INTRODUCTION
1. Singapore Customs is seeking public feedback on the implementation of the submission of export declarations prior to export, termed as Advance Export Declaration (AED). We invite you to contribute comments on the proposed amendments. Your feedback is important in helping us improve the implementation details to minimise the impact to trade.
SCOPE OF THE CONSULTATION EXERCISE
2. Under Singapore’s Regulation of Imports and Exports Regulations, an export declaration must be submitted to Customs prior to export of any type of goods. However, for non-controlled and non-dutiable goods that are exported by sea and air, an administrative facilitation was granted in 1976 to allow traders to submit the required export declaration within three days after export1.
3. On average, about half of the total export permits are currently submitted to Customs prior to the goods being exported, including exports of non-controlled and non-dutiable goods exported by sea or air. With implementation of AED, Singapore Customs will require all export declarations, including those currently exempted, to be submitted before export.
STRENGTHENING SINGAPORE'S SUPPLY CHAIN SECURITY
4. Trade security has become a key global agenda. In Singapore, maintaining the security of our supply chains is crucial as Singapore is a global transportation and trading hub and international trade is a key component of Singapore’s economy. As part of the global community, we also need to play our part in enhancing supply chain security and ensuring that Singapore maintains her reputation of being a secure and trusted trading hub.
5. In order to enhance supply chain security, Singapore Customs adopts risk management techniques. Such techniques require cargo information in advance to perform risk analysis to identify higher-risk cargoes for further action by Customs. Hence, there is a need to make AED a requirement for all categories of exports, so that data on exports are available to Customs prior to the consignments being exported.
6. Under the World Customs Organisation’s SAFE Framework of Standards to Secure and Facilitate Global Trade (WCO SAFE Framework), the Customs authorities of member countries are committed to facilitate the global movement of goods by enhancing greater “end-to-end” supply chain security in partnership with overseas Customs and private sector. The WCO SAFE Framework promulgates that Customs authorities require traders to submit advance information on exports to conduct risk assessment and inspection of high-risk cargo. Singapore signed the letter of intent to implement the WCO SAFE Framework in 2005.
7. In line with the WCO SAFE Framework, the Customs authorities of many countries have implemented AED or already had AED in place, for e.g. the US, the EU, Japan, China and Australia. Singapore’s current practice for export declarations is thus not in line with international norms.
BENEFITS OF AED
8. Companies and traders located in Singapore stand to benefit when Singapore is regarded by our key trading partners and global industry players as a safe and secure trading hub with sound supply chain security practices. Such a premium position would work in favour of our companies, which stand to enjoy more businesses from overseas customers because of greater confidence in our supply chain security. The proposed implementation of AED will strengthen our supply chain security and therefore help to give Singapore companies a competitive edge.
9. With AED in place, Singapore Customs also plans to conclude more mutual recognition arrangements (MRA) with the Customs administrations of key trading partners, who would recognise cargoes exported from Singapore to be of lower risk and hence facilitate the clearance of our exports at the point of import. Companies could enjoy greater predictability when exports reach the importing country and save on delays caused by import inspections.
IMPLEMENTATION DETAILS: FEEDBACK SOUGHT
10. Recognising that implementing AED would impact our trading community, an inter-agency taskforce comprising SC, the Ministry of Trade and Industry (MTI), the Ministry of Transport (MOT) and the Economic Development Board (EDB) had conducted formal industry consultations from April 2010 to Dec 2010.
11. We have received useful feedback from individual companies as well as key associations, such as the Singapore Shipping Association (SSA), Singapore Logistics Association (SLA), Singapore Aircargo Agents Association (SAAA), Singapore Manufacturers’ Federation (SMa), Conference of Asia Pacific Express Carriers (CAPEC), and Association of Small and Medium Enterprises (ASME). We are conducting this public consultation exercise to obtain further feedback.
12. Specifically, we propose the following procedures for AED of non-controlled and non-dutiable goods exported by air and sea2. Some of the suggestions received from companies during the earlier consultations have been incorporated.
a. What to declare: An export declaration would need to be submitted prior to export for risk assessment to take place. Some fields are allowed to be amended if certain conditions are met. To view the list of fields, click here.
b. Who to declare: As per current practice, the exporter or its declaring agent will be responsible for submitting the AED.
c. When to declare: In general, AEDs should be submitted as early as possible, e.g. before the goods are sent to the sea ports or the air cargo terminals. This would ensure sufficient time for Customs’ risk assessment so that low-risk cargoes would not be subject to unnecessary checks. To minimise disruption to cargo flow in the sea ports or the air cargo terminals, Singapore Customs would enlist the help of the port operators and the air cargo terminal operators to divert high-risk cargoes (as selected by Singapore Customs) for checking or scanning when the cargoes are delivered to the sea ports or air cargo terminals. As such, exporters or their declaring agents should submit the export declaration early and before the cargoes are delivered to the sea ports operators or the air cargo terminal operators. We are proposing that AED should be submitted as early as possible and not later than the following timelines:
Sea: 8 hours prior to vessel arrival3 . This is based on the latest gate-in time set by port operators.
Air: 1 hour prior to flight departure. This is based on the latest cut-off time set by ground handling agents.
d. How to declare: Via TradeNet® or ACCESS4
13. There will be an initial ‘no penalty’ phase of 18 months to help companies to adjust and comply with the requirements, and for Singapore Customs to monitor implementation.
PROVIDING YOUR FEEDBACK
14. We would appreciate your support to ensure that the consultation exercise is productive and successful. Respondents are requested to:
Identify yourself as well as the organisation/s you represent (including contact details) so that we may follow up to clarify any issues, if necessary;
Make your comments clear and concise;
Use the prescribed form provided to help us understand your feedback better; and
Focus your comments on how AED would impact your company, explaining your points with illustrations, examples or data as far as possible
15. The information contained in this webpage is released only for the purpose of consultation and should therefore not be used for individual or business decisions as it does not represent the final requirements. All comments received during the consultation exercise will be reviewed thoroughly and, if accepted, may be implemented with or without modifications.
PERIOD OF CONSULTATION
16. The public consultation on the implementation of AED is available from 15 March 2011 to 12 April 2011. Comments received after the closing date will not be considered as they will be too late for incorporation into the final recommendation. Queries may be directed to customs_aed@customs.gov.sg.
FEEDBACK CHANNEL
17. You can send us your comments, using the prescribed form, by:
email to customs_aed@customs.gov.sg; or
fax to 67755946; or
post to: Singapore Customs
55 Newton Road, #07-02
Revenue House
Singapore 307987
Attention: Head Trade Strategy & Security
SUMMARY OF RESPONSE
18. We will publish on this website a summary of the main comments we receive together with our responses by 30 June 2011. The summary will not disclose the identity of respondents, and will not address or acknowledge every comment received.
MORE INFORMATION
19. For your convenience, please click here to download more information on AED and supply chain security.
1The administrative exemption does not include strategic, controlled and dutiable goods as well as all goods exported by road and rail.
2For export of dutiable, strategic (Tier 1 permits) and other controlled goods, and exports by road and rail, the current procedures and requirements will remain unchanged.
3“Vessel arrival” in this context refers to “vessel berth”, which is defined as vessel parking at the berth.
4For the companies currently using ACCESS for submission of customs declarations.