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As of the first of April 2021, EU Customs authorities will start actively using (and enforcing the usage of) a new digital system for the electronic handling of INF data in the Special Procedures domain. From that moment on, no paper INF forms will be accepted anymore under an Inward Processing or Outward Processing authorization.
If you apply Inward Processing or Outward Processing in one of the following scenarios, it becomes mandatory to use the INF system:
Inward Processing EX/IM (prior export) or Outward Processing EX/IM (standard procedure);
Inward Processing IM/EX (standard procedure) or Outward Processing IM/EX (prior import), whereby multiple EU Member States are involved.
An INF needs to be applied for in the EU Customs Trader Portal, which - in the Netherlands - can only be accessed with 'e-Herkenning' (level 3). So make sure you have this available!
It will be possible to apply an INF per shipment, but it will also be possible to apply for a single INF for multiple goods covered by your authorization. The number of the INF(s) is to be included in the customs declarations for both inbound and outbound shipments. If no INF number is mentioned in the customs declaration, the declaration will not be accepted by Customs authorities resulting in delays at customs clearance.
Furthermore, as a result of the introduction of the INF system, it is also likely that (some of) your import/export declarations will need to include much more detail regarding the raw materials used in the production of the imported/exported products.
As a first point, it is important to make sure you have access to the EU portal, and therefore have e-Herkenning available. Next to that, it is important to revise the broker-instructions, as the INF number is to be included in your declarations. Furthermore, it is also advised to verify whether any further (product) details need to be included in your declarations as of April.
Would you like to know what this means for your company or should you need any advice on this matter, please contact your usual PwC customs and international trade specialist at PwC.