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E.        Lodgement of the customs declarations and related data-collection issues

2.21.              Electronic declaration. A declaration can exist not only as a printed document but also in electronic form.  For example, many countries use electronic declarations for a significant proportion of imports.  Many developing countries use the Automated System for Customs Data (ASYCUDA), a computerized system developed by The United Nations Conference on Trade and Development (UNCTAD).[13]   The electronic declarations significantly facilitate the processing of data. 

2.22.              Statistical requirements. The data requirements of customs may not always fulfill all statistical needs. In particular, for most customs procedures, the RKC leaves it to national legislation to decide what customs records are to be kept, whether or not a goods declaration should be lodged and what information it should contain.  Compilers of trade statistics are advised to cooperate with customs to design such forms of customs records which, while not adding administrative or financial burden to customs and traders, contain all statistically significant data fields (see chap. VIII for details) and allow the collection of the data required for trade statistics. The statistical requirements should be addressed systematically with customs and included in a memorandum of understanding and should also be addressed in the joint work programme of customs and the agency responsible for compiling international trade statistics (see chap.V). In this connection, the statistical agencies could seek also greater access to such information as shipping manifests.

2.23.              Time of lodgement and time of data recording.  The RKC does not provide strict standards regarding the timing of lodgement.  It states only that national legislation should lay down a time limit for lodgement that will enable the declarant to assemble the particulars needed for making the declaration and to obtain the required supporting documents.[14]  Governments are free to select the beginning of the time limit, for examples, the time when goods are unloaded, presented at the customs office or released. It follows that the time of 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.  However, since the time of lodgement generally approximates that of  the crossing of the border of the economic territory of a country, it is recommended by IMTS 2010 to use the time of lodgement as the time of trade data recording in the case of customs-based systems of data collection (for further details regarding the time of recording, see chap.XII)

2.24.              Lodgement of provisional or incomplete declarations.  If the declarant, at the time of lodgement of the declaration, is unable to provide all the required information, the customs authorities may accept a provisional or incomplete declaration and release the goods under condition that the declarant will provide the missing information afterwards within the specified period in an additional declaration.[15] The time of lodgement of the additional declaration and the time when goods cross the border of the customs territory may be far apart. However, both declarations refer to the same transaction and must be linked during the data processing. Compilers are advised to use (a) the provisional or incomplete declaration to identify the time of lodgement and collect provisional data and (b) the additional declaration to revise or complete trade data without the time of recording changing.

2.25.               Release of the declaration after release of goods.  Compilers should take into account the use of a standing authority for release of goods before presentation of the declaration.  Such authority is given to a growing number of traders in order to enable speedy release of the imported or exported goods without waiting for collection of the documents needed for completion of the declaration.[16] Compilers should include the data from such declarations in the monthly statistical reports corresponding to the months when the goods actually enter or leave the economic territory of a country.

2.26.               Periodic lodgement of declaration.  When goods are imported or exported frequently by the same company or person, the RKC recommends that customs allow a single goods declaration to cover all importations or exportations by that person for a particular reference period.[17] That facilitation may be granted if the company or person keeps proper commercial records and if necessary control measures can be taken. The RKC recognizes the right of customs to require that the declarant produce, at the time the goods actually cross the border, a commercial or official document such as an invoice, waybill or dispatch note, etc., giving the main particulars of the concerned consignment.  Compilers should periodically review such documents, if permitted by law, in order to be able to assign the trade to the appropriate month (based on time of crossing the border), especially in cases when trade is significant in value (quantity) and/or the reference period of the reporting by the trader does not coincide with a period used for statistical reporting (normally the calendar month).

2.27.              Absence of declarations. In some cases, mostly when duties and taxes are not collected, national law may not require that declarations be lodged.  Compilers are encouraged to collect from the customs any information that may help to identify shipments of undeclared goods, and to use non-customs data sources, including estimation, to ensure proper coverage of the international merchandise trade statistics.

2.28.              Simplified declarations, customs and statistical thresholds and estimation. Certain goods that are not strictly controlled can be declared in less detail or made exempt from reporting requirements; this can also apply when the value or quantity is below a certain customs-defined or statistical threshold.[18] Compilers should be aware of those transactions and decide whether and how to include them in the trade statistics so as to prevent unwarranted loss of coverage.  If the value of the trade is considered significant it should be included in the statistics (see IMTS 2010, para. 1.3). Compilers should develop, in cooperation with the customs administration, adequate data-collection or estimation procedures for these transactions.  Those procedures may rely on the use of commercial documents available to the customs or may be based on appropriate non-customs sources of data.  Compilers may also establish a threshold for statistical purposes, i.e., set a value below which transactions might not be processed and included in the detailed international merchandise trade statistics, or included as an estimate based on a sampling approach or as an aggregate. Such an approach is useful where resources may not be sufficient to ensure processing of all the transactions on a timely basis.  However, in those cases, clear explanatory notes should be included in the metadata. For further information, see section E of chapter XIX, which discusses simplified declarations and reporting thresholds.

2.29.              Retention of customs records. National law usually requires that, for control purposes, copies of goods declarations, along with any supporting documentation, be kept for several years.[19] It is good practice for compilers to work together with customs in developing a retention policy for the documents that support statistical needs, including establishing an electronic database to facilitate storage, retrieval and processing of electronic copies of such documents.

[13]   ASYCUDA can be configured to suit the national characteristics of individual customs regimes. For further details, see chapter VIII of this Manual or visit the ASYCUDA website (http://www.asycuda. org).

[14]   See RKC, General Annex, Chapter 3, Standard 3.23.

[15]    Ibid., General Annex, Chapter 3, Standard 3.13 and the guidelines provided therin.

[16]    Ibid., Standard 3.25 and the guidelines provided therein.

[17]    Ibid., Transitional Standard 3.32, and the guidelines provided therein.

[18]    For example, in the United States, most import transactions valued at less than $1,500 may be reported “informally”, with only minimal information reported. See para. 19.17 for the explanation of customs and statistical threshold.

[19]    For example, in the United States, exporters or their agents must maintain copies of shipping documents for three years after exportation.