CVB requires good preparation
From 4 October 2021, Dutch Customs introduces the Container Release Notice (CVB) in stages. The procedure for the submission of detailed declarations for maritime cargo from outside the European Union will change considerably as a result. Declarants in all of the port sectors must make the proper preparations for these changes, as the CVB does not only apply to containers, but also to trailers, mixed cargo and bulk cargo coming by sea.
As a result of the Container Release Notice, Customs has more stringent requirements in respect of the declarations for goods from outside the EU that come by sea. From now onwards, there will be checks as to whether the detailed declaration of a maritime load corresponds to the Declaration for Temporary Storage (ATO). In this way, Customs wishes to counteract the filing of incorrect declarations.
What is the CVB?
Customs compares the CVB with the detailed declaration from a customs forwarding agent or an importer to see if it corresponds to the ATO from a shipping company or a shipbroker. Goods cannot leave a terminal if the number of the Bill of Lading (B/L-number) and the weight set out in the detailed declaration do not correspond to the ATO.
Once the CVB has been introduced, the detailed declaration is not possible until the arrival of the ship in the Dutch port, in conformity with the Arrival Notification (Actual Time of Arrival or ATA). Which means: not until the goods have actually been unloaded. Customs can ensure that the information in the detailed declaration is the same as the information in the ATO. If the details do not match, Customs will reject the detailed declaration and the permission for the departure of the load will not be given.
Risk of disruptions tax-wise
Up to this point in time, ATOs were discharged by detailed declarations retrospectively, which made it possible that Customs released import declarations prior to the goods actually having been unloaded. “We are going to make it possible to make declarations ahead of time by using the CVB”, says customs officer Thom van Vugt – who is the first point of contact for the CVB in Rotterdam. “It is also a requirement ‘Brussels’ has, which has been an issue for some time to have an obligatory match between ATOs and the detailed declarations. The risk of disruption tax-wise and correcting declarations of maritime import loads is a result of checking retrospectively and correcting declarations. As a result, the risks of filing a declaration at the incorrect rate increase, if the import declarations are being filed prior to the goods actually being in a Dutch port. Another disadvantage of the current import process is the large number of mismatches between the ATOs and the detailed declarations: the data on both declarations often do not match.”
At the moment, Customs has to deal with approximately 60,000 mismatches a month. Van Vugt: “This year the number of mismatches substantially increased, also as a consequence of Brexit. Many entrepreneurs doing business with the United Kingdom have no experience of customs formalities and they may have underestimated the declaration process. As a rule, most of the errors are in the specification of the gross weight: the weight on the packing list or the invoice does not correspond to the ATO. In addition, there are incorrect Bill of Lading numbers as well as differences in the number of packaging units or packages.”
“Such mismatches provide a lot of need for adjustment”, as put forward by Van Vugt. “It applies to Customs as well as to all the links in the logistics chain. Things have to be checked, declarations have to be corrected and companies run the risk of getting substantial fines. The CVB prevents this from happening and it forces companies to make correct declarations.”
More stringent checks
The CVB is therefore introduced on 4 October 2021, after having been delayed, especially on account of Brexit and due to the corona crisis. Van Vugt: “From that date onwards, Customs will always check beforehand whether the ship has come in and whether the goods have been presented if the detailed declaration is being made. If the ship has not arrived yet and there is no ATA yet, the detailed declaration will not be accepted. Customs will furthermore check more stringently whether the numbers of packages and the weights set out in the detailed declaration correspond to the details on the Bill of Lading. Any deviations will lead to error messages. In addition, Customs will reject any detailed declarations that have incorrect Bill of Lading numbers.”
The CVB will be introduced in stages. “From 4 October 2021, we are going to check whether the data of the import declarations in AGS match to the ATOs”, explains Van Vugt. “The import declaration includes both the pre-declaration prior to the arrival of a ship and the follow-up declaration following the arrival of the ship. We will gradually increase the intensity of our checks. From the last quarter of 2022, Customs no longer releases any follow-up declarations, as long as checks are still pending. We will keep a more critical eye on the weight and the quantity of packages.”
Make timely preparations
The introduction of the CVB affects anyone in the logistics chain. Declarants (customs agents and importers), shipping companies and freight brokers, importers (non-declarants), carriers, container terminals and ferry operators will all be faced with it. “Make sure that the CVB is not in the way of your load”, is the appeal of Van Vugt. “Your company can avoid problems by making timely preparations for the CVB. Ensure first of all that the declarations have been completed correctly. Correct declarations prevent unnecessary delays. However, there is another way to get a load quickly and unchanged through the port after the introduction of the CVB: the pre-declaration with an automated presentation message.”
That last method is the most efficient according to Van Vugt. “Customs processes pre-declarations prior to the arrival of a ship. The only thing that must take place upon arrival of the ship or the unloading of the cargo, is the confirmation of the pre-declaration by way of an automated presentation message. Providers of logistics services offer several solutions.”
Trade organizations, interest associations, Portbase and Customs have joined forces for a smooth introduction of the Container Release Notice (CVB). Via the website: www.voorbereidophetcvb.nl all of the parties in the logistics chain are informed and urged to get ready and prepared for the CVB.