Import declaration
Also known as: IMA, entry for free circulation, H1
An import declaration is the declaration with which goods from a third country are released into free circulation in the EU. In the Netherlands it has run through DMS since the move from AGS, where the standard form is called IMA.
What is in an import declaration?
The declaration contains per article line the goods code, the description, the country of origin, the customs value, the weight and the quantities, plus the documents and authorisations that belong with that code. At file level stand the declarant, the importer, the form of representation, the means of transport and the place where the goods are. The goods code on import is ten digits, the TARIC code, because the measures hang on that. The customs value follows from the invoice plus or minus the costs to the external border, depending on the Incoterm. The country of origin is the country of production, not the country of dispatch. Those three fields together decide the tariff. In addition the previous procedure and the MRN of for example the T1 belong on the declaration, so the chain closes. If that reference is missing, the T1 stays open while the goods are already in free circulation. The IMA is then substantively in order and administratively a gap.
Which declaration types does DMS know?
IMA is the ordinary import declaration with the full data set, in EU terminology H1. STO is the declaration for placement in a customs warehouse and ATO the supplementary declaration on entry in the records. The difference sits in one data group: on IMA you pay, on STO you place, on ATO you complete later. In addition there is H7, the super-reduced data set for e-commerce shipments up to one hundred and fifty euro, which in the Netherlands runs through DECO. Above that threshold, or for excise goods and prohibitions, you fall back on the IMA in DMS. DECO is not a shortened IMA, it is a different channel with a different data set. DMS is the Dutch Customs Management System for import and export. It is not ATLAS and not AES. A German declarant does not file in DMS. Anyone writing about DMS as if it were the European system is describing the Dutch gateway to the EU data set, not the system of another member state.
What happens after filing?
Customs checks the declaration automatically against the DTV, the authorisations and the risk profile. On agreement release follows, usually within a few minutes. The MRN is then there, and the goods may leave the place of presentation, under the conditions of the release. On a control the declaration gets a document control or a physical control. The goods then stay under supervision until the control is finished, which on a physical control can take days. For fresh produce that difference decides the shipment. A document control asks for invoice, transport document and certificates; a physical control asks for the container itself. Conditional release occurs: Customs lets the goods go already while processing is still running. That is not a final release. The declarant stays answerable, and a later correction or assessment belongs with the file, not with a closed shipment.
Which controls does Customs carry out?
After filing the declaration runs along an automated risk profile. That looks at the goods code, the origin, the value, the importer, the declarant and the history of earlier shipments. The outcome is one of three: release without control, a document control, or a physical control in which the goods are inspected or scanned. A document control takes hours, a physical control days. For fresh produce that difference is decisive, and that is why AEO status has value: fewer controls, and priority at the controls that are there. AEO is not an exemption, it is a lower hit rate plus a shorter queue. Besides Customs, NVWA and KCB can require an inspection, via a pre-notification in CLIENT PD and a CHED in TRACES-NT. That inspection is not a document control of the IMA, it is a separate gate. Without release from the inspection the IMA does not go through, even if the customs-technical set is in order.
What does the move from AGS to DMS mean?
DMS works with the data set of the Union Customs Code, which is fuller and stricter than that of AGS. Fields that used to be optional are now mandatory, and the code lists are European instead of national. What in AGS was a warning is in DMS a refusal. The practical effects sit in the master data. Articles without a full ten-digit code, without country of origin or without the right document codes no longer get through. A code of eight digits that AGS still accepted stops the IMA before there is an MRN. In addition DMS returns error messages with its own code list. Those codes point to the element that is wrong, but not always to the underlying cause. A code that says an authorisation does not match can just as well mean that the EORI number on the authorisation differs from that on the declaration. Read the element, not only the text of the message.
Which documents belong with an import declaration?
The commercial invoice is leading for goods code, customs value and origin. In addition belong the packing list, the transport document (B/L, AWB or CMR), and the proofs TARIC asks for at the code and the origin: a certificate, a permit, a proof of origin. If a document code TARIC makes mandatory is missing, DMS refuses the declaration. On a previous T1 or STO the MRN of that declaration belongs on the IMA. On goods subject to inspection the release from CLIENT PD or the CHED in TRACES-NT belongs with it. In representation the power of attorney belongs in the file, even if it does not go into the declaration as an attachment. Keep the papers with the MRN, not with the internal file number alone. A later audit asks for the invoice that belonged with that declaration. A collective invoice that covers three shipments without a split is at that question no support.
How do you prevent a refused import declaration?
Check EORI, goods code, origin, customs value and document codes before the declaration goes out. A system linked to the DTV catches most refusals at the moment when correcting is still cheap. A master datum that has not been reviewed for three years is the classic source of a refusal in January, after the annual GN change. Check the Incoterm on the invoice against the build-up of the customs value. EXW without a freight add-back is too low. DDP without deduction of duties is too high. Both sometimes get through DMS and fall at a later audit. The refusal on filing is the cheap error; the assessment two years later is the expensive one. Do not wait with the IMA until the container stands at the terminal without a T1 or without an inspection pre-notification. The chain has an order. An IMA without a previous procedure where that procedure is mandatory is refused or leaves the previous link open. Record the order in the file, not in the head of whoever is on duty that day.