The UCC is the new framework regulation for the rules and procedures for customs throughout the EU. It reflects a move towards a more modern customs environment for EU countries, making European business more competitive and advancing the EU Strategy for growth and jobs.

More specifically, it will:

·streamline customs legislation and procedures across the EU;

·offer greater legal certainty and uniformity to businesses and increase clarity for customs officials;

·simplify customs rules and procedures to make customs transactions more efficient and modern;

·complete the shift to a paperless and fully electronic and interoperable customs environment;

·introduce more speedy customs procedures for compliant and trustworthy businesses.

The UCC should be fully implemented by the end of2020. During the transitional period, the new rules will apply by using existing IT systems and, in some cases, paper forms. Work to develop the new systems or to upgrade existing ones has already begun.

What are the issues of concern in the UK?

Existing Bonded Warehouse arrangements:

This concerns cold stores that have their own approval number to accept and handle goods under bond, over a wide range of commodity codes.

The new UCC regulations seem not to be only hindering the ability of UK cold store operators  to service their many and varied clients but are to subject them and their clients to restrictions, that might force them to reconsider providing such a service and placing many UK trading companies at a distinct disadvantage to others and their ability to compete.

Guarantees

Previously, for those clients who import high value/risk items such as those under commodities 0207 12 and 14 there was arequirement for them to obtain C&E250 guarantees, which they needed to provide to the cold store operator.

FSDF's point of view is that guarantees should continue to be the responsibility of the importer and not the warehouse, as if an imported consignment comes into store,companies always insist on a copy of the C88, which clearly denotes if it’s under bond, or duty paid/free stock. If it’s under bond, the goods will not be released from stock hold status until the company gets the C88 denoting that the duty has been paid in full for the relevant consignment. At no point does the company know or need to know the value of the goods in store.

A cold store company therefore has no way, or need to know the total or average value of goods in store over a period in time, which should be the basis of any such guarantee

Also a cold store company cannot have any responsibility for the goods during their journey from the port to the cold store, as the cold store company does not have any involvement in the transit of the goods, which should be covered by the goods in transit insurance of the relevant haulier. However, as the operator of the cold stores, it is understood that cold store companies have a responsibility for the security of the goods whilst in their care and do so at all times

Commodity codes

Cold store companies usually have approval for a number of commodity codes. It is normal that a cold store company has a client contact them to request a new commodity code whilst goods are in transit by ship, due to arrive in the UK a few weeks later.

1.Regulation EU No 952_2013.pdf 

 Κανονισμός τελωνειακού κώδικα

 Κανονισμός 17 Δεκεμβρίου 2015

 Εφημερίδα ΕΕ 27Απριλίου 2016

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