In the previous message of February 2020 I wrote an update about the impact of a policy change from customs on the situation regarding the definition of exporter. This update is about the Rapid Logistics approach to solve the matter.
Parties in the industry
The trade association EvoFenedex has had several meetings in cooperation with the business community and customs to formulate a workable policy. Until today the 4th of March, no official policy has been drawn up or communicated officially in the industry.
Even today we did have verbally contact with the local customs authorities to ask for an official statement, as the other news messages are suddenly deleted from the customs website. Of course clients and we are asking ourselves where they can find this official announcement, but they do not come with an official announcement. The only answer he could verbally give me is that customs do have a concept for an update in their customs manual, he did see it his selves but is not allowed to share any information in writing on this. Customs is however now advising that they will publish their new manual within a few weeks and that the deadline of the 1st of April stays enforced.
Of course both the clients and the forwarders/customs brokers do need to act and find a proper solution within this time frame.
Rapid Logistics approach
As written in the pervious update Rapid is able to provide a solution. Rapid can take over the roll as exporter based on the fact that we do have a physical control or decision-making authority to export goods outside the European Union. A total new roll that needs to be supported via a new POA. We do prepare on the whole new situation although customs still didn’t officially confirmed the 1st of April. The POA should be drawn up with the highest possible of care but still give everybody enough time to have a solution set up before the 1st of April.
In the past few weeks Rapid was busy with the developments of a POA that covers this new roll in the supply chain. We are involved with our insurance company as well as a lawyer to look into this contract. Currently we do have a positive answer from our insurance company but we are still checking the POA legally to ensure that the POA complies with the legislation of Dutch law.
Offer and POA
The POA and the offer will already be communicated with our clients in order to give both ends enough time to check the contracts by the legal departments. We most probably will get some advices or changes from our lawyers that may affect the content of the contract.
Customs entries in the future and connection for VAT
The customs entries will be issued with a connection to the importers VAT number. We do enter the original EORI or VAT number of the importer on the customs entry documents so we are sure that the connection of the VAT can be made properly. Of course the impact of 21% VAT is huge when not complying to the proof of export of your product.
We have procedures in place to ensure that the confirmation of exit on your export entries is guaranteed. The confirmation of exit is official evidence for your 0% VAT invoice.