Customer notice, 24 June 2010

1 Is your company ready for the change?

We want to offer testing and guidance to our customers concerning the new message declaration format when necessary. Therefore, we ask you to read this customer notice and to make sure that your company has decided on or seen to the following matters:

• Will your company submit declarations to Finnish Customs itself or will you use an agent?
• If your company will use an agent, have you already entered into an agreement with one?
  
• If your company will submit declarations, will they be message format declarations or online declarations?
• If your company will submit message declarations, has it applied for authorisation for submitting message declarations?
  
• Has your company already obtained an EORI number?

2 New declarations of airline companies in Finland

Airline companies operating under transport contracts with Finnish airports (master air waybill) are to submit one of the following declarations for goods arriving from outside of Finland as of 1 January 2011 at the latest:

• entry summary declaration (for aircraft arriving from non-EU airports), or
  
• summary declaration for temporary storage (for aircraft arriving from EU airports).

In addition to these two alternative advance declarations, airline companies which undertake the transport of goods are to submit a manifest presentation for goods arriving at airports as of 1 January 2011 at the latest.

Fast freight companies and airlines operating in Finland as temporary warehouse keepers are to submit an unloading report for all goods warehoused on the basis of a manifest presentation as of 1 January 2011 at the latest.

Airline companies which undertake transports of goods from Finnish airports are to submit two new declarations for export goods exiting Finland as of 1 January 2010:

• exit manifest presentation
  
• exit notification.

3 What measures are required of airline companies?

• An airline company with the obligation to declare is to decide whether it will submit the declarations itself or use an agent.
  
• Declarants are to decide whether they will submit message format declarations (either through an operator or as direct messages) or online declarations.
  
• For online declarations, declarants are to obtain a Katso ID from the Finnish Tax Administration.
  
• Declarants who opt for message format declarations are to obtain an AREX EDI sender authorisation from Customs.
  
• Operators responsible for declarations and those submitting declarations are to agree with their cooperation partners as to how the declarant will be informed of the details on cargo and transport that are necessary for the declaration. The parties should also agree on how the declarant is to forward the reference numbers of submitted declarations to the other operators in the customs clearance chain.
  
• Both declarants and airline companies responsible for declarations are to make sure that they have registered with the EU-wide EORI database for declarants.

4 To be submitted as of 1 January 2011 at the latest: Advance entry summary declaration or summary declaration, arrival notification for aircraft

4.1 Entry summary declaration or summary declaration

When an aircraft arrives at a Finnish airport directly from outside the EU, the airline company which has entered into a transport contract is to submit an entry summary declaration for all goods onboard the aircraft.

When an aircraft arrives at a Finnish airport from another EU member state, the airline company which has entered into a transport contract is to submit a summary declaration for the goods to be unloaded at the airport. In EU legislation, this declaration is referred to as a summary declaration for temporary storage.

A summary declaration to be lodged in Finland or a subsequent customs declaration cannot refer to the MRN of the entry summary declaration that was lodged for the goods upon their first arrival in the EU at an airport in another EU member state. The only exception to this is the arrangement where goods are transported onboard the same aircraft for the whole of their journey and not unloaded at the first airport.

4.2 Details of goods are required for the entry summary declaration and summary declaration

One declaration can cover a maximum of 999 consignments. Each consignment must be specified either with a precise verbal description or by using commodity codes at the level of four digits. For example, the goods description “components” is not sufficient, but needs to be more accurate; the description should state transistors, graphics cards, motherboards etc. Also the quantity and packaging details of the goods are to be declared according to consignment. If a single declaration covers goods of several consignors or consignees, the consignor and consignee details must be provided according to consignment.

Other information to be submitted on the declaration concerns the transport and the operators involved in the transport chain.
When transporting piece goods, even hundreds of entry summary declarations or summary declarations may have to be submitted per aircraft, for example, according to house air waybill (HAWB).

4.3 Entry summary declaration or summary declaration to be submitted also for Community goods

For the purpose of customs clearance in Finland, a summary declaration must be lodged also for Community goods onboard an aircraft that arrives in Finland from an airport in another EU member state. A separate code can be used in the summary declaration to indicate the Community status of the goods. If the aircraft visits a non-EU airport after departure from another EU member state, an entry summary declaration must be lodged for all goods onboard the aircraft, including Community goods.

4.4 Arrival notification

The arrival notification indicates the actual arrival of the means of transport. In EU legislation, this declaration is referred to as the notification of arrival as of 16 April 2009.

When an aircraft arrives at a Finnish airport from outside the EU, the airline company which has undertaken the transport of goods is to submit an arrival notification in order to provide the reference numbers of the entry summary declarations (MRNs) of all goods onboard the aircraft, as well as the related consignment numbers. When an aircraft arrives at a Finnish airport from an EU member state, an arrival notification is to be submitted in order to provide the MRNs of the summary declarations of all the goods onboard the aircraft to be unloaded at the airport, as well as their consignment numbers.

The arrival notification is used also for conveying the identification data of the temporary warehouse into which the goods will be unloaded.

It should be noted that, if goods arriving from outside the EU are to be unloaded in Finland, an entry summary declaration submitted for such goods becomes a summary declaration required in customs clearance for temporary storage of goods once the arrival notification is accepted.

4.5 Diversion

A customer who submits an entry summary declaration must provide a so-called diversion request if the aircraft arrives first in such an EU member state which was not originally included as a country of routing in the entry summary declaration.

5 Exit manifest presentation and exit notification to be submitted as of 1 January 2011

5.1 Exit manifest presentation

An airline company which undertakes the transport of goods based on an exit manifest presentation is to declare, according to master air waybill, the reference numbers (MRNs) issued by Customs for the customs declarations of all export and re-export goods loaded onboard the aircraft at the airport.

As regards goods other than export or re-export goods to be loaded onboard an aircraft departing directly for non-EU territory, an exit manifest presentation is to be submitted in order to provide the reference number of the previous customs declaration (MRN). This can be the MRN of the transit procedure, of the exit summary declaration or, in the case of temporarily stored goods, of the (entry) summary declaration lodged for the goods upon their arrival.

The introduction of new exit declarations does not affect the procedure where Customs adds an EXPORT stamp to the air manifests of export goods departing for another EU member state under an air manifest transit during 2010. The procedure will, however, be no longer applied once the changes in customs legislation enter into force on 1 January 2011.

The customs office of exit for goods exiting Finland by air is always in Finland when the goods are under air manifest transit, required that the goods definitively exit the customs office of destination of the manifest transit.

In cases where goods to be exported by air are transported also by road, all new exit declarations are to be submitted in Finland when the goods are in a loading warehouse (exit manifest presentation and exit notification, and the preceding “Arrival at Exit” notification to be lodged for export goods). The procedure for air goods transported by road is applied when a part of the journey of goods due to exit Finland takes place by road, and the road transport falls under an air transport contract that expires outside the EU territory. The procedure is applied when the final exit of goods takes place by air and the transport of air freight is based on a master air waybill in its entirety, including road transports.

5.2 Times for issuing an exit manifest presentation

The exit manifest presentation must be lodged no later than on the working day following the departure of the aircraft. However, if the next destination of the aircraft is outside the EU and the situation involves goods for which an export or re-export declaration has not been submitted into the ELEX system of Finland, an exit manifest presentation must be provided for the goods already before the goods are loaded onboard the aircraft.

5.3 Exit notification

The submitter of the exit manifest presentation confirms the departure of the goods covered by it by submitting an exit notification. The exit notification can be submitted only after the aircraft has left the airport and Customs has accepted the exit manifest presentation. If the aircraft departs directly for non-EU territory, the notification must be submitted no later than on the second working day following the departure. If the aircraft departs for an EU airport, the exit notification must be submitted no later than on the third working day following the departure.

5.4 Airline companies can also submit an “Arrival at Exit” notification

The presentation of export goods at the customs office of exit takes place with three new electronic declarations in Finland. In addition to the exit manifest presentation and the exit notification, which are the responsibility of airline companies, Customs also requires an “Arrival at Exit” notification when the export goods arrive at the airport. The party ultimately responsible for the notification is the exporter. The notification can be lodged by the party responsible for loading or some other person. Customs replies to the “Arrival at Exit” notification by sending a loading permit. If an airline company wishes to submit the notification, it must send the loading permit to the party responsible for loading in order to keep the said party up to date. Submitting an “Arrival at Exit” notification is subject to authorisation. Under separate authorisation, the submitter of the export declaration can apply for a loading permit from Customs already upon lodging an export declaration instead of submitting an “Arrival at Exit” notification.

5.5 Exit summary declaration to be submitted in some cases as of 1 January 2011

As of the beginning of 2011, customers must submit an exit summary declaration to Customs if no other declaration containing security data has been submitted for the goods and if the aircraft departs directly for an airport outside the EU. Exit summary declarations will become obligatory simultaneously throughout the EU. An airline company may have to submit an exit summary declaration if no other operator has done so.

An exit summary declaration need not be submitted for goods exiting after a temporary storage period of no more than 14 days at the airport. In these cases, the exit manifest presentation is used to provide the reference number of the declaration presented for the goods upon their arrival (see 4.1 above).

6 Airlines required to prepare for data exchange with other operators

The airline and its possible agent who is to submit declarations are to make sure that the following matters are in order in good time:

• The company will receive the reference numbers (MRNs) of the declarations for export goods it has transported out of Finland from the operators responsible for loading or from submitters of export declarations.
  
• The company will receive the necessary information from the goods holder for declarations of arriving goods.
  
• The company will be able to forward the reference numbers (MRNs) of the entry summary declarations or summary declarations it is responsible for to the other operators in the customs clearance chain, namely to airport warehouse keepers and to parties responsible for post-warehousing customs clearance.
  
• The submitter of the export declaration and the airline responsible for the declaration have the EORI number required as obligatory declaration data. The number can be obtained through registration with the EORI database of EU customs declarants.

7 EORI database registration

If the company is a registered credit customer of Finnish Customs, it has been automatically registered into the EORI database by Customs. Customs has also registered the business ID of the company as the EORI number.

If the company is not yet in the EORI register, the registration should be done immediately. Companies registered in Finland apply for registration through Finnish Customs. Companies based in other EU member states carry out the registration in their own countries. Airline companies registered outside the EU can carry out the EORI registration in any EU member state. Further information on registration is available in Finnish at www.tulli.fi/fi/yrityksille/asiakkaana_tullissa/EORI/index.jsp.

An individual company is given only one EORI number which can be used in customs declarations in all EU member states.

8 New declarations can be submitted electronically either online or in EDI message format

8.1 Online declarations

Online declarations are free of charge and suitable for small numbers of declarations. Online declarations do not require a separate authorisation, but the online declarant is to log in to the Customs online service using the Katso ID issued by the Finnish Tax Administration. The Katso ID can be ordered free of charge from the Tax Administration. Instructions on submitting online declarations are available in Finnish at www.tulli.fi/fi/yrityksille/sahkoinenasiointi/internet/index.jsp.

8.2 Message-based transactions with Customs require authorisation

Message-based transactions require an AREX/EDI sender authorisation from Finnish Customs and acquiring adequate software which is to be tested with Customs. Message transactions can take place either through an operator or through direct contact with Customs. Companies that opt for message transactions are to apply for the authorisation as soon as possible in order to ensure testing, because after October 2010 Customs will not be able to test the systems of new message declarants until January 2011. Applicants should observe that once Customs receives an application for authorisation, it may take several weeks before the testing of message transactions can be started.

The application for the status of a direct message customer and the required enclosure forms are available in Finnish at www.tulli.fi/fi/yrityksille/sahkoinenasiointi/lomakkeet/suoran_sanoma_asioinnin_lomakkeet/index.jsp.

9 Message declarants are to archive messages related to transactions

Arrival and exit declarations do not entail any paper documents which can be archived. Therefore, message customers are to archive their electronically submitted declaration messages, reply messages from Customs, requests for further information and their replies to the requests.

10 Declarations can be submitted by an agent

When necessary, an airline company can employ an agent for submitting declarations which are the responsibility of the company. The responsibility for the content of the declarations remains with the airline company also when an agent is used. The use of an agent should be agreed on as soon as possible, so that the agents who offer services can have sufficient time to prepare for submitting new electronic declarations.

11 Additional information

Further information is available at the Finnish Customs website at www.tulli.fi. The decisions by the National Board of Customs (184/010/2009, 22/010/2010 and 23/010/2010) are available in Finnish at www.tulli.fi/fi/suomen_tulli/julkaisut_ja_esitteet/THT/index.jsp. The message descriptions of the new declarations, a general description of the AREX system and current customer notices and instructions on electronic transactions are also available in Finnish at www.tulli.fi/fi/yrityksille/sahkoinenasiointi/index.jsp.

For further information, please send e-mail to turvatiedot(at)tulli.fi.