On March 21, the DMS 4.1 & IIAA information session took place at our office in Capelle aan den IJssel. Leo Alewijnse and Paul Albers of Dutch Customs gave an extensive explanation of the new working methods and were able to answer all kinds of questions from the audience. Very educational and definitely worth repeating! Thanks, gentlemen!
After a nice lunch reception and the welcome words by Steven Veelders, CEO Gateway, Customs gave a detailed and informative presentation on DMS 4.1 and EIDR. Customs has also used a number of case studies to explain various scenarios.
For our blog readers, we have collected some important points regarding DMS 4.1.
After presentation declaration, goods must be available for Customs till the release is given.
If it concerns a warehouse where customs cannot easily access the goods, goods may not be placed in the warehouse until Customs has released them, possibly after inspection. This is different than now seeing that the active presentation is not obligatory at the moment. In most cases, release message follows shortly after presentation, but the possibility of a customs inspection must be taken into account. The presentation must therefore be done at the right moment and not afterwards.
The exemption from presentation in DMS 4.1 is only possible with the chain procedure.
There is a possibility in the legislation to grant an exemption from presentation. The Dutch Customs has chosen to grant this exemption only to companies that use the chain procedure with audit file. These companies only have to send the first presentation in the chain.
In case of Direct Representation, registration must be made in the administration of the Represented.
For companies that act as Direct Representative, the registration must be made in the administration of the Represented. This means that in practice it won’t be possible to use the chain procedure with Direct Representation.
The supplementary declaration must be a complete declaration.
Entry in the declarant’s record can be an incomplete declaration. The supplementary declaration must be submitted no later than the 10th day after entry in the record and must be a complete declaration! This means that when the supplementary declaration is made, all preferential documents and other relevant data must be present. Otherwise, the declaration will be processed at the regular rate and a request for a refund will be sent. To prevent this, you can opt to submit an incomplete declaration in the normal procedure.
The only exception for supplementary declaration is in case of bonded warehouse.
For an EIDR entry in the customs warehouse, it’s possible not to send the supplementary declaration. This is the only exception in the EIDR processes.
The chain procedure can only be used if all EIDR entries take place in 1 administration.
For Customs, 1 administration means 1 company with the same EORI number and everything is kept within 1 system. All processes must also be secured via the stock audit file.
The audit file is mandatory when using the chain procedure.
Furthermore, the audit file will no longer have to be actively submitted to Customs for checking. There will then be a periodic check at the company itself (for example annually). All relevant goods flows must be included in the audit file, including free goods and other goods that are not declared via the chain procedure. This is not necessary if it is a clearly separated flow of goods, for example goods from a specific customer that cannot physically come into contact with the goods that have been placed in the chain procedure. This will then be determined during the revision interview with Customs.
A maximum of 99 additional commodity codes can be entered in DMS per item.
The commodity codes often consist in 10 digits. Currently, a commodity code may consist of 22 digits. In addition to the first 10 digits, there are then 2 additional codes (4 digits each) and the national code (4 digits). In DMS, these codes are indicated as separate codes. A maximum of 99 additional goods codes can be specified per item in DMS, compared to 2 in the current system.
There is an important change regarding the special destination (in Dutch “bijzondere bestemming”)
In the old system this was indicated by the use of a preferential code. In the new situation, a measure code (44 – special destination) is used for this. It is important to note that the measure code must appear in the EIDR permit in order to be allowed to use it.
Do you also make use of EIDR? Do you want to know more about the changes from the old systems to DMS? Then don't hesitate to contact us.