There seems to be no turning back and the deadlines have actually already passed, but still offer a window of opportunity until the end of this calendar year. Even if the new declaration systems for DMS 4.0 appears somewhat the same in terms of "look and feel", underwater and in most processes, things are certainly going to change considerably.
There are many more fields in the new declarations, and a multitude of content checks also take place here due to fitted business rules. In addition, Customs no longer corrects the declaration. This will mainly play a role in the Import declaration. The data structure of the declaration will be completely different from the familiar structure of the Single Administrative Document and the GPA structure used for years.
Whereas export declarations used to get less attention, they seem to become increasingly important and risky. This is due to increasing sanctions and other non-fiscal (so called VGEM) measures.
More and more links need to be made by all kinds of government agencies and customs procedures, making the processes more complex, dependent and vulnerable.
Back to the drawing board
The time where declarants with limited knowledge of customs could ‘just use the same tricks’ and get the work done, seems to be over. Especially for declarants who make (small-scale) export declarations. This means that quite a lot of companies are running up against the wall with this and management needs to go back to the drawing board to review the Customs process within the company. Actually, this should have been done much earlier, but we see in daily practice that declarants had lost confidence in Customs' planning and were hoping for even more delays.
At the moment, companies are working very hard to review their earlier choices of process and Customs software vendors under considerable time pressure.
DMS has now started the first pilot with a small number of companies to gain experience and optimise the electronic declaration process.
What is the status?
Current schedules are being exchanged between stakeholders. Therefore, ask your software supplier if they are ready in time for the migration. The Dutch Customs has now been clear on the deadlines.
For the current warehouse owners with simplifications (IIAA), the deadline for DMS 4.1 is also approaching more and more and Customs is going to start with field audits for review of the current customs authorizations. .
It is becoming increasingly clear that the declaration process will be more dynamic, requires more effort, can cause logistical delays and requires an active notification[PI1] at least for your inbound activities. All in all, for most GPA/SPA companies, this means deterioration in their administrative obligations and efficiency and finally increase in costs. No reasons to feel cheerful about and it is challenging to really see the benefits, despite all the new technology available.
Still, we will eventually start to see the benefits of stable DMS systems, potential customization agreements for AEO declarants and fully automated processes. Patience is still required and hopefully the commitment will be enough to maintain our logistics position, built up over all these years, in the Netherlands.
Are you not yet well prepared for all these DMS changes and looking for a total solution for your DMS declaration process? Then contact us as soon as you can, we are available to support you during this process.
Head of Customs & Trade Affairs