Proof of Union Status,
E-Manifest and Expansion of
the e-T2L
José García, Port Authority of Valencia
B2MOS Mid Term Conference
Valencia, 30 October 2014
1
Table of Contents
1. Proof of Union Status
2. E-Manifest, E-T2L and PoUS
3. Questions for the Discussion Panel
2
Introduction
• The Proof of Union Status (PoUS) is a very important document in the
Motorways of the Sea environment.
• It is required for the transport of goods that enter or leave the EU.
• Customs are required to check the status of the goods.
• Performed by consulting the PoUS system.
• Using the paper T2L document as confirmation of where the goods
originated.
 A new PoUS system is proposed, with aim to integrate it into existing
shipping businesses IT departments….to replace the current paper T2L
with an electronic equivalent.
3
Current situation
• At present, the PoUS document is in paper form.
However, the electronic T2L is available in some countries
e.g. Spain and Belgium (Table 1).
Table 1: Member States and the type of documents used for PoUS
Country
•
e-T2L
T2L
Pre-authenticated
T2L
UK
✓
✓
Greece
✓
Spain
✓
Belgium
✓
C-Status
Manifest
Commercial
invoice
✓
✓
✓
✓
✓
Germany
✓
Slovenia
✓
N.B. Only a sample of shipping businesses were interviewed in each country, and thus it is not to say that each of the
countries do not use other types of documents for PoUS as otherwise stated in Table 1.
4
Proposed system
 Summary of the proposed system
• A new PoUS system is being proposed, which will be integrated
into existing shipping businesses IT departments.
• It is expected that the new PoUS system will become mandatory
for Member States.
• The e-Manifest will allow the PoUS to be checked faster, thus
allowing the status of the goods to be indicated quicker.
5
Proof of Union Status
Main functionalities
6
Electronic POUS in the European Union
PoUS System - Request to register PoUS
7
Electronic POUS in the European Union
PoUS System - Validaton of PoUS
This process is based on the assumption
2nd QUARTER 2014. Vision document
that a national system will be developed
1st QUARTER 2015. Service Specifications
which will interface to a Central Repository
3rd QUARTER 2015. Technical Specifications for the registration of the proof. Only a fully
4th QUARTER 2017. PoUS Operational
validated proof will be stored in the Central
Repository.
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Table of Contents
1. Proof of Union Status
2. E-Manifest, E-T2L and PoUS
3. Questions for the Discussion Panel
9
The synergy of the PoUS and e-Manifest
• The combination of the PoUS system and e-Manifest will provide an
electronic environment for port customs in MoS.
• As an authorised consignor, the PoUS procedure is greatly simplified
(only the e-manifest is needed for proof at re-entry).
• Commercial documents are usually archived for up to 2 years as
required by law  link to the e-archive initiative as a way to increase
efficiency
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E-Manifest
Main functionalities: Maintenance of the Export Procedure
11
E-Manifest
Main functionalities:
Simplified transit procedure
Assistance to safety and security processes
Support to other customs requirements
Excise goods
Requirements from maritime authorities
…
12
E-Manifest
November 2013.
Way forward
January 2014.
Draft legal provisions
July 2014.
e-Manifest legal provisions voted
June 2015?
e-Manifest implemented jointly with Directive 2010/65/EU
The e-Manifest is defined as a document allowing for the identification of goods
for Customs purposes
Authorised consignors vs non-authorised consignors
Simplifications facilitating the free movement of goods by sea in the Single
Market
Validation of the PoUS can be done within the e-Manifest framework
Implementation of a harmonized e-Manifest: Combined with the
implementation of Directive 2010/65/EU.
13
Authorised vs Non-Authorised Consignor
The best option is that all shipping companies that ship goods with Union status
become authorised consignors and use the e-Manifest.
Authorised consignor
Non-authorised consignor
Not required to request the endorsement of
the PoUS
Required to request the endorsement of the
PoUS to customs
Not required to stamp, sign or endorse any
document if they use the e-Manifest
Required to prepare the documentation
required by customs for its endorsement
Not required to use the PoUS system (when
available)
Required to use the PoUS system (when
available)
Only required to mark the goods which have
Union status in the e-Manifest
Required to mark the goods which have Union
status in the e-Manifest and include the PoUS
reference
Not required to hold the PoUS at the time of
presenting the e-Manifest
Not required to hold the PoUS at the time of
presenting the e-Manifest
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Latest update
Proof of Union Status (PoUS System) – 02.10.2017
4 month delay at current situation – from the view of the COM it is not a problem
It will be the Replacement of T2L / T2LF  but only for AEOs?
A link between the declaration of “Temporary storage” and the PoUS was not
planned but after IPCSA comment to the Commission meeting on the 11th July, an
automatic check will be implemented
Registration of the applicant – Everyone now needs an EORI ? (still to be confirmed)
15
Table of Contents
1. Proof of Union Status
2. E-Manifest, E-T2L and PoUS
3. Questions for the Discussion Panel
16
Open questions
Who is taking responsibility for defining the harmonised format of the e-Manifest
and the overlap with the National Single Windows created under Directive
2010/65/EU?
What are the criteria in each Member State to become an authorised consignor?
Who needs to become an authorised consignor, the shipping company or the
national offices/agents of the shipping company in each Member State?
What auditing requirements will be established for authorised consignors?
What validations will be introduced in the MRN of the PoUS to be included in the eManifest for non-authorised consignors?
Will the e-Manifest be able to be used as a Summary Declaration for Temporary
Storage?
Will the e-Manifest be able to be used for the calculation of port taxes or dues
(when required)?
Could the PoUS system remove the requirement to present the ENS of Union goods
when the ship calls outside the EU? And remove the requirements to present the
EXS of Union goods that are transhipped in a third country port?
In such cases, will it be more efficient for authorised consignors to register the PoUS
in the PoUS system even if no endorsement is required?
17
Questions for the discussion panel
Q for IPCSA:
The POUS procedure is directly related to how the manifests are managed, what is the
position of IPCSA on the idea of DG-TAXUD to adopt a unique format of Summary
Declaration of Temporary Storage for the whole EU? How would this affect IPCSA
members?
Q for MCP:
What is MCP’s view on the previous issue?
Q for Italian Customs:
The e-POUS may only be a reality at the end of 2017. Given the considerable benefit
that the e-T2L generates and its short payback period, could the e-T2L be
implemented in Italy before?
What is the view of Italian Customs concerning the adoption of a unique format of
SDTS?
Q for Spanish Customs:
Could some of the functionalities of the e-T2L may be of use for the future e-POUS?
Which are the best practices generated in Spain that could be of use for the POUS
implementation?
18
Electronic T2L
LESS COSTS
LESS TIME
T2L Problems
When forwarding Union goods
Paper presentation of the T2L in customs
Physical post of the document to the European port of
destination
Unfairness and increased time and costs compared to
exports. Worst customs controls
When receiving Union goods
Paper presentation of the T2L in customs
Manual accounting and checking of the goods with the
SDTS by customs
Unfairness and increased time and costs compared to
imports. Worst customs controls.
e-T2L : The solution
Automation of the justifiation of Community
status of the goods (T2L) through electronic
T2L issuance and reception.
Objective: Avoid trips to the customs office to
get the visa of the T2L document and to check
and account the T2L in front of the goods items
in the SDTS.
Improve the control of these goods.
e-T2L : ¿How?
 It was produced the electronic declaration and the T2L
electronic form for forwarding Union goods
 It was produced the electronic declaration and the registration
form for non-electronic T2L documents to be presented in Spain.
It was produced the electronic declaration and clearing form of
the T2L (JEC), which automatically links and settles item quantities of
the proof of Union status with the goods items declared in the SDTS
was produced.
 Definition of filters and CLEARANCE for the electronic T2L and
the electronic proof of Union Status (JEC) declarations.
 Settlement of the goods declared in the SDTS with the goods
declared in the T2L documents.
Electronic T2L national solution recognized by the other Member
States.
e-T2L: CASES
Case 1. Forwarding of the e-T2L and Reception in Spain
Anexes box 44
1. T2L Electronic declaration
Operador
2. Electronic
countersign and
creation ofthe T2L
Forwarding
Spanish
Customs
3. T2L settlement electronic message
4. Electronic countersign and
clearance of the proof of
Operador
Union Status
(JEC)
Arrival
Spanish
Customs
Release
e-T2L: CASES
Case 2. Forwarding e-T2L in Spain and Reception in another MS
Anexes box 44
1. T2L Electronic declaration
Operador
2. Electronic
countersign and
creation ofthe T2L
Forwarding
Spanish
Customs
3. Verification
T2L
Arrival in another Member State Customs Office
T2L electrónico
T2L Document
Electronic T2L
A Customs office in another Member State can verify the authenticity of the T2L certificate
Verification in the customs website without the need of a digital signature
Electronic T2L
Verification including the Security Verification Number
T2L electrónico
Verification in customs website and use of QR
e-T2L: CASES
Case 3. Forwarding T2L in another ME and Reception in Spain
Forwading Customs in
another ME
Annex T2L
1.
Indirectly register
the T2L
2. Acknowledgment
3. T2L settlement message
OPERADOR 4. Countersign and generation of a
customs release notification
JEC
* Additionally to other ME, it could be
generated in paper or by an authorised
operator
Aduana
Llegada
Clearance
e-T2L : ¿When?
 Agreement of the Council of Ministries of 16-09-2011 for
reducing administrative burdent to companies.
 Development of the solution by the Customs & Excise
Department, the IT Tax Department and Valencia
Customs Office and Port Authority.
 Pilot with some operators (ARKAS,GRIMALDI...) in
may 2012
 Generalisation of the solution to all operators in july
2012
Evolution
Electronic T2L
Estatistics forwarded eT2L (29-09-2014)
e-T2L expedidos
25.000
20.000
19.822
17.728
20.680
19.948
17.571
16.624
14.962
15.000
12.008
10.368
10.000
5.000
1.608
0
2T 2012
3T 2012
4T 2012
1T 2013
2T 2013
3T 2013
4T 2013
1T 2014
2T 2014
3T 2014
T2L electrónico
Statistics e-T2L
indirectly register /JEC
Datado electrónico T2L / JEC
(29-09-2014)
4.500
4.000
3.936
3.711
3.500
3.684
3.646
3.475
3.211
3.000
2.500
2.487
2.606
2.086
2.000
1.500
1.000
500
187
0
2T 2012 3T 2012 4T 2012 1T 2013 2T 2013 3T 2013 4T 2013 1T 2014 2T 2014 3T 2014
T2L electrónico
Goods
shipped wit an
e-T2L versus a
paper T2L
Embarque mercancía UE
70.000
(29-09-2014)
60.000
50.000
35,1 %
27,7 %
40.000
30.000
T2L papel
e-T2L
73,4 %
20.000
64,9 %
72,3 %
10.000
26,6 %
0
2.012
2.013
2.014
T2L electrónico
Settlements of
SDTS with
electronic
proof of Union
Status vs
manual proof
of Union
Status
Datados DSDT
40.000
35.000
30.000
63,6 %
25.000
20.000
(29-09-2014)
JCE
84,7 %
55,1 %
15.000
10.000
36,4 %
44,9 %
5.000
0
15,3 %
2.012
2.013
2.014
JEC
e-T2L Ventajas
Presentación on-line con
CSV
Seguridad en destino
Rapidez de gestión a la
llegada
THANK YOU FOR YOUR ATENTION
B2MOS Mid Term Conference
Activity 1: Interoperability in MOS
Proof of Union Status, E-Manifest and
Expansion of the Electronic T2L
Valencia, 30 October 2014
Francesco Cusmai
Direzione Centrale Tecnologie per l’Innovazione
Ufficio Integrazione Applicativa
PoUS – State of the art (1)
• UCC article 6
– all exchanges of information between customs authorities and
between economic operators and customs authorities shall be
made using electronic data-processing techniques
• UCC article IA-V-1-00
– an electronic information and communication system shall be
used for the processing and exchange of information relating to
the customs status of goods
Implementation of a new business process related
to the issuing and presentation of the T2L document
replacing its paper form by electronic means
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PoUS – State of the art (2)
• Business Case for Proof of Union Status
– Published by the European Commission on 15/04/2014
• PoUS (Proof of Union Status) system
– creation of an IT system including the setting up of a Central Repository for
the storage and exchange of PoUS document data between Customs
Authorities across all Member States
– centrally developed and centrally operated application
• Pros
– Shorter implementation time
– Reduction of costs
– Harmonization of the Customs Union
IT environment
• Cons
– Poor integration with MS national
applications
39
PoUS – State of the art (3)
• How to mitigate the weaknesses of a centrally developed and
centrally operated application?
• Open solution  Web services
–
–
–
–
automatically accessing to central PoUS data
enhancing risk analysis and customs’ controls
linking different customs processes at national level
speeding-up PoUS-related formalities
Italian Customs Agency will support this solution in
the context of future PoUS technical requirements
40
PoUS simplifications
Authorized issuer
• Italian Customs Agency fully agrees with article
PoUS of goods shall be provided by an authorised issuer pursuant to Article DA-V-1-09
IA-V-1-11
(513-12-DA) by specifying the appropriate status code on the electronic manifest.
Non-Authorized issuer: ?
• Italian Customs Agency supports the proposal of indicating
the Union status of goods in the e-manifest provided that
– PoUS will be submitted to the PoUS system and endorsed by Customs
at the port of departure
– Non-authorised trader will be subject to a risk analysis and, if needed,
to customs controls
The shipping company should always include the MRN of the PoUS in the
e-manifest in order to let customs carry out necessary controls as quickly
as possible. However, in case of need, the MRN could be optional.
41
Legal provisions of the PoUS
• DA/IA: second
(25/08/2014)
preliminary
draft
provisions
PoUS provisions (Chapter 1 – Title V) might need to be redrafted
as a result of the on-going work on the e-manifest
Business Case (published in April 2014) to be amended accordingly
42
PoUS & e-Manifest
• Italian Customs Agency fully agrees with the implementation
of a harmonized and electronic manifest as soon as possible
• Problems:
– Not possible at moment due to the lack of an agreement between
Member States
– The project fiche “Blue Belt initiative and e-Manifest” has been
deleted from the last version (Rev. 2014 v1.0) of MASP (Multi-Annual
Strategic Plan) published on 02/07/2014
However, even if a harmonized manifest is not possible in a short time,
at least an electronic version should be operational in all Member States
43
e-Manifest in Italy (1)
Italian Customs Agency has its own version of electronic manifest,
which is used as Notification of Arrival, Manifest of Inbound Goods and
Temporary Storage. It is also fully integrated with the previous ENS
(ENtry Summary declaration) and the subsequent customs declaration
44
e-Manifest in Italy (2)
• Our electronic manifest already accepts the declaration of
goods with “Community” status
– In this case, the manifest only serves as notification of arrival and
manifest of inbound goods (no temporary storage is created)
– At present there is no possibility to declare a reference to the T2L
paper document
• We are already amending our manifest in order to be
compliant with the future PoUS system
– A new specific field has been added with the aim of giving economic
operators the possibility to declare the MRN (Master Reference
Number) of the PoUS
– This amendment will be operational by 2016
45
e-Manifest in Italy (3)
• We are amending our electronic manifest to be compliant
also with the Directive 2010/65/EU
– IMO FAL forms data will be included in the e-Manifest for the fulfilment of reporting
formalities
– This amendment will be operational by 01/06/2015
Recommendations
• All shipping companies carrying goods of Union status should
become authorized consignors as this will lead to a reduced
effort compared to non-authorized traders. In these cases, no
Customs control should be necessary
• Successful key elements in the Spanish electronic system
related to the T2L
– Italian Customs Agency fully agrees with them because their aim is to
•
•
•
•
•
•
harmonize the customs union IT environment
simplify and speed-up PoUS-related formalities
enhance risk analysis and customs’ controls
link different customs processes at national level
reducing costs
improving the throughput of all parties involved
47
Tests or pilots for B2MOS partners
• Italian Customs Agency is willing to participate and
collaborate with B2MOS partners, stakeholders and any other
interested Member State, to a pilot project concerning the
implementation of a harmonized electronic manifest
48
Thank you for your kind
attention!
[email protected]
Direzione Centrale Tecnologie per l’Innovazione
Ufficio Integrazione Applicativa
www.agenziadoganemonopoli.gov.it
Thanks for your attention!
www.b2mos.eu · [email protected]
50