JCCC EU Exit Trusted Trader Sub-Group Update

The July JCCC EU Exit Trusted Trader Sub-Group meeting was lead by Mike Howe, Deputy Director for Customs Strategy and Tax design. The key highlights are listed below

Scope

  • AEO(S) and AEO(C)
  • CFSP (including warehousing)
  • Comprehensive Guarantees (CCG)
  • Simplified Declaration Procedure (SDP)
  • Duty Deferment Scheme
  • Possible single authorisation and mutual recognition

Industry Feedback

  • AEO provides important benefits, but HMRC are not embracing the spirit or intention of
    trusted trader accreditations
  • Application process needs attention
  • Experience is time-consuming and burdensome
  • Not observing time limits (abusing ‘stop the clock’)
  • Application process and application documentation not user friendly
  • Contact / relationship management needs improvement (predictable service)
  • Quality of assurance and audit work inconsistent
  • Lack of cohesion with other authorisations (multiple requests for the same
    information)

HMRC approach and plans

  • Short term service improvements
  • Longer term sustainable solutions
  • Global recognition
  • Facilitated Customs Agreement – but also readiness for NO DEAL
  • Project managed HMRC improvement programme
  • Consultative group with trade / wider engagement with stakeholders

HMRC AEO service improvement plan

  • Reduce ‘elapsed time’ and more disciplined use of ‘stop the clock’
  • Digitise application documentation (capability to save and return to incomplete applications)
  • Industry support and education
  • A more predictable service, including published service standards of what trader can expect
  • Extend approach to other key authorisations

The next meeting is scheduled for 9th August 2018. Updates will be provided subsequent to each meeting.

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