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About the journal

Dear Reader,

Customs formalities cover global supply chains from the country of exportation to the country of importation. The legal rules to be addressed on the way are extensive (tariff, non-tariff, safety, etc.). They vary across countries and regions, change constantly, and often are inaccessible because of the language barrier and/ or unavailability online. 

Businesses aim to arrange customs formalities in the most cost-effective way, taking into account tariff preferences, the variety of customs procedures, and the simplifications. Therefore, the task to ensure compliant and cost-effective customs formalities is a complex one and any customs-related topic is in the scope of the journal. 

At the core of the Customs Compliance & Risk Management Journal for Practitioners in Europe are these keywords: up-to-date customs knowledge, compliance, harmonisation and simplification of the international and national rules (the simpler the rules, the easier to trade and to manage compliance and risks).

The first bi-monthly issue was released at the end of March 2020. Stakeholders - business, customs, academia, and others - from all over the world are invited to read the journal and to contribute articles.

The Editorial Board:
Enrika Naujokė, CC Learning, UAB, Lithuania
Dr David Savage, Ireland
Roberto Raya da Silva, Raya Consult, Brazil
Prof Dr Borys Kormych, National University 'Odesa Law Academy', Ukraine
Dr Ilona Mishchenko, National University 'Odesa Law Academy', Ukraine
Samuel Draginich, Amazon EU, Luxembourg
Ira Reese, Global Security and Innovative Solutions, the USA
Mark Rowbotham, Portcullis ISC, the UK
Svitlana Siurik, Belgium

We will be happy to answer your questions. Contact us: info@customslcear.net  

Best regards,
Editorial Board

Terms and conditions

Terms and Conditions

Responsibility for the content. The information contained in the Customs Compliance & Risk Management Journal for Practitioners in Europe is for general information purposes only and cannot be construed as legal advice, conclusion or consultation. The publisher CC Learning, UAB (CustomsClear, the Publisher) does not necessarily agree with the views of the authors of articles.

Distribution. The exclusive right to distribute the journal belongs to the Publisher. The paid articles of the journal are only for the use of those who have acquired them lawfully. The originals or copies of the articles may not be distributed, sold, rented, lent or otherwise transferred without the written consent of CustomsClear.

Procedure upon violation. The Publisher will make every effort to resolve any disputes in a consensual manner and therefore asks to be notified (using the contact details provided) of any conflict or misunderstanding before other steps are taken.

Disclaimer. The Publisher accepts no liability for the quality of the information provided or for it being correct, complete or up-to-date. It is the sole responsibility of the authors themselves to ensure compliance with intellectual property rights. We expect authors to indemnify and hold the CustomsClear harmless from any loss, damage, claim, expense or costs, that may be incurred or sustained in connection with or in any way arising out as a result of intellectual property violation claims.

Contact: info@customsclear.net 

Information for authors

Information for Authors

Writing an article is a great way to share your knowledge and, if relevant, to inform readers about your expertise in a particular field of Customs.

Articles are contributed on a non-remunerated basis. Thanking you for your contribution, we will invite you to meet other authors in bimonthly online meetings.

The ISSN 2669-2171 number can be used for academic purposes.

Reader

The reader of the journal is a practitioner dealing with customs-related questions first of all in business. She or he might be a beginner or experienced one. Therefore, please write for practitioners, delivering your message in a simple and clear way. 

Language 

The main language of the journal is English. However, practitioners in many countries do not speak English, therefore, we encourage to write the article in several languages up to your choice.

Structure and length

Please start with about 3-5 sentences introducing what is your article about. Structure the article in short paragraphs, use subtitles. At the end of the article (and/ or in the author’s profile), you may introduce your organisation and services.

The length of the article is up to your choice, the most important is to clearly deliver the knowledge/ the main message to the reader (there are articles of 1000 and of 3000 words, it can be less or more). 

Author’s profile

Additionally, you may send us a picture and a description of the author for the author's profile. The author's profile opens when you click on the author’s name in the article. 

Note

Please also read 'About the Journal' and 'Terms and Conditions'.

Contacts

We will be happy to answer your questions. Please contact us by info@customsclear.net

Dear Readers,

Without a doubt, the main news of May was the unveiling of a large-scale customs reform in the EU. The European Commission describes it as the most ambitious and comprehensive reform of the EU Customs Union since its establishment in 1968. The far-reaching plans, which are expected to be implemented in 2038, will continue to be discussed by practitioners, academics and interested parties for a long time to come. I am confident that the CCRM journal will contain many articles on this topic, with analysis, forecasts and other insights. I am pleased to draw your attention that one of the “fathers” of the UCC, Michael Lux, has already made a start with his article "The Reform of the UCC". In it, you will find a description of the changes he considers most important and a first assessment.

Another major topic covered in this issue is the Carbon Border Adjustment Mechanism set out in a recently published regulation. In the article “CBAM reports and declarations for imported goods: Who, what, when?” by Enrika Naujokė, you can find answers to these questions and learn what will change from October 2023 and beyond.

The multifaceted subject of customs compliance does not go unnoticed by our authors. Dr Michael Jung looks at the challenges of customs compliance management, as well as a new approach to it through the use of the INCASE model. The article by Prof Dr Andrew Grainger highlights the role of the key players in customs compliance - customs managers. 

Directly related to customs compliance, the topic of customs knowledge management is always relevant and inexhaustible. You can never have too much knowledge, it is never too late to learn - these are simple truths that everyone has known since childhood. In a dynamic environment, with frequent changes in legislation, this topic is particularly acute. Best practices, tips and tricks for managing customs knowledge can be found in the review of the 15th Authors' Meeting. 

Another topic that has remained at the top of our recent issues is export control. The Russian-Ukrainian war has intensified the cross-border movement of military and dual-use goods, bringing with it new challenges and old problems. In this context, I would like to draw your attention to the articles by Armin Belle and Christelle Dubouchet.

More than three years after Brexit, the legal processes associated with it are still ongoing. The Windsor Framework, which was designed to address the problems associated with the application of the Northern Ireland Protocol, is a testament to this. The articles by Michael Lux and Dr David Savage outline the key aspects of the Windsor Framework in relation to trade in goods between Great Britain and Northern Ireland and provide a detailed overview of the background, drivers and key points of the agreement.

The case law section traditionally deals with classification and origin issues. In this section you can find out whether car seat covers and bag nets are parts or accessories, what pitfalls to avoid classifying unassembled goods and the limits of binding origin information in Union customs law.

Another important topic in this issue is information technology in customs. It is covered in articles dealing with issues related to the creation and functioning of an EU digital customs environment and tips for businesses on choosing the right customs software.

Ira Reese's article describes how the United States prevents the entry of goods obtained with the forced labour in China and the challenges importers face. 

A country-specific section is presented with insights from Ukraine and Bulgaria.

I sincerely hope you enjoy this CCRM issue. If you have any questions about our journal, including how to contribute an article, please contact us at info@customsclear.net 

Best regards,
Dr Ilona Mishchenko,
Member of Editorial Board

Enrika Naujoke, Member of the international Editorial Board of CCRM journal, Lithuania:  Dr Ilona Mishchenko is living and working in Odesa, Ukraine. We send her our thanks and support. In the night from 9 to 10.6.2023, three people died in Odesa due to explosions caused by drone attacks. People in Odesa are also witnessing the tragedy after the Kakhovka hydroelectric power plant was blown up on 6.6.2023: objects from the Kherson region (refrigerators, sofas, roofs, etc.) are washed up on the coast of Odesa, a dog was rescued after spending several days at sea.

en
Changes to trade in goods between Northern Ireland and Great Britain as a result of the Windsor Framework
11-06-2023

!!! Updated article with adjustments made to the UCC !!! On 24 March 2023, the EU and the United Kingdom (UK) agreed to settle their dispute over the Northern Ireland Protocol, in particular by responding to some of the UK's requests to facilitate trade between Great Britain – GB (England, Wales, Scotland) on the one hand and Northern Ireland on the other (so-called East-West trade) and by accommodating the UK on some other issues. The relevant legal acts, recommendations and declarations were published in Official Journal No. L 102 of 17 April 2023. CCRM Journal for Practitioners in Europe has therefore asked Michael Lux, who advised the Government of Northern Ireland on the interpretation of the original version of the Northern Ireland Protocol, to outline the main aspects of the Windsor Framework with regard to trade in goods between Great Britain and Northern Ireland.

Michael Lux

law, restrictions, trade barriers
en
Changes to trade in goods between Northern Ireland and Great Britain as a result of the Windsor Framework
11-06-2023

!!! Updated article with adjustments made to the UCC !!! On 24 March 2023, the EU and the United Kingdom (UK) agreed to settle their dispute over the Northern Ireland Protocol, in particular by responding to some of the UK's requests to facilitate trade between Great Britain – GB (England, Wales, Scotland) on the one hand and Northern Ireland on the other (so-called East-West trade) and by accommodating the UK on some other issues. The relevant legal acts, recommendations and declarations were published in Official Journal No. L 102 of 17 April 2023. CCRM Journal for Practitioners in Europe has therefore asked Michael Lux, who advised the Government of Northern Ireland on the interpretation of the original version of the Northern Ireland Protocol, to outline the main aspects of the Windsor Framework with regard to trade in goods between Great Britain and Northern Ireland.

Michael Lux

law, restrictions, trade barriers
en
CBAM reports and declarations for imported goods: Who, what, when?
11-06-2023

To reduce carbon emissions in the EU and globally, the EU has put in place a legal framework - the Carbon Border Adjustment Mechanism (CBAM), set out in a recently published regulation. The CBAM will apply to imports of certain goods such as fertilisers, screws, wires, hydrogen, etc., the range of which will be expanded. The obligation for importers of these goods or their indirect customs representatives to submit quarterly CBAM reports comes into force already this year.

Enrika Naujokė

duties, taxes, import, restrictions, trade barriers, sustainability
en
CBAM reports and declarations for imported goods: Who, what, when?
11-06-2023

To reduce carbon emissions in the EU and globally, the EU has put in place a legal framework - the Carbon Border Adjustment Mechanism (CBAM), set out in a recently published regulation. The CBAM will apply to imports of certain goods such as fertilisers, screws, wires, hydrogen, etc., the range of which will be expanded. The obligation for importers of these goods or their indirect customs representatives to submit quarterly CBAM reports comes into force already this year.

Enrika Naujokė

duties, taxes, import, restrictions, trade barriers, sustainability
en
Current progress towards a fully digital EU customs environment
11-06-2023

From the point of view of many customs operators, especially those who conduct cross-member state customs activities, the developments in IT are rather sobering. Although the legal framework for further standardization and harmonization has been established, isolated solutions and uncoordinated development statuses within the EU are delaying a real breakthrough. In this article, we provide an overview of the project status regarding the report of the European Commission.

Antonia Livajic, Michael Tomuscheit

IT systems, databases
en
Current progress towards a fully digital EU customs environment
11-06-2023

From the point of view of many customs operators, especially those who conduct cross-member state customs activities, the developments in IT are rather sobering. Although the legal framework for further standardization and harmonization has been established, isolated solutions and uncoordinated development statuses within the EU are delaying a real breakthrough. In this article, we provide an overview of the project status regarding the report of the European Commission.

Antonia Livajic, Michael Tomuscheit

IT systems, databases
en
Ukraine customs and trade news April/May 2023
11-06-2023

News at a glance: Ukraine plans to join the CPTPP; start of application of the Pan-Euro-Med transitional rules of origin with the Republic of Moldova; Ukraine stops exporting sugar; extension of trade liberalisation with the EU; and more updates.

Iryna Pavlenko, Oleg Kyryievskyi

law
en
Ukraine customs and trade news April/May 2023
11-06-2023

News at a glance: Ukraine plans to join the CPTPP; start of application of the Pan-Euro-Med transitional rules of origin with the Republic of Moldova; Ukraine stops exporting sugar; extension of trade liberalisation with the EU; and more updates.

Iryna Pavlenko, Oleg Kyryievskyi

law
en
EU law news April/May 2023
04-06-2023

News in week 22: More trade-related cooperation agreed between the EU and the US in the Trade and Technology Council; WTO dispute panel established to review EU duties on Indonesian steel products; regulation on tariff cassification of a cooling mat for dogs and cats; anti-dumping duty on imports of rebars originating in Belarus; and more updates!

law
en
EU law news April/May 2023
04-06-2023

News in week 22: More trade-related cooperation agreed between the EU and the US in the Trade and Technology Council; WTO dispute panel established to review EU duties on Indonesian steel products; regulation on tariff cassification of a cooling mat for dogs and cats; anti-dumping duty on imports of rebars originating in Belarus; and more updates!

law
en
The Reform of the UCC
04-06-2023

The EU Commission has presented a proposal for the reform of the Union Customs Code (as well as amendments of several other legal acts). In view of the largely failed centralisation (and thus standardisation) of customs activities and – apart from ICS2 – IT systems, as well as a lack of harmonisation of customs sanctions, the proposals for an EU Customs Data Hub, an EU Customs Authority, the shift to the (deemed) importer as the person responsible for duties and all compliance aspects, as well as a partial harmonisation of customs sanctions are bold steps with regard to which the business community suffering from unequal treatment within the EU Customs Union and Single Market can only wish the EU Commission success in the Council and the Parliament.

Michael Lux

e-commerce, IT systems, databases, law
en
The Reform of the UCC
04-06-2023

The EU Commission has presented a proposal for the reform of the Union Customs Code (as well as amendments of several other legal acts). In view of the largely failed centralisation (and thus standardisation) of customs activities and – apart from ICS2 – IT systems, as well as a lack of harmonisation of customs sanctions, the proposals for an EU Customs Data Hub, an EU Customs Authority, the shift to the (deemed) importer as the person responsible for duties and all compliance aspects, as well as a partial harmonisation of customs sanctions are bold steps with regard to which the business community suffering from unequal treatment within the EU Customs Union and Single Market can only wish the EU Commission success in the Council and the Parliament.

Michael Lux

e-commerce, IT systems, databases, law
en
‘Fair prices’ vs transaction value in Bulgaria
04-06-2023

The article deals with the changes in the Bulgarian customs legislation on customs value. These changes do not correlate well with the relevant European legislation, and this raises many questions: Is the application of these new provisions legitimate? What was the reason for the Bulgarian legislator to take such steps? What are the possible consequences? Let us try to find some answers.

Georgi Goranov

valuation
en
‘Fair prices’ vs transaction value in Bulgaria
04-06-2023

The article deals with the changes in the Bulgarian customs legislation on customs value. These changes do not correlate well with the relevant European legislation, and this raises many questions: Is the application of these new provisions legitimate? What was the reason for the Bulgarian legislator to take such steps? What are the possible consequences? Let us try to find some answers.

Georgi Goranov

valuation
en
Certain critical export-controlled product groups to be aware of
01-06-2023

The main purpose of the article is to raise awareness of certain product groups that are subject to export control. This concerns in particular drive and automation products as well as emerging technologies in the high-tech industry. For example, inverters can have a special software extension for output frequencies above 600 Hz, which is critical because this type of product can be used in chemical centrifuges and nuclear power plants in sanctioned countries.

Armin Belle

export, export control, sanctions
en
Certain critical export-controlled product groups to be aware of
01-06-2023

The main purpose of the article is to raise awareness of certain product groups that are subject to export control. This concerns in particular drive and automation products as well as emerging technologies in the high-tech industry. For example, inverters can have a special software extension for output frequencies above 600 Hz, which is critical because this type of product can be used in chemical centrifuges and nuclear power plants in sanctioned countries.

Armin Belle

export, export control, sanctions
en
First steps in choosing customs software
14-05-2023

This article covers the questions that companies should raise when looking for customs software. It highlights the key points to consider before choosing software and gives advice on how to minimise potential issues and maximise benefits. This is important for businesses considering making their own customs declarations for the first time, or switching from one customs software package to another. Here's what you need to know.

Kieran Gleeson

IT systems, databases
en
First steps in choosing customs software
14-05-2023

This article covers the questions that companies should raise when looking for customs software. It highlights the key points to consider before choosing software and gives advice on how to minimise potential issues and maximise benefits. This is important for businesses considering making their own customs declarations for the first time, or switching from one customs software package to another. Here's what you need to know.

Kieran Gleeson

IT systems, databases
en
Export control: the need for an internal compliance programme
14-05-2023

What is an Internal Compliance Programme (ICP) and what are its core elements? What if the ICP is not required by law, should companies still use it? The answer is definitely yes. Even if your company does not fall under the criteria for a mandatory ICP, it is important to have one in place if you deal with export-controlled items.

Christelle Dubouchet

export, export control, sanctions, restrictions, trade barriers
en
Export control: the need for an internal compliance programme
14-05-2023

What is an Internal Compliance Programme (ICP) and what are its core elements? What if the ICP is not required by law, should companies still use it? The answer is definitely yes. Even if your company does not fall under the criteria for a mandatory ICP, it is important to have one in place if you deal with export-controlled items.

Christelle Dubouchet

export, export control, sanctions, restrictions, trade barriers
en
Customs compliance with the “INCASE-Model” – a holistic approach for real effectiveness
07-05-2023

Through several years as a customs auditor, I saw many companies with numerous approaches and attempts to get a grip on the management of the customs requirements. Despite big efforts (financially, personally, technically), organizations often do not succeed in establishing the desired effect and corresponding success in the area of customs compliance. Instead of this, customs compliance or customs management frequently is not sufficiently managed (especially strategically, but also operationally as a result of this weakness). This even leads to blind spots in the organisation, particularly in the structural field, which has in the meantime become increasingly apparent due to the changed audit approach by the authorities.

Dr. Michael Jung

risk management
en
Customs compliance with the “INCASE-Model” – a holistic approach for real effectiveness
07-05-2023

Through several years as a customs auditor, I saw many companies with numerous approaches and attempts to get a grip on the management of the customs requirements. Despite big efforts (financially, personally, technically), organizations often do not succeed in establishing the desired effect and corresponding success in the area of customs compliance. Instead of this, customs compliance or customs management frequently is not sufficiently managed (especially strategically, but also operationally as a result of this weakness). This even leads to blind spots in the organisation, particularly in the structural field, which has in the meantime become increasingly apparent due to the changed audit approach by the authorities.

Dr. Michael Jung

risk management
en
Best practices and tips for managing customs knowledge in a company
07-05-2023

What aspects should be taken into account in the context of customs knowledge management within a company? During the 15th Authors' Meeting, experts from the UK, Israel, France, Colombia, Brazil and Lithuania shared many tips and practices on how to acquire, update and manage knowledge to be successful in customs processes. The main insights – on the role of a customs manager, exchanging information internally, ensuring awareness of all the involved persons, manuals, peer learning, etc. - shared are summarised in the following overview.

knowledge management, risk management
en
Best practices and tips for managing customs knowledge in a company
07-05-2023

What aspects should be taken into account in the context of customs knowledge management within a company? During the 15th Authors' Meeting, experts from the UK, Israel, France, Colombia, Brazil and Lithuania shared many tips and practices on how to acquire, update and manage knowledge to be successful in customs processes. The main insights – on the role of a customs manager, exchanging information internally, ensuring awareness of all the involved persons, manuals, peer learning, etc. - shared are summarised in the following overview.

knowledge management, risk management
en
Harley-Davidson case highlights limits of binding origin information in Union customs law
07-05-2023

In the European Union customs law, it is possible for an economic operator to obtain binding tariff or origin information decisions, which provide assurance about the tariff classification or origin of goods. However, does such a customs decision always guarantee legal security just because national customs has issued a favorable decision to the trader?

Jonas Sakalauskas

duties, taxes, origin
en
Harley-Davidson case highlights limits of binding origin information in Union customs law
07-05-2023

In the European Union customs law, it is possible for an economic operator to obtain binding tariff or origin information decisions, which provide assurance about the tariff classification or origin of goods. However, does such a customs decision always guarantee legal security just because national customs has issued a favorable decision to the trader?

Jonas Sakalauskas

duties, taxes, origin
en
Paper or pixels? The dual challenge of document management in Ukraine’s e-customs clearance
07-05-2023

In the era of digital technologies, electronic customs clearance of goods has become a standard for many countries across the globe. Ukraine is no exception. However, unfortunately, even in the modern system, problems can arise that can significantly complicate and slow down customs clearance. One such problem is the provision of paper documents. In this context, it is crucial to clarify some issues that regulate the procedure for providing paper documents and the form of customs control during electronic customs clearance of goods in Ukraine. In this article, we present a real case that happened to us at the end of March 2023 in Odesa.

Dr Oleksii Fedotov, Artem Nazarko

customs clearance, IT systems, databases
en
Paper or pixels? The dual challenge of document management in Ukraine’s e-customs clearance
07-05-2023

In the era of digital technologies, electronic customs clearance of goods has become a standard for many countries across the globe. Ukraine is no exception. However, unfortunately, even in the modern system, problems can arise that can significantly complicate and slow down customs clearance. One such problem is the provision of paper documents. In this context, it is crucial to clarify some issues that regulate the procedure for providing paper documents and the form of customs control during electronic customs clearance of goods in Ukraine. In this article, we present a real case that happened to us at the end of March 2023 in Odesa.

Dr Oleksii Fedotov, Artem Nazarko

customs clearance, IT systems, databases
en
Brexit Diary – the Journey to Windsor
30-04-2023

The Windsor Framework possibly places Northern Ireland in a very enviable position. Importers and exporters from Northern Ireland uniquely have free access to both the UK and EU markets – which should surely attract considerable foreign investment and transform it into a prosperous trading hub. How did the journey to Windsor go?

Dr David Savage

law, restrictions, trade barriers
en
Brexit Diary – the Journey to Windsor
30-04-2023

The Windsor Framework possibly places Northern Ireland in a very enviable position. Importers and exporters from Northern Ireland uniquely have free access to both the UK and EU markets – which should surely attract considerable foreign investment and transform it into a prosperous trading hub. How did the journey to Windsor go?

Dr David Savage

law, restrictions, trade barriers
en
Customs managers: What do they do?
30-04-2023

How are customs issues managed within companies? What is it that people in charge of meeting Customs’ expectations do? This article highlights the role of the key players in customs compliance - customs managers. The findings presented are based on interviews with key informants in nine multinational companies from a cross-section of industries.

Prof. Dr. Andrew Grainger

knowledge management, risk management
en
Customs managers: What do they do?
30-04-2023

How are customs issues managed within companies? What is it that people in charge of meeting Customs’ expectations do? This article highlights the role of the key players in customs compliance - customs managers. The findings presented are based on interviews with key informants in nine multinational companies from a cross-section of industries.

Prof. Dr. Andrew Grainger

knowledge management, risk management
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