Now it’s a good moment to clarify the current state of affairs regarding the transition of DMS for current GPA declarants.
Customs has been visiting a great amount of the GPA declarants and discussed the two remaining scenarios:
- Declare via the normal procedure in DMS (similar to the current AGS declaration)
- A scenario where declarants do an inbound registration in the administration (Placing of Union goods under the customs warehousing procedure) and subsequently submit a real-time (additional) declaration
It makes sense as the real specifications from the Message Implementation Guide (MIG) have not been released yet. In this way, it cannot be used to verify whether the required information (from MIG) is actually present and tested at the right time, at the moment of the declaration.
In the current situation, companies can still validate certificates and document codes during the month and implement recovery actions. These are usually initiated by missing and/or incorrect information in the master and transaction data.
What scenario will you choose?
Although the majority of the companies can't really estimate the impact on their business processes when choosing one of the scenarios, they still need to make a decision.
Fortunately, commercial businesses are resourceful and most of these business state that they would like to make use of both scenarios.
In this way, companies are at least able to submit a declaration in scenario 1 (the normal procedure) during the transition period. This will prevent the risk of a possible delay in the process of issuing a (IIAA) permit and the facilitation of customs audits. This probably covers higher administrative costs. As a result, trained declarants need to take care of the additional work, although there is already a lack of trained declarants in general.
Implementation & challenges
The project team at Dutch Customs is currently busy with planning several implementation phases. However, all regular AGS declarants need to be transitioned to DMS before a start can be made with the project for GPA declarants. This is quite an operation and cannot be foreseen in advance in terms of lead times and performance of systems, because huge volumes of declarations will run across the data lines.
In future, the entire DMS data communication will also be facilitated directly by Dutch Customs. This will entail changes in, for example, IP addresses, Firewall settings, user names and passwords. Another topic is the current discussion with Customs EU about the database. The required logic isn’t enough anchored yet. However, a minimum set has been published in Annex B of the Delegated UCC Regulation (only available in Dutch), including fixed common data requirements.
Although this is extremely important for software developers (field names, logic, message structures and message flows), the declaration fields for the user won’t change tremendously. A declaration remains a declaration with the same old standards.
GPA stock mutations
The GPA stock mutations have been excluded from the current DMS scope. During the next phase, a new solution will be developed via a new Audit File format.
In addition, it will become extremely challenging, for companies with a combined license GPA and monthly declaration for IPR and excise, to create a comprehensive administration in the outlined DMS scenarios.
It remains a concern that companies currently aren’t able to properly estimate the impact these DMS changes may have on the their current logistical and administrative (chain) process, the declaration process, resources, knowledge and costs. Moreover, we haven’t even talked yet about all internal control measures, which must be complied with and revised from AEO procedures and Internal Control descriptions. Luckily, the deadline has been extended with one year to July 1, 2022. In this way, companies will have more time to prepare for DMS.
Yellow, Green and Blue flows
Eventually, Customs is going to classify companies into ‘yellow’, ‘green’ and ‘blue flows from a supervisory perspective.
- Yellow flow: mainly focuses on the future where optimal chain integration and (re)use of data being important points of attention which results in the creation of a reliable trade flow.
- Green flow: mainly focuses on AEO companies with proven reliability on the basis of the working of control measures. For this purpose, the company must, among others, monitor itself and its chain partners.
- Blue flow: are companies that can’t be classified in the yellow or green flow. This means that additional supervision and checks are necessary for these companies.
Customs has the ambition to monitor these flows through well-developed dashboards.
What can Pincvision do for you?
Despite the many loose ends in the transition period from GPA to DMS, I would like to conclude my blog with a positive note. At Pincvision, we are closely monitoring the developments regarding DMS and we are happy to help you with monitoring and validating your future Customs processes, focusing on the modern supervision of Dutch Customs.
Did I spark your interest? Don’t hesitate to contact me, Peter Italiaander, Sr. Business Development Manager, for an appointment via firstname.lastname@example.org or call +31(0)6-83216125
Read previous articles written by Peter about GPA and DMS: