That’s right — in addition to the new UK Bribery Act, you now have to deal with the EU’s new Import Control System (ICS) and Export Control System (ECS). The ICS, which is the electronic security declaration management system for the importation of goods into the EU, comes into effect with the Export Control System, which is the electronic security declaration management system for the exportation of goods out of the EU, on December 31, 2010. Following in the footsteps of similar electronic customs filing systems, like the US Importer Security Filing (better known as 10+2), the EU is now requiring that a number of data elements must be sent to the EU customs office of first entry before the merchandise enters the territory.
Considering that the data requirements outlined in Annex 30A (as amended by DF” target=”_blank”>Regulation 169/2010) defines seven (7) different tables of approximately 30 elements each (one for air & sea, express consignments, road, rail, AEO, diversion requests, and “simplified procedures”), and that the Consolidated FAQ (for Annex II) is 53 pages, there is a considerable amount of documentation that needs to be reviewed in order to make sure your organization is compliant. While it is theoretically as simple as insuring that, depending on the mode of transport, a set of data fields is provided before the goods enter the territory or, depending on shipment time an/or country of origin, the filing is made before the goods leave the port, verifying compliance is not likely to be as simple.
Plus, as this recent article points out over in MM&D on how you have to prepare for complexity, you have the added complexity in that you will have to handle the specifications for 27 separate countries when the regulations come into effect.
For more information, refer to the European Customs Information Portal.