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(S,P) Food and drink producers and retailers need to prepare for submitting Export Health Certificate for EU-UK POAO trade from July 2022. On 14 September 2021, the UK has set out a new timetable for introducing full import controls for goods being imported from the EU to the UK. Our part blog series explores everything an EU exporter or GB importer needs to know: Part 1: New timetable and overview in a nutshell Part 2: Frequently Asked Questions about the SPS import controls from 2022 Part 3: Details about the SPS changes Questions and Answers When will I need an Export Health Certificate? Animal products being imported from the European Union into Great Britain will not require a certified Export Health Certificate to accompany the consignment until 1 July 2022. Further information about the requirements from July 2022 can be obtained by joining our SPS training and asking our customs and global trade experts via the chat function. Where can I view the Export Health Certificates? EHCs are issued by the competent authority in the exporting country, based on the requirements outlined in the model Export Health Certificates. The EHC is issued to the exporter based in the European Union (EU), who then provides the importer with an electronic copy to upload onto the notification in IPAFFS before the consignment arrives into Great Britain. From 1 July 2022, will my animal products need to enter via a point of entry with a Border Control Post? Yes, from July 2022 your animal products consignment will need to enter Great Britain via the Border Control Post that is designated to receive your type of goods. Does the delay apply to animal by-products (ABP) as well as animal products for human consumption? Yes, products of animal origin (POAO) for human consumption and ABP not for human consumption are included in these new arrangements. Both POAO and ABP consignments will require pre-notification from January 2022 and an EHC from 1 July 2022. From July 2022, consignments will be subject to documentary, ID and Physical Checks. Further information can be produced at our SPS training or by asking about requirements from January and July 2022ing our customs and global trade experts via the chat function. How does the delay impact Prohibited and Restricted (P&R) goods? Businesses can continue to import P&R goods from the EU into Great Britain until 31 December 2021. Further information can be found on gov.uk How and where will I need to pre-notify my goods from 1 January 2022? IPAFFS is the import of products, animals, food and feed system (IPAFFS) and is the system used to notify the arrival of imports of live animals, animal products and high-risk food and feed not of animal origin. It is the responsibility of the GB importer (or a representative acting on their behalf) to register for IPAFFS to pre-notify the relevant authority of the goods’ arrival. If an EHC is required for the commodity, the EU exporter should provide the GB importer with an electronic copy of the EHC and the GB importer must upload this on to the notification in IPAFFS. We file IPAFFS for You and analyze your EHC needs Leave a message in the chat and we will get back to you FOCUS on IPAFFS You can watch the video on how to register for IPAFFS and how to pre-notify, here: Too complicated? Solution: Customs Manager's IPAFFS and EHC Service for food businesses Other official videos: How to register for the Imports of Products, Animals, Food and Feed System IPAFFS How to submit a pre-notification on IPAFFS for Products of Animal Origin (Official Defra Video) How do these delays impact my goods that are transiting through Great Britain? Consignments of EU origin and/or third country that have been cleared for free circulation in the EU can continue to transit through Great Britain as they do today. From 1 January 2022, animal products transiting through Great Britain will need to be pre-notified via IPAFFS before they enter Great Britain. When these goods leave Great Britain, you will also need to notify authorities that the goods are leaving the country. Additionally, from 1 July 2022, EU origin consignments transiting through Great Britain will require a certified EHC and must enter and exit through a point of entry with an appropriately designated Border Control Post. Further information can be produced at our SPS training or by asking our customs and global trade experts via the chat function. My composite product is exempt from certification, will I need to pre-notify its arrival into Great Britain? No, if your product meets the requirements for exemption from Sanitary and Phytosanitary (SPS) controls you do not need to pre-notify authorities of its arrival. Further information can be produced at our SPS training or by asking our customs and global trade experts via the chat function. Watch the official video from September 2021 Created before the change of timetable was announced. Does the delay remove any controls from products under safeguard measures? No, products being imported under safeguard measures must continue to follow existing requirements and controls. Import requirements are already in place for a few POAO subject to safeguard measures. Emergency safeguard action can be taken at very short notice to prohibit or restrict the importation of certain products from certain countries following an outbreak of disease or a public health issue (such as avian or swine flu). Information on the latest updates concerning disease outbreaks that may affect imports into the UK can be requested by your customs manager using the chat function. POAO subject to safeguard measures are required to be pre-notified in advance of arrival using IPAFFS and all goods must be accompanied by an Export Health Certificate. The GB importer will also need to supply the EU exporter/ Certifying Officer (usually an Official Veterinarian) with the unique notification number (UNN) that is produced when the importer notifies the UK’s Animal and Plant Health Agency (APHA) about the import. The exporter must add the UNN to the Export Health Certificate. If the safeguard measure is in place due to a new or emerging disease outbreak, and the commodity code is not available in IPAFFS, there may be other steps traders need to take to pre-notify. Further information can be produced at our SPS training or by asking our customs and global trade experts via the chat function Does this impact on the introduction of the new EHCs for goods exported to the EU or moved to NI from Great Britain as part of the Animal Health Regulation? No, Animal Health Regulations EHCs apply to goods being exported from GB to the EU or goods moving from GB to NI only. The changes in this communication relate to goods being imported from the EU into Great Britain only. What shall businesses do? At this stage, it is reasonable for businesses to start thinking about the appropriate and relevant actions they will need to take to be ready for 1 January 2022. Please contact us via the chat function to discuss your requirements or book a free consultation. This is a great time to upskill yourself on how SPS works by booking one of our pieces of training. In addition to the LIVE! training, we offer an on-demand training courses on SPS: LIVE TRAINING On-Demand Training Study anywhere, anytime, on any device: Importing Food Products from EU into Great Britain On-Going Support for subscribers DOWNLOAD PRESENTATION BY DEFRA OCTOBER 2021 PRESS RELEASE About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages..

(S,P) ATA Carnets are complex. Part 2 of our mini-series explores the essentials businesses need to understand for efficient use. In this two-part series, we take a closer look at ATA Carnets, what they do and what they do not do and overall how the system works. In Part 1 we looked at the fundamentals of the ATA Carnet and talk through a practical example. We also find out in which countries ATA Carnets are used. In this part, Part 2, we look at the specifics. How does an ATA Carnet look? What are its features? What are the common mistakes? What happens if goods remain in a country? And what is a Carnet de Passages en Douane? Guarantees The Carnet system provides for guarantees to be given by a national guaranteeing association (NGAs), to cover the import duty to which the importations will be subject in the event of a breach of the conditions of the temporary importation. NGAs are appointed by customs authorities and have joined an international guaranteeing chain (a risk management scheme administered by an international organisation). If we go back to our example of the UK business from Part 1, they will be required to hold a guarantee, or other security, in case the goods are incorrectly used or not re-exported from the country visited. This would also need to be set up by your UK business. If customs in the country visited are not satisfied that the goods have been re-exported or an ineligible use has been made, they will make a claim to the carnet association in their country for payment of the customs charges due. Not returning the goods to the UK Sticking with our practical example of a UK business, you’ll need to contact the customs authority in the country where the goods will remain to complete any customs documents they require and for them to note on the carnet which items are not being returned. As the goods are no longer a temporary export from the UK, you will also need to complete an export declaration in the UK to replace the temporary export made under the carnet. How to re-import the goods to the UK Present the carnet and goods to customs at the port or airport of arrival or designated point in the UK. Customs at the office of import will check and endorse the yellow re-importation voucher and stamp the matching counterfoil. The yellow voucher will be removed and the carnet returned to you. If goods are included in a passenger’s baggage and re-imported to the UK direct from a non-EU country, the carnet must be presented at the red point or channel. Failing to present the ATA carnet when leaving the country visited If the carnet is not presented, the carnet will not be discharged correctly. Customs in the country of temporary import may then demand payment of duty or ask for proof of the current location of the goods. If you’re asked for proof of re-export you maycontact customs in the country where the goods are located. As long as the carnet was correctly presented on re-importation to the UK, they can issue a certified copy of the relevant re-importation voucher. If the appropriate voucher is not available or was not presented at re-importation, they may be able to arrange for you to present the goods for inspection so that we can confirm that the goods are in the UK. There may be a charge for each inspection. Watch Out Most problems are caused by: giving an unclear or inaccurate description of the goods - for example, the description on the carnet should be comprehensive enough for customs authorities to identify the goods if the details on the ATA carnet are not clear, the importing customs authority may refuse to accept it - the release of the goods could then be delayed until a normal customs declaration is made; make sure that the description of each item is as full as practicable, photographs of the item can be very useful to aid identification failing to present the ATA carnet to customs for endorsement at re-export - for example, if a carnet is not presented customs will not know the goods have been re-exported using general lists - for example, if details are altered or changed after it has been issued customs authorities can refuse to accept the carnet If there are any problems with the carnet it could result in a claim for payment of customs duty and taxes and/or a penalty being imposed. Any irregularity could also delay the discharge of the carnet. How does an ATA Carnet look? It comprises of a front and back cover, vouchers and counterfoils. The front and back cover contains detailed information on the Carnet holder, the representative(s), the intended use, the issuer, the guarantor, the Carnet number, the validity, and the general list of goods. Vouchers, differentiated by colours and titles, are used by holders as declaration and guarantee. Continuation sheets may be inserted if not enough space is provided on the cover or on the vouchers to show the details of all the goods covered. The carnet can include any number of vouchers to allow the goods to be moved between many countries before their return or for multiple trips to be made using the same carnet. To simplify the use of the carnet, the cover and vouchers are printed on coloured paper: green - the cover sheet, this identifies the holder and their address, the holders representative (if applicable), the intended use of the goods, which countries the carnet can be used in and how long it is valid for; this front cover must be endorsed by the issuing association and signed by the carnet holder - it will normally be certified by customs in the country of issue yellow - the exportation and re-importation vouchers, corresponding counterfoils are printed on a separate yellow sheet white - the importation and re-exportation vouchers, corresponding counterfoils are printed on a separate white sheet Carnets may also contain blue vouchers The back of the green front cover and each voucher contains the ‘general list’ of the goods covered by the carnet. Each voucher also contains a declaration which must be completed and signed by the holder or their representative each time the carnet is presented at export and import and re-export and re-import, including transport if applicable. The vouchers will be stamped and removed as appropriate by the relevant customs authorities, they will then stamp the corresponding counterfoil on the carnet and return the carnet to the person who presented it. One voucher must be provided to the foreign customs officials when entering the country and another when leaving. This rule also applies when exiting and entering your own country. After declarations, vouchers are kept by customs authorities to monitor and regulate temporary import and export. Counterfoils, differentiated by colours and titles, are prepared for customs officials to commit transactions performed at border offices. Counterfoils can be used as key evidence to discharge claims should customs claim exempted duties and taxes at a later stage. Carnet de Passages en Douane A CPD Carnet, (Carnet de Passages en Douane) lets a business temporarily take a UK registered vehicle into the EU. This means a business does not pay the import duties in the EU when you drive through or temporarily stay in its territory. The carnet allows travellers to temporarily import their vehicles, or other items of value such as broadcasting equipment, without having to leave a cash deposit at the border. It is, in essence, an international guarantee for payment of customs duties and taxes to a government should the vehicle or item not be re-exported from that country. Persons who temporarily import their vehicles or items into countries where the Carnet is required must agree to obey the laws and regulations of that country and particularly the conditions of temporary importation. The Carnet contains relevant information about the items or vehicle – make, model, colour, engine capacity, seating capacity, registration number, owner and value. To obtain a carnet, the owner of the items is required to provide security based on the countries travelled to, age and market value of the items. Generally, four types of security are acceptable from motoring organisations: • Cash bond • Banker's letter of indemnity • Insurance policy • Loss Prevention Security – US and Canada only How Customs Manager Ltd can help We advise on ATA carnets and help you get one quickly. We discuss your ATA carnet and supply chain needs and decide jointly on the most compliant, efficient and effective way to use it. This will ensure you enter and exit countries with your goods without delay. Missed Part 1? We looked at the fundamentals of the ATA Carnet and talk through a practical example. We also find out in which countries ATA Carnets are used. About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

(S,P) Many businesses struggle to get goods into the EU. Some say ATA carnets are a way to fast-track entry to Europe. Not so fast!, argues Arne Mielken of Customs Manager Ltd. In this two-part series, we take a closer look at ATA Carnets, what they do and what they do not do and overall how the system works. We imagine the case of a UK business sending an engineer to the EU. How would the company go about using an ATA Carnet? In Part 1 we look at the fundamentals of the ATA Carnet and talk through a practical example. We also find out in which countries ATA Carnets are used. In Part 2, we look at the specifics. How does an ATA Carnet look? What are its features? And what is a Carnet de Passages en Douane? The ATA Carnet procedure The ATA Carnet often referred to as the "Passport for goods", is an international customs document that permits the tax-free and duty-free temporary export and import of certain goods for up to one year. The acronym ATA is a combination of French and English terms "Admission Temporaire/Temporary Admission”. Your business can an ATA Carnet in more than 80 countries. You can use it to: temporarily export goods for use outside your own country; and, claim relief under temporary admission on goods that you import for temporary use into another (the third country to yours). Benefits The ATA Carnet allows the business traveller to use a single document for clearing certain categories of goods through customs in several countries without the deposit of import duties and taxes. So long as the goods are re-exported within the allotted time frame, no duties or taxes are due. The main benefits can be summarised in: it simplifies customs clearance of goods in exporting and importing countries by replacing customs documents that would normally be required, it provides financial security for customs charges potentially due on the goods that will be used in the countries visited, it helps to overcome language barriers and having to complete unfamiliar customs forms. Using the ATA Carnet will mean that your business will not pay customs charges. It also simplifies clearing your goods through customs and replaces the customs documents that your business would normally need to complete. However, it does require the provision of financial security for customs charges. Goods covered TA Carnets cover the usual and unusual: computers, repair tools, photographic and film equipment, musical instruments, industrial machinery, vehicles, jewellery, clothing, medical appliances, aircraft, racehorses, artwork, prehistoric relics, ballet costumes and rock group sound systems. ATA Carnets do not cover perishable or consumable items or goods for processing or repair. The most common uses include but not limited to: • exhibitions and fairs • professional equipment • commercial samples and goods for testing purposes • sports equipment. Goods should be intended for return to the country they were initially exported from. They cannot be processed or repaired other than the routine maintenance necessary to keep them in their original condition. Example: Presenting ATA Carnets in the EU For customs purposes, the EU is treated as a single territory so a carnet does not need to be presented in each EU country visited, only at the place of first entry and exit from the EU. What would a typical engineer do who wants to use an ATA Carnet? The engineer of your UK business can use the ATA Carnet upon entry into the EU, regardless if with van or plane. The ATA Carnet would cover only the equipment used for set-up, service, maintenance and repair, not devices that you may take out of the EU for repair. An ATA Carnet presented to customs in the EU is considered as an application for authorization for temporary admission provided the EU’s conditions are met: The Carnet must have issued in a contracting party to the ATA Convention or Istanbul Convention and endorsed and guaranteed by an association forming part of a guaranteeing chain as defined in Article 1(d) of Annex A to the Istanbul Convention. It must relate to goods and uses covered by the Convention under which it was issued. It must be certified by the customs authorities. So, your UK business should make sure that an HMRC customs officer can stamp the Carnet at the port or airport your goods are being shipped from. It must be valid throughout the customs territory of the Union. Responsibilities of your UK businesses’ engineer as ATA Carnet holder When the engineer travels with an ATA Carnet they may become the Carnet holder and their name will be on the front cover of the Carnet. The holder of the ATA Carnet is automatically responsible for any customs charges that may become due if they either do not: use the goods correctly re-export them from the country you visit Carnet holder to the EU must also make sure they show the Carnet to customs for stamping each time the goods enter or leave the EU / UK meaning that the Carnet must be presented to customs each time the goods are imported, exported or pass through a country. they tell customs authorities if the goods are no longer eligible for use under the Carnet, for example, they decided to leave them in the EU / UK or sold the goods; and, that they can show the Carnet and the goods when customs ask them to. Consequently, an engineer arriving in the EU or UK should go through the red channel at customs if they were bringing the goods back in the baggage that were in temporary admission. Carnet Countries & Territories - Where Can An ATA Carnet Be Used? In 100+ countries and territories located in Europe, North America, South America, Asia, Africa and Oceania. More to come or may have joined since this article was written. Check for updates. *Countries ending with an asterisk are part of the European Union (EU). If goods are properly imported into one EU carnet country and re-exported from a second EU carnet country, the Carnet holder is unlikely to encounter any claims fees. Albania Algeria Andorra Antarctica Aruba Australia Austria* Azores (Portugal) Bahrain, Kingdom of Balearic Islands (see Spain) Belarus Belgium* Bosnia & Herzegovina Botswana Brazil Bulgaria* Canada Canary Islands Ceuta Chile China Corsica (France) Cote d'Ivoire Croatia* Curacao Cyprus* Czech Republic* Denmark* Estonia* European Union Faroe Islands (Denmark) Finland* France* French Guiana French Polynesia - Tahiti Germany* Gibraltar Greece* Greenland (Denmark) Guadeloupe (France) Guam Guernsey (United Kingdom) Hong Kong Hungary* Iceland India Indonesia Iran Ireland* Isle of Man (United Kingdom) Israel Italy* Ivory Coast see Cote d'Ivoire Japan Jersey (United Kingdom) Kazakhstan Latvia* Lebanon Lesotho (SACU) Liechtenstein (Admin by Switz.) Lithuania* Luxembourg* Macao, China Macedonia Madagascar Madeira (Portugal) Malaysia Malta* Martinique Mauritius Mayotte (France) Melilla (Spain) Mexico Miquelon (France) Moldova Monaco (Admin by France) Mongolia Montenegro Morocco Namibia (SACU) Netherlands* New Caledonia (France) New Zealand Norway Pakistan Poland* Portugal* Puerto Rico (USA) Qatar Reunion Island (France) Romania* Russia Senegal Serbia Singapore Slovakia* Slovenia* South Africa South Korea Spain* Sri Lanka St. Barthelemy (France) St. Martin/Sint Maarten St. Pierre (France) Swaziland (SACU) Sweden* Switzerland Tahiti (France) Taiwan Tasmania (Australia) Thailand Tunisia Turkey Ukraine United Arab Emirates United Kingdom United States Wallis & Futuna (France) Example of a US Carnet Procedure Instruction Manual How Customs Manager Ltd can help We advise on ATA carnets and help you get one quickly. We discuss your ATA carnet and supply chain needs and decide jointly on the most compliant, efficient and effective way to use it. This will ensure you enter and exit countries with your goods without delay. What to expect in Part 2 In Part 2, we look at the specifics. How does an ATA Carnet look? What are its features? And what is a Carnet de Passages en Douane? About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

Customs Manager Ltd is delighted to present, in conjunction with WorldECR , a six-webinar series giving you the lowdown on the new EU export control regulation. (P) This series has 6 sessions: • Session 1: Overview of the key changes in a nutshell • Session 2: The new cyber surveillance controls – what, why, how? • Session 3: Could I be caught by catch-all? • Session 4: Two new General Licences: Are they right for my company, and how do I use them? • Session 5: The EU Export control regime – for non-EU companies • Session 6: Putting it all together: What does the regulation mean for my ICP? Let's explore Session 1. Session 1: Overview of the key changes in a nutshell In Session One, we move quickly through the key changes to the regulation, providing you with a checklist of areas to further explore – including, the new broader definitions of ‘exporter’, and broker, a new provision for member state information sharing, emphasis on cyber-surveillance and human rights concerns and broader catch-all provision. It also asks – and answers – whether, in practice, EU member states can now create their own control lists. Script Tom Blass, WorldECR: Tell me in a nutshell what the new regulation does. Arne Mielken, Customs Manager Ltd: The new Export Control Regulation entered into force on 9 September 2021. Overall Objectives: 1. tighten controls on trade in dual-use items – civilian goods and technologies with possible military or security use. 2. enhance the EU's capacity to protect human rights and support secure supply chains for strategic items. Why is this needed? to better respond to emerging threats in an increasingly volatile world. Prime examples are the kind of “cyber-surveillance technologies” that can be misused for human rights violations. What are the changes in a nutshell? Well, before I say what does change, let me tell you what does NOT change: The existing multilateral framework of export controls, namely the Wassenaar Arrangement, which forms the basis for many restrictions imposed by the regulation at the EU level remains. In other words, Annex A which holds the EU Dual-Use list does not change with this recast The EU GEAs 1 to 6 does not change. They remain valid at the EU level and can be leveraged. To those rules, however, and all others, there are some important modifications and enhancements. Let me highlight a few now and some others a little later: New and updated definitions – lots of legal updates, some improvements/effectiveness (e.g., the definition of exporter including carrying in personal luggage), reference to researchers and emphasis on natural persons. Introduction of some concepts, essential to an effective Export Control System (e.g., enforcement, compliance, essentially identical transaction). Innovative definitions e.g., Cyber-Surveillance Items and reference to risks associated with emerging technologies, not existing in the current Regulation. Harmonisation of licensing procedures (e.g., the requirement for Internal Compliance Programmes, reporting, etc.). This one is very important for businesses. There are two new General Export Authorisations on Intra-group export of software and technology (EU007) and Encryption (EU008 ). Harmonisation of provisions and tightening of controls for services: Eu harmonisation of technical assistance, broker or supplier of Technical Assistance can be a non-EU resident or national; There is partial “deemed export control” for Technical Assistance ; provision on dual-use Technical Assistance to foreign nationals in the EU is now covered. Regulation (EU) 2021/821 introduces a basis for EU autonomous controls allowing the EU to make its own decisions regarding cyber-surveillance items (goods and technologies) used or intended for use, in internal repression and/or the commission of serious violations of human rights and international humanitarian law. We will talk about this in detail on Thursday. Tom Blass, WorldECR: What is the first thing that I need to do, as a result of the new regime? Arne Mielken, Customs Manager Ltd: Take this as an opportunity to review your supply chain for dual-use items and assess how the new rules affect you. I would recommend a step-by-step approach, combing through the legislation, article by article (as far as it concerns businesses) asking yourself the key questions of the regulation about your supply chain. Some obvious questions can easily determine if a new provision is in scope or out of scope for you: If you are not involved at all in cyber-surveillance exports, there may be no need to consider this provision for your business. But what about dealing with countries where human rights abuses are suspected? Rather than being a matter that you could manage at export with an export authorisation, it appears more of a due diligence matter, so how strong are your due diligence checks? Do they need to be strengthened? If you are not dealing with encryption or have no branch or subsidiary abroad (outside the EU), then no need to consider the new EU GEAs. But some national GAs may change, and so businesses need to review these to make sure you are trading with the latest permissions. Another key point on the bucket list is to implement an ICP if not already done. And if you have one, the dual-use regulation is a great opportunity to update the current one. Tom Blass, WorldECR: What is the new definition of ‘exporter’ under 821? Arne Mielken, Customs Manager Ltd: The definition of an ‘exporter' also applies to any natural or legal persons or any partnerships. This now includes also researchers involved in dual-use technology transfers. The person that contracts with the consignee in the third country and/or has the power to determine the sending of the items out of the EU. transmits software or technology electronically to a destination outside the EU or makes them available in the electronic form to a person outside the EU any natural person carrying the dual-use items in the person’s baggage Tom Blass, WorldECR: Is there anything really important for non-EU companies to know? Yes, I would at least 5 points that are important for exporters from non-EU countries that move goods through the EU, such as the UK. 1. There are no extraterritorial controls in the EU like in the US, but this does not mean you can ignore EU export controls. 2. Don’t assume that the rules in your country as regards export controls are the same as in the EU, even where your country and the EU are signatories to the Wassenaar Agreement. 3. Remember that this regulation enables the EU to implement autonomous controls and so it may be that, in the future, there will be controls that do not exist in your country. In the future, there will be an EU mechanism for human rights controls on cyber-surveillance exports, including the publication in the Official Journal (C series) of an “EU watch list”, that also non-EU companies need to know about. There is also a mechanism for the EU to “react rapidly to new risks associated with emerging technologies”, including the publication in the Official Journal of national controls on such emerging dual-use technologies; There are practical changes, too. 4. If you are moving dual-use items through the EU, think about the transit changes. There is a certain level of harmonisation and revision of provisions on transit, to make it more effective in practice (e.g., any MS can prohibit a transit through its territory). 5. Question of jurisdiction. Next, remember that when a dual-use item enters the EU and then are exported, third-country companies may need to make an export control application in the Member States that the Dual-Use Items are. This often requires a person in the EU, to be held legally responsible. How will you get a Polish or Slovak Export Control licence though? Tom Blass, WorldECR: Will the new regulation be applied uniformly across the EU? Arne Mielken, Customs Manager Ltd: The regulation is directly appliable across all of the EU 27, so yes the rules are the same. But not all rules can be acted upon right away. We are now at the implementation stage, so expect gradual changes and amendments to national licences and processes and procedures. I don’t expect a disruptive change in the next weeks. The new Regulation requires actions for the implementation of new rules: Expect provision of guidelines to exporters and licensing authorities (e.g., due diligence for human rights, internal compliance programmes, etc.), so this should greatly assist with the uniform implementation. With that said, do not forget that licences and decisions regarding licences are a national competence, so there will be a certain degree of divergence. Tom Blass, WorldECR: Is there anything in the regulation that will make compliance easier for my company? Arne Mielken, Customs Manager Ltd: I think so. Some are five less practical consequences of these new rules. They are not tangible immediately but they should improve the way the EU authorises licences. 1. More harmonisation across the EU should be about a certain degree of stability and predictability, making it easier for businesses to plan and stay compliant. The rules allow for the EU countries to work more closely amongst themselves and with allies on emerging technologies. For example, there will be an “Emerging Technology Expert Group” (ETEG) on certain emerging technologies. 2. Secondly, transparency. This allows our businesses to know what the rules are and what we need to do, for all Member States. Again, this can boost compliance. There is enhancing information exchange between licensing authorities and the EU Commission to increase the transparency of licensing decisions; robust enforcement of controls 3. Training: There will be an EU capacity-building and training programme for Member States' licensing and enforcement authorities. May the EU could consider making this training available to exporters as well as the EU does in the area of customs. 4. Outreach to industry and transparency with the business community and the developing a structured relationship with the private sector through specific consultations of stakeholders by the relevant Commission group of Member States experts; 5. IT: There is a move to an EU electronic wide licensing platform rather than individual applications like is the case now. This could simplify and streamline processes and, therefore, improve compliance. There is a website already where the current system can be explored plus a promotional video which I have placed on the expert blog on customsmnager.org for participants to download and watch. See: https://webgate.acceptance.ec.europa.eu/frontoffice/welcome Video: https://audiovisual.ec.europa.eu/en/video/I-207430?lg The most practical compliance area of compliance facilitation is, however, of course, the new two GEAs 007 and 008, no doubt. We will talk about that in a couple of weeks. About Customs Manager Ltd. Working with us means having a Customs Advisor , Global Trade Exper t and Export Controls Consultant , on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline . Or sign up to our no-charge, insightful newsletter . Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker . We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

(P) This guide explains how to interpret the Rules of Origin under the EU-Canada Free Trade Agreement - CETA This series has three parts: Part 1: How businesses gain better access and save real cash Part 2: EU Exporters to Canada: How to secure zero duty trade in three easy steps Part 3: Summary of the CETA agreement (S,P) + Download Rules of Origin and Interpretative Guidance (P) Blog articles followed by S require a Starter Premium Support Plan subscription to access, blog entries followed by P require a Premium Support Plan subscription to access. About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

(P) The Free Trade Agreement between the EU and Canada applies the drawback provision. We explain The Comprehensive Economic and Trade Agreement (CETA) between the European Union and its member states, on the one hand, and Canada, on the other, was published in the Official Journal of the European Union No. L 11 on January 14, 2017. The trading part of the agreement has been provisionally applicable since September 21, 2017 (Official Journal of the European Union No. L 238/9 of September 16, 2017). Article 2.5 of the agreement provides for a prohibition of draw-back. According to Paragraph 3 of this article, the draw-back prohibition applies three years after the agreement has come into force. According to a communication from the European Commission, the draw-back ban will apply from September 21, 2020, three years after the provisional application of the trading part of the agreement. "Draw-back prohibition" means that preference certificates may not be issued in certain circumstances. This is where on-originating materials have been used in the production of originating goods for which that were placed under a special customs procedure (and had their duty suspended on import). This affects, in particular, the inward processing customs procedure. Origin certificates, giving grounds to duty reduction, cannot be issued since the envisaged import duties in question have not been collected in the first place. German customs advises that the issuance of an origin declaration (not observing the draw-back prohibition) automatically leads to customs debt arising according to Art. 78 Union Customs Code (UCC). The date of acceptance of the re-export declaration is decisive for the incurrence of a customs debt (cf. Art. 78 para. 1 UCC). Your Links https://www.zoll.de/DE/Fachthemen/Warenursprung-Praeferenzen/WuP_Meldungen/2020/wup_warenverkehr_kanada1.html TOP TIP We Monitor Canadian legislation so you don't have to

In September 2021, the agreement is four years old. Time to recall why this agreement secures better market access and saves real money to businesses. This series has three parts: Part 1: How businesses gain better access and save real cash Part 2: EU Exporters to Canada: How to secure zero duty trade in three easy steps Part 3: Summary of the CETA agreement (S,P) + Download Rules of Origin and Interpretative Guidance (P) Blog articles followed by S require a Starter Premium Support Plan subscription to access, blog entries followed by P require a Premium Support Plan subscription to access. The European Union (EU) is one of the largest economies in the world and Canada’s second most important trading partner, after the U.S., with around 9.5% of Canada's total external trade in goods in 2015. In 2015 Canada was the EU's 12th most important trading partner, accounting for 1.8% of the EU's total external trade. What is CETA? The Canada-European Union or EU-Canada Comprehensive Economic and Trade Agreement (CETA) presents European and Canadian businesses with preferential access to and excellent opportunities for growth in the EU and Canada. Learn about CETA and what it can do for your business. Does it actually apply already? It entered into force provisionally in 2017, meaning that most of the agreement now applies. All national (and in some cases regional) parliaments in EU countries need to approve CETA before it can take full effect. Progressive... CETA features some of the strongest commitments ever included in an EU and Canadian trade agreement, including on promoting labour rights, on protecting the environment, and on sustainable development. CETA integrates EU and Canadian commitments to apply international rules on workers' rights, environmental protection and climate action. These obligations are binding. Benefits The benefits of CETA include the following: It eliminates duties on 99% of all tariff lines, of which 98% were scrapped when it provisionally entered into force; It defends the Canadian and EU’s Geographical Indications, and; It improves and secures companies’ access to the Canadian and EU services market. CETA means reduced or zero tariffs at Canadian customs for EU businesses and vice versa. What does CETA cover? CETA covers virtually all sectors and aspects of Canada-EU trade in order to eliminate or reduce barriers. CETA addresses everything from tariffs to product standards, investment, professional certification and many other areas of activity. The agreement’s broad scope—including improved access to EU / Canadian markets for goods and services; greater certainty, transparency, and protection for investments; and new opportunities in EU / Canadian procurement markets—translates into real benefits for businesses. Why it matters to businesses... Prior to CETA’s entry into force, only 25 per cent of EU/Canadian tariff lines on goods from the other market were duty-free. On the day that CETA entered into force, 98 per cent of tariff lines became duty-free for goods, and an additional one per cent will be eliminated over a seven-year phase-out period. Tariff elimination will provide enhanced export opportunities into the EU & Canadian market for producers, processors, and manufacturers, as well as for agricultural and agri-food products, fish and seafood, forestry goods, and the full range of industrial goods. CETA’s most visible benefit is the ambitious obligation undertaken by Canada and the EU to eliminate tariffs. Why do tariffs matter for Canada and the EU? Tariffs are essentially taxes levied at the border that have the effect of increasing the costs to consumers of imported goods. These tariffs are applied to “tariff lines,” where each line represents a specific product. Some of these tariffs can be very high (for example, the pre-CETA EU tariff on frozen mackerel was 20 percent and the pre-CETA EU tariff on oats was around 51.7 percent), which made it more difficult for imported Canadian goods to compete in the EU market. For producers, manufacturers and exporters, the progressive elimination of tariffs provides increasingly better competitive market access terms for their products over time. Tariffs that are subject to a phasing out by the EU will include, for example, those on some fish and seafood products, grains, and passenger vehicles. Once CETA is fully implemented, seven years after entry into force, approximately 99 per cent of all tariff lines will be duty-free. Rules of origin CETA’s rules of origin strike a good balance, respecting the real-world sourcing patterns of Canadian and European companies while encouraging production to take place in Canada or the EU. CETA provisions relating to autos and other areas, as well as language on cross-cumulation, potentially allow for third parties (with whom the EU and Canada have FTAs) to be brought into a single free trade area encompassing Canada, the EU, and the third party. Access the Rules of Origin Hub: https://www.customsmanager.org/rules-of-origin Customs and trade facilitation Canada and the EU share a desire to keep customs procedures simple, effective, clear, and predictable so as to reduce processing times at the border and make the movement of goods cheaper, faster, more predictable and efficient. CETA includes commitments that aim to: provide importers/exporters with all the information they need on importing or exporting, including advance rulings on the origin of goods or tariff classification; simplify and, where possible, automate border procedures; respect the privacy of company information collected for customs purposes; and provide an impartial and transparent system for addressing complaints about customs rulings and decisions where there may be differences of opinion. Regulatory cooperation and conformity assessment New Market Access CETA helps to ensure that unnecessary or discriminatory regulatory requirements do not diminish the value of new market access to the EU and Canada. Cooperation and information sharing between Canadian and EU regulators result in more compatible regulatory measures that could make it easier for businesses to do business in the EU and Canada. Regulatory cooperation Cooperation in regulatory matters is forward-looking and promotes good regulatory practices and engagement early on as measures are being developed. By fostering cooperation earlier in the regulatory process, differences in regulatory approaches between Canada and the EU may be reduced, resulting in fewer barriers to trade once regulations are finally put in place. CETA also includes a protocol on conformity assessment, which allows Canadian companies in a number of sectors to have their products tested and certified for the EU market right here in Canada. This is a significant innovation that saves companies time and money and is particularly useful to small and medium-sized enterprises. Government procurement Canadian and EU companies can bid on opportunities at all levels of the EU or Canadian government procurement market, which is worth trillions annually. People and companies are not the only ones active in the marketplace. Governments are also important participants, whether through the purchase of office materials or the construction of roads and bridges. CETA’s commitments expand and secure opportunities for Canadian firms to supply their goods and services to all levels of EU or Canadian government, including thousands of regional and local government entities, and a large array of entities operating in the utility sector. Trade-in services and labour mobility Canadian and EU service providers have more business opportunities in the EU or Canada. Furthermore, CETA makes it easier for certain skilled professionals to work temporarily in the EU or Canada. CETA gives Canadian and EU service suppliers great market access. This means that Canadian suppliers in most service sectors are on an equal footing with EU or Canadian service providers. CETA uses a negative list approach, meaning that all services sectors are covered unless explicitly listed as otherwise. About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. TOP TIP: FTA TRAINING GET ACCESS TO MORE INSIGHTFUL BLOG ENTRIES 365 24/7 support helpline About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

(S,P) Read a summary of the agreement and download interpretative guidance for rules of origin (P) This series has three parts: Part 1: How businesses gain better access and save real cash Part 2: EU Exporters to Canada: How to secure zero duty trade in three easy steps Part 3: Summary of the CETA agreement (S,P) + Download Rules of Origin and Interpretative Guidance (P) Blog articles followed by S require a Starter Premium Support Plan subscription to access, blog entries followed by P require a Premium Support Plan subscription to access. The Canada-European Union Comprehensive Economic and Trade Agreement (CETA) is a bilateral agreement between Canada and the EU. The agreement covers virtually all sectors and aspects of Canada-EU trade in order to eliminate or reduce barriers. Why CETA matters CETA represents the best in international trade agreements. CETA sets new standards for trade in goods and services, non-tariff barriers, investment, government procurement, and other areas like labour and the environment. The EU is one of the largest economies in the world and Canada’s second-largest trading partner after the United States. It is also the world’s second-largest importing market for goods. The EU’s annual imports alone are worth more than Canada’s GDP. By opening new markets in the EU to Canadian exporters, CETA gives us a competitive advantage in the global market, which benefits all Canadians. CETA is helping to create jobs, strengthen economic relations and boost Canada’s trade with the world’s second-largest market. What CETA covers CETA covers virtually all sectors and aspects of Canada-EU trade in order to eliminate or reduce barriers: Trade in goods: CETA eliminates tariffs and reduces barriers for virtually all sectors and aspects of Canada-EU trade. Rules of origin: Canadian exporters have clear and favourable rules that consider the EU's and Canada’s supply chains to determine which products are considered originating and therefore eligible for preferential tariff treatment. Customs and trade facilitation: Canada and the EU are working to keep customs procedures simple, effective, clear and predictable. This reduces processing times at the border and makes it easier to move goods between countries. Regulatory cooperation and conformity assessment: CETA helps avoid unnecessary or discriminatory regulatory requirements. Canadian and EU regulators are collaborating to create regulatory measures that make it easier for Canadians to do business in the EU and vice versa. Government procurement: Canadian and EU companies can bid on opportunities at all levels of government in the EU or Canada. Trade in services and labour mobility: CETA provides EU and Canadian service providers with more business opportunities in Canada and the EU and makes it easier for certain skilled professionals to work temporarily in Canada and the EU. Investment: Investment provisions in CETA are designed to give investors greater certainty, stability and protection for their investments and to provide access to an independent dispute resolution mechanism. Sustainable development, labour and the environment: CETA includes clear commitments to uphold the EU's and Canada’s high standards and not to undermine them for commercial gain. Clear language confirms the right to regulate for all levels of government. What it means for Canadian and EU businesses Here’s how CETA helps businesses across Canada: Competitiveness: Gives Canadian and EU businesses preferential access to one of the largest economies in the world. Access to new clients: Allows Canadian and EU businesses to supply goods and services to all levels of EU and Canadian governments. It also offers new opportunities with regional and local governments. Market transparency and stability: Sets requirements for product standards, investment, professional certification and other areas of activity. It also includes labour rights and environmental protection. Reduced barriers to trade: Makes it easier to move goods across borders and for business people to get to the right place at the right time to pursue opportunities. Summary of the agreement Full CETA Trade Agreement Press Release 2020 - Three Years on Press Release 2021 - Four Years on https://trade.ec.europa.eu/doclib/press/index.cfm?id=2302 Download Interpretative Guidelines on Rules of Origin (P) These are essential for businesses to assess if they meet the Rules of Origin which allow goods to benefit from preferential duties. Helpline About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

(S,P) EU Exporters to Canada: How to secure zero duty trade in three easy steps under CETA To benefit from preferential tariff treatment under CETA, EU exporters will have to complete these few simple steps: This series has three parts: Part 1: How businesses gain better access and save real cash Part 2: EU Exporters to Canada: How to secure zero duty trade in three easy steps Part 3: Summary of the CETA agreement (S,P) + Download Rules of Origin and Interpretative Guidance (P) 1. Apply for a Registered Exporter (REX) number by completing this form 2. Send the completed form to your national Customs Office 3. Get a Rex Number You will then receive a REX number to indicate on the origin declaration to be provided on the commercial document that describes the product Result: The originating product may then benefit from CETA in Canada on the basis of the origin declaration About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information, unless other sources are identified. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. We cannot guarantee the quality, content, or accuracy of the information provided on this page as laws and information change regularly. Moreover, the application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

Businesses can reject your goods when they are not up to standard. Find out how to reclaim your taxes paid for faulty or wrong goods (S,P) Find out how to claim repayment or remission of customs charges paid on rejected imports customs forms issued by customs authorities. Businesses can claim for repayment or remission of customs charges on goods you have been charged import duties on (including import VAT) at their border, which: do not meet the conditions of their contract are defective are damaged before customs clearance Businesses cannot make a repayment or remission of customs charges claim for goods they have bought when VAT has been charged at the point of sale unless you are a VAT-registered business. If you are not a VAT-registered business, the seller or online marketplace you bought the goods from should refund you the VAT. When to apply You must submit your claim one year from notification of the debt for rejected imports. Customs authorities usually can extend these time limits if there are exceptional circumstances (for example, a fire or flood has destroyed your records). You may contact the authorities to ask for a time limit extension. What you’ll need You must attach any supporting documents to the form, such as: a copy of the import invoice documentary proof of entitlement a calculation worksheet if you’re claiming a proportion of the charges paid How to claim There are forms electronically or .pdf that the customs authorities will ask you to complete. For example, in the UK, there is form C&E1179 import duty Common Agricultural Policy and anti-dumping duty charges VAT and excise duty paid on rejected imports About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information with a view to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

Returned Goods Relief or RGR is a popular way to claim back money spent. But make sure the conditions are met, says Arne Mielken of Customs Manager Ltd. RGR allows businesses to pay less import duty and VAT when re-importing goods to the country or the territory it came from. This means the business can claim a relief to pay less Customs Duty and VAT if they re-import goods to that country. Getting your dedicated Customs Manager to complete your customs declaration You can use us to complete entries on your behalf, and we will ask you for clear written instructions for the goods that you’re claiming relief on. Find out about our Customs Declaration Service Unaltered State Usually, as a condition of Returned Goods Relief (RGR), goods must be re-imported in an unaltered state, apart from any work that may have been carried out to maintain the goods in working order, the goods cannot have been upgraded to increase their value. Free Circulation The businesses goods must also have been in free circulation in the country or customs territory from where they were exported, unless they were originally declared to a customs procedure called inward processing or so-called "end-use". No export for repair The RGR goods must not have been exported to be repaired or processed, if they were but the repair or process was not carried out, relief may still be available, check with your local customs. 3 Year Rule To benefit from relief, the returned goods must be re-imported within 3 years of their export, shorter periods apply to goods that benefitted from agricultural measures at export. ATTENTION: The requirement that the goods must be returned within 3 years can be waived by customs authorities in exceptional circumstances. Returning only some of the goods If only a proportion of the original export is returned, then subject to the conditions above, relief is available. Can I claim back import VAT? To claim relief on the import VAT, the exporter and importer must be the same person.In addition to customs requirements, when you claim VAT relief you usually must show the: original export declaration with you as the exporter – if you cannot provide this the customs authorities may consider alternative evidence of export re-import declaration with you as the importer. LIVE ONLINE TRAINING Situations can claim RGR relief on You can get relief on goods being imported into Country A following their export from country A. This may include, for example (check with you local customs or let's talk details) goods exported as free circulation goods benefitting from agricultural measures goods exported following inward processing goods imported which were previously declared to authorised use in the same country (if the goods are put to the same authorised use when imported) goods temporarily exported using the Admission Temporaire (Temporary Admission) (ATA) or Carnet de Passages en Douane (CPD) carnet procedures goods declared for an outward processing procedure and exported, that remain: unprocessed on re-import in the same state as they were when originally exported returned personal effects, vehicles, sports equipment or means of transport returned professional and commercial equipment that has been hired, leased or loaned outside the country, Relief on pallets, containers and packaging You can usually get relief on pallets, containers and packaging suitable for re-use, for example, if they are: used to import goods pallets and containers previously exported or used to export goods, which are re-imported Goods imported in baggage You usually do not need to make a formal customs declaration to claim relief on your own personal belongings re-imported in accompanied baggage if the conditions for relief are met. You must declare any other re-imported goods in your baggage, for example, commercial samples, at the red channel or redpoint when you arrive, and we may ask you to make a formal customs declaration claiming relief. Goods imported by post from outside a country/territory One idea is to ask the sender to write ‘Returned goods — relief claimed’ clearly on the package and its accompanying customs declaration. The declaration should then include a complete and accurate description of the goods, their quantity and value. If the business is registered for VAT, the business can quote the VAT number is quoted on the declaration (CN 22 or CN23). Claiming relief Businesses can usually claim relief at the time of import. If you do not do this, customs may accept a late claim and repay the appropriate charges, subject to conditions. Businesses can claim Returned Goods Relief in the normal way, orally or by conduct (walking through the green channel). Where a business is sending your items by freight, they may claim the relief by using the relevant (customs) procedure codes in the national customs tariff. EXAMPLE: THE UK Businesses may be asked to complete the C1314 and C&E1158 forms to support claims. Take a look: EU: Returned Goods Relief Read the guidance on how to claim relief and what conditions you need to meet in each EU member state: Austria Belgium Croatia Cyprus Denmark Estonia Finland France Germany Ireland Italy Latvia Lithuania Luxembourg Malta Netherlands Poland Portugal Romania Slovakia Slovenia Spain Sweden Proof eligibility It is usually that businesses need to prove that the goods satisfied the conditions for acceptance as returned goods at the time of previous export from the originating country. Alternative evidence Customs authorities may consider alternative evidence which clearly confirms the previous export of those goods and their duty status at export (that is, goods in free circulation, products of an inward processing operation or end-use goods). If the goods are readily identifiable and duty status is clear, they may accept one or more of the following documents as evidence: a document that proves the goods were previously in that country a copy of the export invoice a copy of the export airway bill or bill of lading a commercial certificate of shipment prepared at the time of export a certificate of posting relating to the export of the goods a copy of the import invoice if it clearly shows that the goods are being returned a suitable statement from the manufacturer or exporter if other than yourself a preferential origin form, for example, in the EU or UK, the EUR1 in certain cases in the case of collectable items, catalogue information or qualified opinion from a recognised expert in the field such as National Institutes and specialist auction houses record from the trader’s stock record book. Check for alternative arrangements A business that regularly imports returned goods and find the presentation of the evidence at the time of import is difficult, can try to make alternative arrangements. Please contact us for details. After you’ve claimed There are usually some important records you must keep, like any customs acknowledgement letters receipts bills invoices insurance documents It is usual to keep all records for a minimum of 4 years. ​About Customs Manager Ltd. We are on a mission to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We offer consultancy and expert advice, training (live, in-house and on-demand), support for your import and export business and customs clearance/broker services into the UK (Great Britain) and Northern Ireland. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. We even file customs declarations for you. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information with a view to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

In this two-part series, we consider the pros and cons of setting up an EU base as more UK firms move abroad to avoid crippling Brexit costs. In part one, join Arne Mielken and a team of Global Trade Specialists and Customs Manager in the debate. Many UK businesses have been hit hard by our departure from the EU and are now looking to set up operations in Europe to avoid hefty customs fees and border delays. But it’s not just big businesses that are investing in premises abroad to bypass the profit-sapping bureaucracy and extra costs thrown up by Brexit. About one in five small businesses exports overseas, according to the Federation of Small Businesses, and many are scouting for space across the Channel. Model train maker Hornby and the retailer JD Sports are thought to be among the companies currently looking for warehouse space in the EU. But it’s not just big businesses that are investing in premises abroad to bypass the profit-sapping bureaucracy and extra costs thrown up by Brexit. About one in five small businesses exports overseas, according to the Federation of Small Businesses, and many are scouting for space across the Channel. The pros of setting up an EU base There is certainly far less paperwork and fewer costs for UK exporters, once established in the EU. Once inside the “club”, there are zero customs formalities and declarations to slow things down, and you don’t have to grapple with the notoriously complex rules of origin to enjoy tariff-free trade. Frictionless trade within the EU means no customs duty, no border clearance paperwork or delays at ports to worry about. No-one wants to see their goods left spoiling in the back of a stationary lorry just because a form’s been filled in incorrectly. With a base in Europe, UK firms can also benefit from EU VAT rules so there would be no need to register for VAT in multiple jurisdictions – one is usually enough. In addition, there are no complicated sanitary and phytosanitary (SPS) checks required to protect animal or public health. Perhaps the biggest benefit of having an EU presence, however, is the promise of more sales. You have direct access to more than 400 million customers who are all following the same set of rules and freedoms. Being closer to customers means being able to serve them better. Trading with them can continue as frictionless as before. This avoids them having to worry about customs procedures themselves – just for the privilege of importing from you. This is something few EU businesses have an appetite for. Continuing to trade with you from outside the EU may otherwise require them to act as an importer which comes with onerous registration and compliance obligations, not to mention being charged customs duty and having to deal with import VAT. The cons of setting up in the EU But there are also potential downsides that businesses should consider before rushing to acquire warehouse space in the EU. Crucially, you should factor in set-up costs which could be considerable and possibly prohibitive for some smaller businesses. Then there are the costs and disruption associated with moving employees out of the UK, or hiring new staff from within the EU. Finding suitable premises or workers can be a lengthy and frustrating process, especially in a foreign country with different languages and ways of doing things. It also means complying with new rules and requirements for setting up in the EU, which can vary among member states and result in some duplication of tasks. However, the EU tries to encourage countries to streamline procedures through a single administrative body and register companies through the national contact points You can find more advice on this here: https://europa.eu/youreurope/business/running-business/start-ups/starting-business/index_en.htm Customs warehousing Ideally, UK firms should either rent space from an existing operator or turn premises they already have into a customs warehouse. This would enable you to store goods on EU territory without being subject to immediate import duties. The payment of duties would be delayed up until the point that goods are imported or sold into the EU. To be authorised, you would need to meet strict customs warehouse requirements and have the necessary IT systems in place to track goods in and out. Setting up a base in the EU may not be a viable option for some small businesses, however, but there are other ways to reduce costs when exporting from the UK. You could consolidate goods in one weekly shipment, for example, rather than export items daily to minimise delays and friction. You could store some products in the EU if you have this capability. UK-based exporters should make sure they work with well established, competent freight agents and carriers in order to clear customs into the UK or EU efficiently. You should also ensure you have all the registrations to trade with the EU and upskill staff to learn about the necessary customs processes and procedures. There are several free online tools to help you do this. Use the Access2Markets database of the EU or ROSA, the EU’s self-assessment tool to assist you in complying with the rules of origin. https://trade.ec.europa.eu/access-to-markets/en/content The UK also has a great support tool, which allows you to check duties and customs procedures for exporting goods. It shows the rules and restrictions, tax and duty rates and what exporting documents you need. https://www.gov.uk/check-duties-customs-exporting SME entrepreneurs can read more expert advice on low-cost trading with the EU here: http://elitebusinessmagazine.co.uk/global/item/is-there-a-low-cost-way-to-prepare-for-brexit?category_id=208 But if you are thinking about investing abroad, make sure you look at the potential downsides, as well as the benefits, of setting up shop in the EU. Access Part 2 In this second part of our series, we consider the top 10 tips to consider when setting up shop abroad. Access a step-by-step guide, too! https://www.customsmanager.org/post/part-2-shall-i-set-up-shop-in-the-eu-to-beat-brexit Links Read the article published by Elite Business Magazine http://elitebusinessmagazine.co.uk/global/item/should-i-move-to-the-eu-to-beat-brexit?category_id=208 FAQs - Setting up a European Company (SE) If a company has its head office in a non-EU country, can it participate in the formation of a European Company? https://www.customsmanager.org/post/faqs-setting-up-a-european-company-se About Arne Mielken Arne Mielken is a leading global trade professional in the UK and the EU and Managing Director of Customs Manager Ltd. He is an accredited customs & export control practitioner and certified classification specialist. Arne is on a mission to empower businesses and people with import and export responsibilities with advice, consulting, training and trade intelligence to grow their businesses by trading across the border effectively, efficiently and, of course, compliantly. https://www.linkedin.com/in/arnemielken/ https://twitter.com/MielkenArne About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer pubic and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements. Join us on social media · YouTube · Twitter · Linked In · LEAVE us a POSITIVE REVIEW ON GOOGLE Important Notice Customs Manager Ltd. owns the copyright in this information. You are not allowed to use this information in any way that infringes the intellectual property rights in it. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Premium subscriber to the Customs Managers’ Trade Intelligence service. As a Premium subscriber, you may download and print this information which you may then use, copy or reproduce for your own internal non-profit-making purposes. However, under no circumstances are you permitted to use, copy or reproduce this information with a view to profit or gain. In addition, you must not sell or distribute this information to third parties who are not members of your organization, whether for monetary payment or otherwise. This information is intended to serve as general guidance only and does not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd, be liable for any decision made or action was taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.