As we discussed in our previous blog post, the European Commission brought forth the EU customs reform, which puts forward some of the biggest changes in centuries for EU customs. In this blog post, we focus on one specific topic that will impact economic operators, namely the change that is proposed for the duration of Temporary Storage (TS).
Where operators are currently allowed to store goods under Temporary Storage for 90 days, the European Commission proposed to reduce this timing to only 3 days, or 6 days in the case of an authorised consignee. Reasoning behind it is three-fold:
- The EU Commission wants the goods flow as real-time as possible
- The EU Member States want to have better coverage of customs debt under TS
- The EU Commission wants the operators to provide or make available the data to customs as soon as this is available, which gives customs authorities ample time to carry out a risk analysis and take appropriate measures.
However, this stark reduction in the Temporary Storage timeframe poses some significant challenges to economic operators. Some thoughts from our side:
- Why decrease the duration of TS when the new ICS2 system is already foreseen to capture the necessary data in order to carry out the risk analysis? Additionally, with the introduction of the UCC in 2016, the TS duration was extended for specific operational reasons that still apply.
- How will this impact TS authorisation holders when all EU entry points were built based on the concept of Temporary Storage for longer than 3 days?
- How will economic operators cope with this change and how will it impact their processes for importing goods when most of their entry flows are designed based on the concept of Temporary Storage?
Taking the above questions in mind, we would like to raise awareness of the impact the change could have.
Our suggestions:
- We heard from operators that they were upset and surprised about the proposed changes to the Temporary Storage duration. Therefore, we are of the opinion that this part of the UCC reform should be revisited. Official feedback must be submitted to the European Commission by 30/09/2023, consolidated per EU Member State.
- We recommend that economic operators begin reviewing flows and processes now to see where there is a link to Temporary Storage and how the change may affect trade if it enters into force.
- As it is a general tendency of the EU Commission to have data more upfront and pre-lodged, check whether your processes are designed and automated as much as possible to cope with this change in timing.
Feel free to reach out to Portorium Solutions for assistance on the abovementioned actions.