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REX declarations cause problems for importers

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REX declarations cause problems for importers

Expediteur Bangladesh
If you import from an APS country, such as Bangladesh, Indonesia or Vietnam, you are entitled to tariff preference via the REX system. It is important that the REX declaration on the invoice is 100% correct. Any errors may result in extra costs and more 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

 

For this reason, it is sensible to check the REX declaration thoroughly at all times. This will prevent problems.

 

1. Be careful when using an intermediary or agent

If you are buying products from an APS country through an intermediary or agent, make sure you check properly that the information on the invoice is complete and correct to 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 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 explanation on completing the information, please see the Official Journal of the European Union, dated 29/12/2015, Annex 22-07

 

The REX declaration must always be copied word for word, on the packing slip or the supplier declaration. He will then add the necessary information. It is used by the supplier to prove that the relevant goods meet the rules of origin.

 

Another frequent error relates to the REX number. The agent or intermediary often uses the supplier’s number on the invoice. However, this is not permitted. Only the producer of the goods is permitted to declare that these goods meet the rules of origin. The supplier may include the REX declaration on the packing slip or hand it over to the agent or intermediary as a separate appendix, as long as it contains a reference to this on the invoice.

 

2. Is the product processed or reworked?

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. This is now the supplier’s responsibility. 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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