EU+UK: Entry into the Declarant’s Records (EIDR): What is it and how does it work?
One of the simplifications offered to importers is called “Entry in the declarant’s records” or EIDR. We take a closer look at how it can help importers.
What is EIDR?
EIDR is a simplified procedure that allows authorised imports to enter certain goods into the declarant’s records. Once authorised, importers can move goods into free circulation by entering their details in the importers’ own records. Then, businesses need to submit a supplementary declaration.
For what customs procedures can I use EIDR?
Release for free circulation
Customs warehousing
Temporary admission
End / Authorised use
Inward processing
What happens when you enter goods into records?
Upon entry into records’, customs authorities may not require the goods to be presented to customs. Instead, the goods are deemed to have been released at the moment of entry in the declarant’s records. Depending on the scheme and the authorisation, the trader needs to make issue a notification every time goods are entered into record (EU only).
Notification Waiver (EU Only)
This means that no notification must be sent to customs when importing goods. It provides for automatic release of the goods. The goods are deemed to be released at the moment of entry in the declarant’s records. The date of release of the goods must be clearly stated in the records. The conditions under which the release of the goods is allowed will be set out in the authorisation. There is no need for a notification where the business uses EIDR in the UK
How and what to enter into the declarant’s records
Businesses must hold and maintain a set of commercial records and enter an account of all consignments released for authorised procedure into these records. A clear method of reference or internal filing system is required, e.g. invoice number, delivery note etc.
The data entered the records must be at least those of a simplified declaration minimal data set by the Data elements of the Union Customs Code (listed in column I1 of the ‘Data Requirements Table’ and any supporting documents, in accordance with Article 234(1)(b) of the IA and Annex Bof the DA). As the UK essentially applies a similar system, it is recommended for UK businesses to follow a similar approach. The structure and form of the data of the records are free.
The data may be stored in different locations and/ or in different IT systems belonging to the importer but must be accessible to customs and show a clear audit trail of each operation information entered into records must be made available to the customs authorities, upon request.
The supplementary declaration
A supplementary declaration containing the required data elements of the customs declaration must usually be lodged after the goods have been released. It is a mandatory requirement for EIDR procedure that a supplementary declaration is submitted by the importer. The entry in the declarant’s records is equivalent to a simplified or a standard declaration. The date of the EIDR is the date of the acceptance of the customs declaration. This establishes the date of the customs debt. It is essential that there is complete traceability from the records to all supporting documents.
The supplementary declaration will need to include:
a (customs) procedure code
a commodity code
the declaration unique consignment reference (DUCR in UK) which is the main reference number that links declarations.
Businesses also need to provide information like the:
consignee and consignor
transport methods and costs
currencies and valuation methods
certificates and licences.
After you submit
When the supplementary declaration is accepted, customs will send a customs response message giving a calculation of what monies owe. Payment usually will be taken from your deferment account on the 15th day of the following month.
Final Supplementary Declaration
There is also a need to submit a final supplementary declaration by the fourth working day of the month following the reporting period when the supplementary declarations were due.
For example, if a business submits a supplementary declaration in the January reporting period, businesses must submit the Final Supplementary Declarations by the fourth working day of February.
Authorisation
To be authorised, an importer needs, usually, to
be established in the customs territory
have an appropriate record of compliance with customs requirements (usually including VAT returns and duty deferment account payments)
have no record of serious criminal offences related to their business activities
keep records of all declarations made for 4 years after the submission date and make this available to customs on request
provide and maintain written procedures (have a satisfactory system of managing commercial and, where appropriate, transport records)
demonstrate, where appropriate, proven financial solvency
demonstrate practical standards of competence or professional qualifications
meet appropriate security and safety standards where required
list of (customs) procedure codes and commodity codes
be an Authorised Economic Operator (EU only – where a waiver to submit a notification is requested).
About the compliance records
The compliance record will be based on the last 3 years before a business applies. During that period, the importer should not have committed a serious infringement or repeated infringements of customs rules. Where a business has not been established for less than 3 years, then their compliance will be judged on the records and information available, including your involvement in previous businesses.
About Written procedures
Businesses must usually provide a document which details your customs procedures along with the application, and this must include information on:
the company’s experience and qualifications in customs matters
who will be responsible for making customs and supplementary declarations?
management checks, showing how the business will identify and report any errors found after having submitted a final supplementary declaration
document retention and security
Where a business holds Authorised Economic Operator authorisation for customs simplifications, they do not need to give this information.
Commodity codes
Businesses may be asked to provide a description of the goods, either the relevant 8 digit Customs Nomenclature (CN) codes of the goods or the 4 digit chapters of the CN. The description of the goods must be the normal trade description and detailed enough for immediate, precise identification and classification. For example, Import 090112 00 or Import 0901 Coffee – not roasted – decaffeinated. The lists could, for example, be provided as spreadsheets.
Application
To apply for authorisation to use EIDR, importers in the EU can usually apply electronically using the Customs Decision System (CDS). The CDS allows traders to use an European Union (EU) trader portal to apply for and manage customs decisions electronically. The CDS is used to exchange and store information in relation to 22 specific customs decisions. The CDS is a centrally developed EU system. It has been implemented simultaneously with the Uniform User Management and Digital Signature system (UUMDS). The UUMDS allows economic operators and their representatives access to the EU Trader Portal.
In the UK, you need to complete form C&E48.
After you’ve applied, the authorities may write to you about your application or post a letter in the application portal. If they authorise a business, they will get a letter that:
confirms the authorisation numbers
sets out the authorisation conditions
What will be checked in the assessment by the authorities
Authorities will have to verify compliance with requirements. They may check
The time limit to make available to customs the necessary supporting documents.
The time limit to lodge the supplementary declarations
Approval of places for the presentation of goods to customs and/ or designated places
The representative or declarant.
Where goods are not presented to customs, it must be proven that the data entered in the records are accurate and then compiled for making the supplementary declaration.
Reconciliation between the presentation notification and the supplementary declaration when requested (EU only)
Tax and Duty Manual for EIDR
The link between records and the accounting system.
The place where records are kept.
The guarantee in place for the customs procedure required (where requested, EU only)
The type of goods, quantity and value.
Other issues such as VAT identifications, authorised consignee and other transit matters, deferred payment information
EIDR for movement of goods out of warehouse
This is a facility that allows businesses to apply for an authorisation under EIDR whereby it allows for the movement of goods out of warehouse procedure and entry the details in their own records during the month.
A supplementary declaration in the form of a full customs declaration must be submitted to the customs authorities by the deadline specified in each Authorisation. In order to obtain approval for this type of authorisation, the same processes and procedures apply as for that of EIDR at import.
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