From GPA to DMS: next steps for businesses

Based on the input that GPA declarants provided to Dutch Customs in March this year, Dutch Customs re-examined the DMS possibilities and listened to the business community to come up with better alternatives. For this purpose, the following 3 scenarios were made available when implementing the new Customs Management System (DMS) to replace the current Monthly Import Declaration (GPA):

Scenario 1: Normal declaration procedure, including the simplified (incomplete) declaration and the pre-declaration

This scenario is similar to the current AGS system and can also be used without an AEO license, in case you don't need a Bonded Warehouse and/or other AEO related licenses. You also need to apply for a registration on DMS at Customs and you also need a certified software supplier for this. Does the declarant who submitted the pre-declaration have AEO status? If so, he will be informed about the checks that will be carried out. Announced checks can then be taken into account in advance when planning the logistics.

Don't you have an AEO permit? Then you fall into a different control regime. In this scenario the declaration is also the submission message (unless a pre-declaration is made).

Scenario 2: Entry in the Declarant's Records, with Goods Presentation and periodic Supplementary Declaration

In this scenario, Entry in the Declarant's Records is declared electronically to Customs via a simplified message. You must submit the supplementary declaration within 10 days of the expiry of the period within which the goods are registered in the administration. This period is set at 1 (calendar) day. The supplementary declaration, together with the Goods Presentation message, contains the same data as a declaration in the normal procedure. For this scenario, in addition to your existing licenses, the license 'Registration in the Administration of the Declarant (IAA)' is required.

Scenario 3: Entry in the Declarant's Records, with exemption of Goods Presentation and with periodic Supplementary Declaration

In the third scenario there is an exemption for the Goods Presentation message. In case a declarer is using successive customs procedures, the Good Presentation is only required for the first procedure. This is linked to the so-called 'chain arrangement'. This means that companies with multiple licenses as successive customs procedures are granted dispensation from additional messages for Goods Presentation. For example, in the case of final release for free circulation by placing goods in a bonded warehouse under the Inward Processing Procedure or a Special Customs Regime. A condition is that the goods under these permits are entered in the same business records. In combination with the supplementary declaration and registration of stock movements, Customs has track on your declaration process. For this scenario, in addition to your existing licenses, the license 'Entry in the Declarant's Administration (IAA)' is required.

Representation

If declarants and logistics service providers jointly take care of the declaration process, you should check together the possibilities and in particular the responsibilities for representation by using DMS. Especially if you are going to make use of the simplifications from the IIAA permit.

Stock movements

For stock movement administration, the current solution still needs to be used as a basis (if possible via the current GPA declaration format), because the stock movement administration is not declared in DMS.

This will create challenges for companies that need to maintain both the current and the new system based on this process. They may need to set up an additional interface. In the meantime Customs is working on a new format according to international guidelines: the so-called audit file logistics.

Current GPA declarants are feeling the effects of the introduction of DMS regarding the following aspects:

• They need to set up a new declaration process.
• The impact of the new database should be investigated.
• Master data and transactions need to be declared (near) real-time.
• Reporting of stock movements must be reassessed/implemented.
• The new DMS process is more intensive. This means that declarations, payments and possibly also (internal) control moments require capacity and knowledge.
• Links with other Customs permits, such as Inward Processing, require extra attention.
• They must verify whether the chain arrangement can be complied with, especially if the GPA is submitted by a logistics service provider.
• Companies may end up in a different control regime because of the choices made.

For the further elaboration of DMS and the roll-out to the business community, a new guidance committee has been established by Customs. Pincvision is represented in this guidance committee.

Would you like to stay informed about the latest developments regarding GPA and DMS? Subscribe here for our monthly newsletter. Do you have further questions about the new system? Contact me directly via p.italiaander@pincvision.com or call +31(0)6-83216125.