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REX declarations cause problems for importers

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REX declarations cause problems for importers

Expediteur Bangladesh

Are you importing goods from an APS country, such as Bangladesh, Indonesia or Vietnam? If so, you are entitled to tariff preference via the REX system. It is important that the REX declaration in question is 100% correct. Any errors may result in extra costs and additional customs checks. What should you do to avoid problems?

 

Consequences of an incorrect REX declaration

The introduction of the REX system has simplified trade with APS countries. Suppliers who are registered exporters self-certificate the origin of goods on the so-called REX declaration. It is no longer necessary to use an external party for this.

 

However, completing the REX declaration is not always without issue. This could have unpleasant consequences for you:
  • You cannot make use of the tariff preference and are liable to pay import duties
  • More customs checks

Checks can take place even after the goods have been released. As such, it’s always a good idea to thoroughly check the REX declaration. This will prevent problems.

 

 

Common errors

If you are buying products from an APS country through an intermediary or agent, Make sure to thoroughly check if the REX declaration is complete and correct. That way, you can avoid problems at customs. We frequently see the following errors:

  • The REX declaration is missing
  • The supplier’s REX number is listed on the invoice issued by the agent or intermediary
  • The REX declaration is not signed by the supplier

 

The REX declaration is actually a standardised paragraph. Unfortunately, we frequently see this is missing from the invoice.

REX declaration text

The exporter … (Number of Registered Exporter (2), (3), (4)) of the products covered by this document declares that, except where otherwise clearly indicated, these products are of . . . preferential origin (5) according to rules of origin of the Generalized System of Preferences of the European Union and that the origin criterion met is … … (6).

*For more information on completing these data, please refer to the Official Journal of the European Union, dated 29/12/2015, Annex 22-07 (English) and Annex 22-07 (Dutch).

 

If the invoice is filled out by a broker or agent, they are not allowed to use the supplier’s REX number. Only the producer of the goods, i.e. the supplier, is permitted to declare that these goods meet the rules of origin.

 

Moreover, it is important that the supplier explicitly copies the REX statement above. This should be added to the packing list or as a separate statement on origin. In order to validate the REX declaration, the supplier always needs to sign it. That way, the supplier proves that the relevant goods meet the rules of origin. Note: if the REX declaration is added to the statement on origin, the agent or broker should refer to this in the invoice.

 

 

Be extra careful when it comes to processed goods

Goods are not always fully manufactured in one country. A good example is a shirt made in Bangladesh, with buttons from China. It is mandatory for the supplier to specify this on the REX declaration. This can be done at point (6):

  • If the item is produced entirely in one country, this is indicated by a “P”;
  • The letter “W” is used for processed or reworked products, followed by the first four letters of the HS code.

 

Prior to the implementation of the REX system, an external party was responsible for specifying the correct composition through the so-called A Form. Now, this is the responsibility of the suppliers. Things frequently go wrong, especially when listing processed or reworked goods. The first four letters of the HS code are often missing. Have you noticed this happening with your supplier? Discuss the matter with them.

 

 

Questions about the REX declaration

We advise that you always check the REX declaration to make sure it is complete and without errors. This way, you can prevent possible customs problems. If you have any questions about the REX declaration, please contact our customs declarants on 010-76 71 000.

 

 

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