Dutch Customs has announced a further postponement of the implementation of the new exporter definition, due to the Covid19-crisis. So far, it is an informal notification, but we shortly expect an official publication as well.
As a result, the current deadline of April 1 will be moved to ‘the 15th day of the month following the official disbandment of the Covid19 measures by the Dutch Government’.
The current COVID-19 measures are in force until 6 April 2020 If this remains the case.
In addition to the postponement of the implementation of the new exporter definition, we understood that discussions are taking place on potential further relief matters in response to the considerable economic consequences of the current situation.
As soon as there is more info on this, we dedicate a news-flash on this.
In May 2018, the definition of exporter in the Union Customs Code was officially changed. Following these changes, a non-EU company would no longer be able to export goods from the EU by itself, even by using an indirect customs representative.
Dutch Customs among several other member states followed a more practical approach where non-EU exporters were still able to export goods from the EU by using an indirect customs representative. This meant that in practice, there were no major changes for non-EU exporters (see PwC Tax News 21 August 2019).
In October 2019, Dutch Customs released a statement announcing that a new interpretation would become effective per 1 December 2019 (see PwC Tax News 7 October 2019).
This resulted in complaints from both individual companies as well as branch organizations, as they felt they would not have sufficient time to adjust their processes. As a result, the deadline was postponed until the 1st of April 2020 (see PwC Tax News 20 November 2019).
The postponement of these measures provides companies with some additional time to make any necessary adjustments to their supply chain.
We understand that companies currently may be engaged with many different adjustments due to the Covid19-crisis. However, it is important to not wait until the last moment to apply changes to your supply-chain, as this could mean that your company will no longer be able to export goods outside the EU.
We already have assisted several companies with successfully aligning their supply chain with the new exporter-definition. Should you also need any advice on this matter, please contact your regular Customs & International Trade contact at PwC, or reach out to Claudia Buysing Damsté or Jos Verstraten.
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