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12.2.        Time of recording. The time of recording is defined in IMTS 2010 (para. 1.8), as the time when goods enter or leave the economic territory of a country. In general, it is sufficient to identify the day when the goods physically cross the boundary of economic territory. This day is to be used to allocate a given flow of goods to the shortest reference period for which official trade statistics are compiled. For example, if certain goods entered the economic territory of a country on 1 January and in this country the shortest reference period for trade data compilation is a month, then those goods should be included in January imports irrespective of when these statistics will be officially published.  The country practices in the implementation of this general guideline vary to some extent, depending on the availability of relevant data sources and other circumstances. 

12.3.        Use of different data sources. Customs records are the main source for determining time of recording. However, the economic territory in many cases does not coincide with the customs territory and some cross-border movements of goods are not sufficiently reflected in customs records. Therefore, it is a good practice (a) to use both customs and non-customs sources of information and (b) to develop sound approximation techniques for the cases where no reliable data exist and to consistently apply such techniques to ensure maximum possible data comparability. 

12.4.        Customs as data source: lodgement of customs declaration and date of lodgement. IMTS 2010 states that in the case of customs-based data-collection systems the time of recording can be frequently approximated by the date of lodgement of the customs declaration. Compilers should be aware that the revised Kyoto Convention (RKC) does not define the term “lodgement of customs declaration” and does not prescribe the rules regarding the determination of the date of lodgement. However, from the context of the Convention, it is understood that the date of lodgement is the date when customs registers[1] (or accepts) the declaration for processing, taking into account that certain customs requirements were satisfied.[2] 

12.5.        Requirements for lodgement of the customs declaration. The customs requirements for lodgement of the customs declaration include provision that customs “shall limit the data required in the Goods declaration to only such particulars as are deemed necessary for the assessment and collection of duties and taxes, the compilation of statistics and the application of Customs law” (General Annex, Chapter 3, Standard 3.12). Further, according to the Convention: “Where, for reasons deemed valid by the Customs, the declarant does not have all the information required to make the Goods declaration, a provisional or incomplete Goods declaration shall be allowed to be lodged, provided that it contains the particulars deemed necessary by the Customs and that the declarant undertakes to complete it within a specified period” (ibid., Standard 3.13). Moreover: “Where national legislation lays down a time limit for lodging the Goods declaration, the time allowed shall be sufficient to enable the declarant to complete the Goods declaration and to obtain the supporting documents required” (ibid., Standard 3.23). Further: “National legislation shall make provision for the lodging and registering or checking of the Goods declaration and supporting documents prior to the arrival of the goods” (ibid., Standard 3.25). 

12.6.        Use of time of lodgement. In view of the above provisions, compilers should be aware that the date of lodgement may not be appropriate in all cases for determining the time of recording. The lodgement of the declaration and the actual time when goods cross the border of the economic territory of a country may, in some cases, vary significantly. Therefore, it is good practice for trade statistics compilers to consult with national customs authorities about the rules that define the date of lodgement and assess in which cases it can serve as an acceptable approximation of the time of recording and when it should be replaced with a more appropriate date. As practices and terminology vary across countries, some countries might use the date of release from customs, the date of assessment or the date of acceptance by customs, instead of the date of lodgement, for determining the time of recording. This might be appropriate if any of those dates reflect an appropriate approximation of when goods enter or leave the economic territory. 

12.7.        Use of non-customs sources. It is good practice for non-customs sources to be used only in cases where customs records do not exist or the date of lodgement significantly deviates from the moment when goods physically cross the boundary of the economic territory of a country. 

12.8.        Use of estimates. In a number of cases, the time of cross-border movement of goods is not reflected in any data source. In such cases, development of sound approximation techniques becomes a necessity in order to ensure a better temporal data comparability. 

12.9.        Metadata on sources and rules used for establishing time of recording. The determination of which data sources and rules should be used while establishing the time of recording, so as to ensure both compliance with the international recommendations and high- quality national data, is the responsibility of the national compiling agency. It is good practice to develop clear and practical rules to ensure (a) that the time that will be used for the purposes of time of recording is the closest possible approximation of the time when goods actually enter/leave the economic territory of the country and (b) that reliable methods of establishing such a date are established and consistently applied. The description of the selected sources and rules should be part of the country’s trade metadata.

 


[1] The terms “register” and “registered” are used in several RKC standards, for example, standards 3.26 and 3.30, respectively.

[2] See IMTS 2010, para. 2.22.