Dutch Customs, like many other customs authorities in the Customs Union, is undergoing some system changes. The move from AGS to DMS 4.0 is in full swing, shifting traders from the old AGS system to a new, UCC-compliant system built on a standardised data model.
Furthermore, the geautomatiseerde periodieke aangifte, or automated periodic supplementary declaration (GPA) is being phased out. The GPA system allowed traders to use EiDR by means of a non-digitalised system that is no longer compliant with the UCC. The UCC requires a digitalised system to be used along with real-time monitoring, so Dutch Customs had to come up with a solution. This is done by means of the introduction of DMS 4.1.
In DMS 4.1, traders will still have the possibility to register EiDR declarations, albeit not completely in the same way. The process has become more real-time rather than extracting data once a month from the WMS or ERP system, allowing for more transparency and compliance.
For one type of new flow, the ‘ketenregeling’, or chain arrangement in English, a question still had to be answered in regard to transparency and compliance. This flow allows for goods to only be presented once in a chain of customs procedures, meaning that keeping track of the goods could become more problematic. In order to solve this issue and still have a proper audit trail, the auditfile was introduced.
Finally, Dutch Customs also came up with a solution to fix the sophisticated reporting files that differ per Customs office. With one file and one standard, the reporting will look the same throughout the Union.
What is the Auditfile Voorraadverloop?
The auditfile is a standardised dataset filled with data from the company’s recordkeeping. It could come from any kind of ERP or WMS system. The dataset must be provided when Customs requests it. This can be either periodically or at any given time when Customs would like to carry out an audit. The big advantage is that a standardised dataset allows for standardised analyses when auditing the files.
In total, the auditfile consists of two base modules and 22 separate tables, each table containing information about the goods in the warehouse. Elements such as the owner of the goods, quantity moved in or out of the warehouse, and the type of goods are included.
The auditfile, in itself, is only mandatory for users of the chain arrangement procedure at the moment, but Customs strongly recommends anyone to consider it. The auditfile is applicable to both Union and non-Union goods. Simply put, as soon as the 'ketenregeling' is used, all movements must be tracked in one single file.
When a company migrates to using the 'ketenregeling', they have 6 months to implement the auditfile, but during those 6 months, they still must be ‘in control’. This means that they must ensure that there is proper recordkeeping for the goods that move into and go out of the 'ketenregeling', and afterwards, that they are seamlessly integrated from their ‘old’ into their ‘new’ administration.
What is the purpose of the auditfile?
The auditfile is being introduced so there is a generic framework that is the same for all warehouse owners. In this way, based on the 22 similar tables, Customs would be able to perform audits that are quick and efficient. Having standards allows for automated controls for Customs and for traders or software providers. It gives certainty for all stakeholders on what is expected to be delivered. It is noteworthy that the concept of the auditfile and the required data itself are not described as such in the UCC or Dutch legislation. Dutch Customs interpreted the UCC in such a way that the legal provisions allow Customs to ask for extensive data in the context of controls.
The Netherlands: Piloting the standard data model
The standard model includes two modules with a total of 18 tables coming from ISO Standard 21378:2019, one base module and one inventory module. On top of that, Dutch Customs added four tables specifically for customs purposes. These are also placed under the two modules. As the name suggests, the base module includes basic information that is always available in an ERP or WMS system, such as the name of the user, customer, supplier, and other information. In the end, this should give the possibility to identify the entries. The inventory module contains the information about what is in stock, including the quantity, type of product, when the goods moved in or out, and some other necessary information.
The auditfile sets a precedent in reporting and the Netherlands is the first country to pilot this kind of standardisation. The reporting may be an important step into the direction of self-assessment for companies and it gives an easy platform for Customs to perform audits. This Netherlands pilot is currently admired by the EU and the WCO, and they are monitoring closely how this model turns out and will potentially implement the same standards if proven successful.
How can you benefit as a trader?
Making use of an ISO-standardised reporting could benefit you as a trader, even when you are not making use of the ketenregeling’. The reporting is based on international standards and could, in the future, become applicable across the Customs Union. Furthermore, in general, standardisation brings about other benefits, such as:
- Consistency in data, diminishing the risk of errors and allowing for inconsistencies to be noticed quicker
- Compliance with customs regulations
- Transparency into the processes being reported on
- Data analysis comes into reach for warehouses. The standarised data model format can easily be interpreted by a BI tool.
- Reporting requirements are clear and no unexpected requirements can pop up when being audited by Customs.
The introduction of the auditfile fits into the broader topic of becoming more and more in control of your trade and customs compliance data. The Border Target Operating Model and the modernisation of the UCC built a large part of their models on reporting and being in control of data. If you would like to know more about these topics, check out our whitepaper and blog post and keep an eye out for our newest whitepaper on customs control towers!