Simplifications and amendments in the EU Customs Data Model (EUCDM)

The EU Customs Data Model (EUCDM) is the model for Customs trans-European systems such as NCTS (New Customs Transit System), AES (Automated Export System), ICS (Import Control System), EOS (Economic Operators System) and for Member States’ national customs clearance systems.

Its overall objective is to provide a technical instrument that models the data requirements laid down in EU Customs legislation and present a single and genuine source of information for the technical developments of the different IT systems that are used for data processing by customs in the EU.

The backbone of the EUCDM is the data provided by traders to customs authorities in the various declarations and notifications required under EU customs legislation.

The data requirements are defined in the UCC-DA (UCC Delegated Act), their formats and codes in the UCC -IA (UCC Implementing Act).

One of the main reasons Malta customs upgraded CES to NIS & NES was to comply with the provisions of the Union Customs Code (UCC) in view of the various IT systems that will be implemented by 2025. The UCC stipulates that all communication between Trade and Customs must be electronic.

The Customs department is preparing for changes in:

• The import manifest which will be replaced with a presentation notification and Temporary Storage Declaration;
• Pre-lodged import declaration;

It shall be possible for Economic Operators to lodge a declaration prior to the arrival of the goods. However, the goods must be presented to customs within 30 days from lodgement otherwise the declaration is invalidated.

• Lodgement of a pre-arrival notification ENS (Entry Summary Declaration);
• Import Declaration in NIS will have a slightly new format and some content of the declaration shall change;
• Provision of new Trader Portal where economic operators can apply directly to customs for an authorisation;
• Facilitations: Simplified declaration, Centralised Clearance; EIDR (Entry into the Declarant’s Records) & Self-assessment;
• New data elements according to procedure in question;
• Type/description of declaration type H shall be split in:
• H1 Declaration release for free circulation and special procedure Specific use – declaration for end-use;
• H2 Special procedure – Storage – declaration for customs warehousing;
• H3 Special procedure -specific use – declaration for temporary admission;
• H4 Special procedure – Processing – declaration for inward processing;
• H5 Declaration for the introduction of goods in the context of trade with special fiscal territories;
• H6 Declaration in postal traffic for release for free circulation;
• H7 Customs declaration for release for free circulation in respect of a consignment which benefits from a relief from import duty in accordance with Article 23(1) of Article 25(1) of Regulation (EC) No 1186/2009;
• I1 Import simplified declaration;
• I2 Presentation of goods to customs in case of entry in the  declarant’s records or in the context of customs declarations lodged prior to the presentation of the goods at import; 
• G4 Temporary storage declaration;
• G3 + G4 combination of declaration presentation of goods to customs and temporary storage.

Import Safety and Security Declaration (ENS)

The carrier of the goods is legally obliged to ensure an electronic Safety & Security declaration is submitted for all goods on board. This must be submitted to Malta Customs in advance of departure from the non-EU country where Malta is the first port of call. This declaration is called an Entry summary declaration (ENS) and will be lodged in ICS 2 (Import Control System 2).

In the near future, the Customs department will also be offering the following simplifications:

1.   Simplified Customs declaration (Article 166 UCC)

This authorisation allows the economic operator to speed up the logistics;

Authorisation is granted to AEO-C or to EOs who reach certain AEO criteria;

A reduced data set for speedier clearance;

A supplementary declaration has to follow within a stipulated period agreed with customs.

2. Centralised Clearance (article 179 UCC)

What is Centralised Clearance for Import (CCI)?

Centralised clearance at Import (CCI) is one of the simplifications linked with the placement of goods under a customs procedure of the UCC. CCI is a simplification that entails significant benefits for traders based within the EU, as the Economic Operator (EO) can lodge the customs declarations for import at a single point in the EU at a customs office within the Member State where he is established (Supervising Customs Office for Centralised Clearance for Import - SCI) whilst goods are being physically presented at a customs office in another Member State (Presentation Customs Office for Centralised Clearance for Import - PCI).

Advantages of the Centralised Clearance procedure:

• The CCI concept allows economic operators to centralise and integrate accounting, logistics and distribution functions at one place and reduces interaction with customs by using the SCI as the main single contact partner eliminating the need for multiple brokers and customs offices across the community.
• CCI enables companies to be more competitive in the globalised market and do more business with customers and partners regardless of their location.
• CCI will enable traders to benefit from standardised declarations, reducing the number of datasets for each country and certain customs procedures such as the Transit, whilst optimising the logistics flow at EU level and increasing the efficiency of the processes.
• CCI will facilitate the convenience of centralised finances, allowing traders to manage a singular customs account with reduce administrative costs through streamlined processes and consolidated accounts.

What are the requirements to apply for CCI authorisation?

The main requirement to apply for the CCI authorisation is to hold a valid authorisation and status of an Authorised Economic Operator for simplifications (AEOC).

A request is to be made to the Customs Authority within the Supervising customs office to grant access to the applicant to the CDS (Customs Decision System) AEO’S are to apply at least 120 days before the intention of using the CCI procedure.

Additional references :

CCI Phase 1 Business Guidance & CCI P1 Business Guidance accompanying slides – Centralised Clearance for Import - European Commission (europa.eu)

E-learning module Course on CCI for Economic Operators and Customs Officers - Course: EU Centralised Clearance for Import (CCI), Phase 1, Topic: en (europa.eu)

3.   Entry into the declarant’s Records (EIDR) (Article 182 UCC)

The holder of this authorisation is allowed to lodge a customs declaration in the form of an entry into the declarant’s records provided that the particulars of that declaration are at the disposal of customs at the time of its lodgement.

The entry into the declarant’s records could be either with presentation of goods or without presentation. For the latter additional conditions have to be fulfilled. This authorisation is limited to AEO-C.

4.   Self-assessment (Article 185 UCC)

Allows the EO to carry out customs formalities that are normally carried out by the customs authorities.

• The EO is allowed to determine the amount of import & export duty payable;
• To perform certain controls under customs supervision.

The customs formalities are to be negotiated with the customs authorities and the rules will be laid down in the authorisation.