the speed of logistics. Or take e-commerce, for example, where boxes full of small packages are thrown into a container. That container is rented for, for example, 1,000 boxes, but because some boxes are somewhat large, it can only carry 998 boxes. This is no longer adjusted in the bill of lading; it will show the initial 1,000 boxes.”
“Another possibility is that a transit period has expired, and we are not informed that the corresponding transport document has been properly ‘terminated’. In that case, we will first contact the declarant or the consignee, if they are established in the Netherlands, and, if necessary, the office of destination abroad. For example, I often ask colleagues from other European customs administrations by chat or e-mail to sort something out for me. For instance, the German customs authorities can check whether that one importer in Aachen has received and declared the goods – we cannot contact that importer ourselves. Conversely, colleagues from other Member States regularly ask for a missing invoice or bill of lading. In general, this cooperation goes smoothly within the EU.”
Determining a possible customs debt
Crimes are committed as well, and declarants are certainly not always to blame for this, Bosch says. “Sometimes, a load of goods is stolen from a lorry in a parking lot at night, for example. This theft must then be reported by the affected party as soon as possible. However, the most common statements are: ‘oh, we forgot to check out that shipment’, or: ‘the system was down’. Sometimes, a document is drawn up for onward transportation. In that case, the declarant must be able to demonstrate that the shipment has arrived at its destination and that a subsequent customs procedure has been carried out, after which I can terminate the document. In other words, I make every effort to find out what happened to a shipment, for the main purpose of establishing whether a customs debt has arisen – and if so, who pays the bill.”
Shoes or socks?
Businesses may submit supporting documents enabling the Clearing Unit to terminate a transport document, in which case no request for payment (RFP) will be issued. However, they do not have unlimited time to do so, Bosch explains. “And sometimes a declarant or consignee does not respond at all. In that case, it ends here for us, and we will transfer the case to the collection department. However, we often see that businesses still take action and send supporting documents after having received such prior notice. And they are allowed to do so.”
“Those supporting documents must, of course, meet certain requirements,” Beekman says. “For example, there must be a match between the goods that were sent and the goods that arrived at the place of destination. That is self-evident, one would say. Yet, I once experienced that a shipment of shoes had gone missing, but socks had been supplied instead. We then assess whether things already went wrong during shipping. Was it actually a consignment of shoes at first? For there are businesses that manufacture both types of products. If it were actually shoes at first and we only find those socks, then those missing shoes have to be recovered.”
Beekman continues: “Once we have prepared the bill, taking into account the different customs duties, debtors will first receive prior notice from us. They are given one month to reply. During that period, they can demonstrate with additional information that the goods arrived at the office of destination. If those data are correct, we can still proceed to discharge. If this is unsuccessful, missing invoices and bills of lading can still ensure that we send out a correct RFP. And such RFP is not without obligation.”
Depending on other countries
Sometimes time is a factor. If so, a declarant is unable to present the requested supporting documents within the set time limits. The declarant can then object to the RFP, but only by introducing new facts. Beekman: “Customs allows most of those objections when we receive the requested additional information afterwards. It could take six weeks for a customer to receive written confirmation from India that their shipment was properly cleared there. So for clearing purposes, we also depend on the working methods and swiftness of other countries.”
Thinking along with customers
Finally: can businesses contact Bosch, Beekman and their colleagues directly if they have any questions? “The first point of contact is our Businesses Contact Point,” Beekman says. “There they can put you through to the department responsible for issuing authorisations. On our website www.douane.nl, you can also find useful information about the clearing process.” Bosch: “As said, we are in direct contact with businesses or their declarants, but that is because of investigations that are launched. Incidentally, we do try to think along with our customers. For example, if we see that a declarant regularly fails to correctly check out documents, we will forward such a signal to the Customer Profiles cluster. This cluster will then contact the declarant: why is this, why do you keep making errors?” Beekman: “In the end, both we and our customers benefit from customs formalities being handled in the best possible way.”
National units in the spotlight
Dutch Customs has several national teams and units, all of which focus on specific tasks and have highly specialist in-house expertise. As knowledge and advice centres, they support the customs regions and often customs clients as well (be it directly or indirectly). Some of these organisational units (such as the Central Import and Export Service, the Central Excise Unit and the National Customs Help Desk) have been discussed in Customs NL inSight before; other units have so far received less attention. In this issue, we will highlight five of the latter group of units: our national units that deal with valuation, tariff classification, origin, guarantees and clearing respectively.