Import Entries & Risk Assessment NOT GOVERNMENT POLICY Import Entry - Status Quo Risk assessment information contained within import entries not uniformly received ahead of goods arrival Risk exists regarding movement of un-cleared goods from ports Duties and charges fall due on submission of an import entry – this may be driving late lodgement due to cash flow concerns Proposed Change – Option One Require import entries (containing necessary risk assessment information) to be submitted before or on arrival of goods Requires provisional revenue confirmation to be submitted ahead of arrival Allow adjustments to value to be made where necessary (see ‘declaring and adjusting value’ A3) Proposed that duties and charges are to remain payable within 20 working days of goods arrival Pros Risk assessment information contained on an entry will be received for analysis before goods physically arrive in New Zealand allowing Customs to assess risk Lower compliance costs relating to CCAs Small impact on FCL imports according to data analysis Cons Potential compliance difficulties for LCL and Airfreight due to complex information chain and timing issues Implementation considerations TSW/JBMS feasibility work required Option may be phased in over time Analysis must be undertaken with respect to the management of non-compliance (admin penalties) Further industry consultation required Problem Definition Customs requires certain import entry information for cargo risk assessment purposes Currently import entries may be lodged up to 20 days after goods arrive in New Zealand Import entries confirm liability for duties and charges which become payable following submission of entry The current 20 working day timeframe creates border security risk for Customs as the provision of risk assessment information is delayed Customs’ Risk Assessment Approach Timing Principle Advanced knowledge of domestic and overseas goods, people, and craft entering and exiting New Zealand enables risk to be assessed and legitimate trade and travel to be facilitated efficiently Technology and Data Principle Risk assessment processes must be driven by advanced data analysis and the application of technological solutions Compliance Approach Customs makes compliance easy to do and hard to avoid. Customs provides high assurance with a light touch Objective Import entries contain information integral to Customs’ cargo risk assessment process. Our objective is to ensure that required data is supplied within a timeframe that allows for its most effective use. Feedback from submitters Changes must be balanced against operational impacts on importers (especially with respect to cash flow) Further consultation with industry required 1. Results of internal data analysis of 68, 922 air import entries lodged between 1/04/2014 and 30/04/ Results of internal data analysis of 56,268 sea cargo import entries lodged between 1/04/2015 and 30/04/2015. Proposed Options for Change Proposed Change - Option two Require import entries (containing required risk assessment information to be submitted within hours of arrival Require provisional revenue confirmation to be submitted within hours of arrival Allow adjustments to value to be made where necessary (see ‘declaring and adjusting value’ A3) Proposed that duties and charges to remain payable within 20 working days days of goods arrival Pros Risk assessment information on an import entry received earlier than present Smaller impact on LCL and Airfreight according to data analysis. Compliance Cons Risk assessment information will not be received for analysis before goods hit the border introducing a risk element Proposed that duties and charges remain payable 20 working days after arrival. Ability to adjust value where necessary (see ‘declaring and adjusting value’ A3) Time Border Option One: Import Entry submitted before or on arrival 83.25% of import entries for sea cargo lodged before or on arrival. 88.9% of import entries for sea cargo lodged within 24hrs of arrival ² % of import entries for sea cargo lodged before or on arrival. 88.9% of import entries for sea cargo lodged within 24hrs of arrival ² % of import entries for air cargo lodged before or on arrival ¹ Status Quo: Import Entry submitted (up to 20 working days after goods arrival) Option Two: Import Entry submitted hours after arrival. Goods cleared. Goods removed from port System A3 Number 5 Status Quo: Customs permit for removal of goods (to CCAs) lodged OR delivery order lodged if import entry submitted and goods cleared. Goods released NOT GOVERNMENT POLICY