CE Int ConsultingWelcome to Customs & Excise Intl. Consulting Limited (CEICL).

CEICL is a boutique Customs and Excise Consulting Service to industry, established in 2015 by Chris Byrne and Jenny Brady Byrne to provide unique services in the area of customs and excise and trade advice to businesses in Ireland, the EU, and third countries. Chris, who previously worked with PwC and also served nationally and internationally as a Customs and Excise Official with the Irish Revenue Commissioners.

The CEICL is supported by a team of experts in customs, industry, and large practice experience to bring to the business sector. CEICL is part of a network of Legal, Tax and VAT professionals in Ireland, the UK, other EU Member States, USA, and other third countries. Due to the wealth of experience, we have extensive contacts in Customs Authorities throughout Europe, the US, Australia and also in the EU Commission and World Customs Organisation.

As an independent practice, there is no restriction or limitation on the services CEICL can provide such as those restrictions resulting from US Sarbanes Oxley and other similar regulations in other territories.

2015/16 Combined Nomenclature Published


The 2015/2016 Combined Nomenclature is published as European Commission Implementing Regulation No 1011/2014 of 16 October 2014.

The Combined Nomenclature – European commission

The basic regulation is Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff. An updated version of the Annex I to the Combined Nomenclature Regulation is published as a Commission Regulation every year in the L-series of the Official Journal of the European Communities (as well as on CD-ROM). Such updates take into account any changes that have been agreed at international level, either at the World Customs Organisation with regard to the nomenclature at HS level or within the framework of the WTO with regard to conventional rates of duty. Other changes may be required to reflect the evolution of, for example, commercial policy, technology or statistical requirements.

The Union Customs Code

sarbanes_oxley--150x150The Union Customs Code was published in Regulation (EU) no 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code (Official Journal L 269 of 10.10.2013).  This is available from the European Union website.   The UCC entered into force on 1 May 2016.The Commission Implementing Regulation (EU) 2015/2447 and The Commission Delegated Regulations (EU) 2015/2446 sets out the details as to the operation of the Union Customs Code.  Please see the update in relation to Implementing Acts and Delegated Acts page.

UCC – Introduction
The Union Customs Code (UCC) is part of the modernisation of customs and serves as the new framework regulation on the rules and procedures for customs throughout the EU. Its substantive provisions enter into force on 1 May 2016.

Simplicity, service and speed are the key drivers of the UCC: Read the rest of this entry »

REACH Chemical Regulations

chemREACH Chemical Regulation Registration, Evaluation, Authorisation and Restriction.

REACH is a new European Community Regulation on chemicals and their safe use and entered into force on 1 June 2007 and will take effect on 1 June 2008. The aim of REACH is to ensure a high level of protection of human health and the environment as well as the free movement of substances, on their own, in preparations and in articles, while enhancing competitiveness and innovation. REACH should also promote the development of alternative methods for the assessment of hazards of substances.

Read the rest of this entry »

Next HS change will be January 2017

HSFollowing the end of the 2017 review of the HS, many classification codes changed with effect from I January 2017. The classification codes used for Intrastat reporting and customs clearance at import and export may be impacted. We suggest you check the following:

Classification used for Import and Export Customs clearance codes;
Preferential Origin Qualification criteria;
Binding Customs Rulings, tariff and origin;
Customs Special Procedures,
Intrastat Returns;
Duty Suspensions; and
Trade Protection measures that affect your business, i.e. anti-dumping and countervailing duties, and tariff quotas.
Your should ensure that your customs clearance agents/carriers are informed, as the impact of the changes may cause shipment delays or result in unexpected duty bills or penalties.

The 2017 correlation tables will be available on the WCO website.

The 2017 Review of the HS is almost complete, watch this space.

INNS – Amended List Published Annually


imagesRFDEE11SAmendments to the INNS list are published annually by the World Health Organisation and t

hen published in an EU Official Journal. If you are importing or exporting pharmaceutical active ingredients, INNS specified salts, esters or hydrates of such INNS, or pharmaceutical intermediates used in the production of finished pharmaceutical products, we recommend you review your imports and exports in light of these changes. The amendments to the Combined Nomenclature (“CN”) include:

Annex 3 of the CN – pharmaceutical substances that are duty free.

Annex 4 of the CN – list of prefixes and suffixes which, in combination with the INNS of Annex 3, describe the salts, esters or hydrates of INNS; these salts, esters and hydrates are duty free provided they fall to be classified in the same 6-digit HS subheading as the corresponding INN.

Annex 6 of the CN –list of pharmaceutical intermediates (compounds used for the manufacture of finished pharmaceutical products) which are duty free.

Please contact us for more information.

Excise Movement and Control System (‘EMCS’)

emcs_seed_enEMCS is a computerised system for monitoring movements of excise goods between Member States under duty suspension. It will replace the paper document that currently must accompany such movements (the Administrative Accompanying Document or “AAD”). EMCS will mean simplification of procedures, paperless administration, and effective use of modern IT tools and amounts to an important evolution for those who trade in alcohol, tobacco or oil products.

Read the rest of this entry »

The EU Customs UCC Delegated Act (DA) and UCC Implementing Act (IA)

UCC – Introduction

The Union Customs Code (UCC) is part of the modernisation of customs and serves as the new framework regulation on the rules and procedures for customs throughout the EU. Its substantive provisions enter into force on 1 May 2016.

Simplicity, service and speed are the key drivers of the UCC:
• Simplicity: ◦The UCC builds on existing concepts to streamline the customs processes and procedures across the Customs Union. For instance, it clarifies the rules on release for free circulation and on special procedures.
◦The UCC covers most of the customs legislation in one package and provides for precise rules of application.
◦It defines data requirements for customs, pre-arrival and pre-departure declarations, notifications, applications and decisions in an integrated way designed to enable its modelling via the nationally extensible EU Customs Data Model and in full compliance with international standards like the WCO data model.
All of this will contribute to a harmonised implementation across the EU.
• Service: ◦The design of the UCC took into account to a large extent the daily needs and existing practices of trade. For instance, it allows the use of electronic transport manifests for customs purposes, moving goods under temporary storage without lodging a transit declaration and it envisages new forms to extinguish a customs debt.
◦It introduces modern concepts, such as centralised clearance, and offers more uniformity to business, by providing uniform and harmonised rules on guarantees, for example.
◦It also reduces the administrative burden on compliant and trustworthy economic operators (AEOs) by allowing a number of simplifications on customs procedures, on the use of guarantees and self-assessing their customs debts under certain conditions.

• Speed: ◦The UCC strives for further automation of all exchange and storage of information through additional IT systems that integrate the new processes and legal requirements, such as common and shared services to customs and harmonised interfaces and EU portals to trade.
◦The UCC shortens from 6 to 3 years the period of validity of the decisions on tariff classification and origin, to better adapt to a rapidly changing world.

While the substantive provisions of the UCC enter into force on 1 May 2016 it is necessary to have a transition period before full implementation can be achieved. This is primarily due to the fact that there is a need to develop new IT systems or upgrade existing ones in order to fully implement the legal requirements. Therefore not all of these systems will be in place on 1 May 2016. This transition period lasts until 31 December 2020 at the latest. The detailed rules regarding the transitional period are contained in a Transitional Delegated Act and the UCC Work Programme. Their practical application is addressed in several guidance documents produced in collaboration with Member State and Trade representatives. These rules will ensure a smooth transition from the existing customs legislative regime to the new UCC rules on a gradual basis between 1 May 2016 and 31 December 2020.

The UCC in a nutshell

The UCC is meant as a natural evolution towards a modern customs environment for which the results and benefits will be grasped only when it will be implemented in its full capacity by the end of 2020 with a view to :
•Streamline customs legislation and procedures
•Offer greater legal certainty and uniformity to businesses and Increase clarity for customs officials throughout the EU
•Simplify customs rules and procedures and facilitate more efficient customs transactions in line with modern-day needs
•Complete the shift by Customs to a paperless and fully electronic and interoperable environment
•Reinforce swifter customs procedures for compliant and trustworthy economic operators (AEO)

This will enhance the competitiveness of European businesses and thereby advance the main goals of the EU strategy for growth and jobs. In addition, the changes envisaged by 2020 will protect the flow of goods transiting or moving in and out of the Union and safeguard the financial and economic interests of the Union and of the Member States as well as the safety and security requirements.