The European Union (EU) continues to be very active in promulgating legislation to support its drive to create a single customs union for its 27 member states. The latest in a long line of supply chain security legislation is the introduction of the Import Control System (ICS), which requires the provision of advanced shipment information to Customs authorities.

Similar to the US 10+2 (CTPAT) supply chain security initiative, ICS aims to communicate critical shipment data to customs before the shipment reaches the EU, and thereby enable their ability to assess any risks it may pose. With effect from 1st January 2011, ICS places the burden of supplying advanced shipment information squarely on the shoulders of carriers, not industry. However, importers and exporters are not completely off the hook; they must provide accurate information on a timely basis to their carriers, or goods could be held up indefinitely by customs authorities.

Import Control System background
ICS is included in European Parliament and Council Regulation (EC) No. 648/2005, the safety and security amendment to the Customs Code, and Commission Implementation Regulation No 1875/2006. Originally, ICS was to be introduced across the EU on 1st July 2009; however, it was recognised that this date was not achievable for a number of EU member states. The Commission and member states then agreed to a final transition deadline of 1st January 2011. As of this date, it has become mandatory for carriers to electronically provide EU Customs authorities with advance information on shipments that are either in transit through the EU, or destined for a member state. Therefore any shipment that enters the EU is subject to ICS regulatory security checks and profiling.

The recent security alerts at airports and ports have only reinforced the need for Customs to be more vigilant with imported goods.

Although related, ICS is different from the Authorised Economic Operator (AEO) supply chain security program promulgated by the same EU regulations. AEO is an accreditation regime aimed at improving global security by attempting to certify the cross-border actions of businesses and their trading partners. Whereas AEO is a certification program, ICS is a transactional program requiring up to 30 data elements for EU Customs filings on each and every shipment, much like the 10+2 program in the United States, which requires the advance filing of 12 data elements (10 from the Importer of Record and 2 from the carrier) prior to goods being loaded on a carrier at the point of origin.

The intention of ICS and 10+2 is the same - securing the supply chain by evaluating shipments prior to arrival.

Impact on the Automotive Industry
The new requirements will affect every shipment of automotive parts, assemblies and other related goods coming into European plants. The responsibility to submit the data to Customs falls on the shoulders of the carriers and LSPs, but the suppliers from where the goods originate must provide them with the accurate information in the first instance. And it is not just the component suppliers who need to be involved. Many vehicle manufacturers are also importing goods themselves into Europe, or to other OEMs with whom they collaborate. If they do not receive the items on time, the production lines will be seriously affected and emergency transport costs could also be incurred, which makes it vital that Odette plays a part in ensuring the data communications are as effective as possible.

ICS requirements
The pre-arrival information needs to be provided to Customs authorities in a specified electronic format at the first point of entry into the European Union (EU). The electronic declaration is known as an Entry Summary Declaration (ENS), which includes:

• Details that identify the cargo such as unique consignment reference, container numbers, seal numbers, goods description, shipping marks and commodity codes;
• Traders involved in the movement such as the consignor, consignee, carrier, person filing or lodging the ENS;
• Identification of consignee and AEO status;
• Specific route into, across and out of the EU, as applicable to the transaction.

The ENS declaration is required for ALL shipments, including those en route via the EU to a destination outside of the EU, with only a few specific exemptions.
It is likely that not all 30 different data items will be needed in every case because all of the 27 EU member states will have different demands, just to make things more challenging.

What is Odette doing?
Odette is bringing the industry players together in a project which will ensure that the relevant data is exchanged as seamlessly as possible between all the partners and their Logistics Service Providers. It will involve the development of a comprehensive process description for the flow of information in the different business scenarios and the definition of a harmonised communication interface (using EDIFACT or XML messages) between automotive industry companies and LSPs.

The project is supported by national groups working in GALIA, the VDA and Odette Sweden, along with their local Customs authorities.

If you are interested to know more please contact info@odette.org