Regulatory Compliance updates 10/21

October 12, 2021

China: China extends extra tariff exclusion against import US commodities

The Tariff Schedule Committee of China formally announce to extend the first batch of first and second groups again of extra tariff exclusion against import US commodities. The last exclusions were published in Tariff Schedule Committee announcement [2020] No. 8 and [2021] No.2 expired on Sep 16,2021. Adapted to the context, Tariff Schedule Committee has decided in accordance with procedures to extend the exclusion period for the above-mentioned commodities. As for the 81 items listed in the Annex, China will continue to suspend additional tariffs imposed in response to the US Section 301 Measures from Sep 17, 2021 to Apr 16,2022.

China GAC revised and officially released new Measures for AEO Credit Administration

China GAC promulgated new Measures for AEO Credit Administration (Decree No. 251 of the General Administration of Customs), which will come into force on November 1, 2021 and replace Measures of the Customs of the People's Republic of China on Enterprise Credit Administration promulgated by Decree No. 237 simultaneously. In the new Measures, the sorts of enterprise credit rating, management measures of AEO Advanced Certified Enterprise, credit cultivation and repair mechanism and other important contents are adjusted and improved:

The former "Advanced certified Enterprise", "General Certified Enterprise", "General Credit Enterprise" and "Trust-breaking Enterprise" will be upgraded to only three sorts in the new Measures that "Advanced Certified Enterprise" and "Trust-breaking enterprise" will be retained. Convenient or strict measures will be implemented respectively, and conventional customs management measures will be implemented uniformly for "other enterprises".

It is clearly stipulated that "The customs shall provide credit cultivation services to enterprises, help enterprises strengthen the awareness of honesty and law-abiding, and improve the level of integrity management.

To establish a relatively complete enterprise credit repair system for customs registration and archival filing: first, it is stipulated in the general provisions that "the Customs shall establish enterprise credit repair mechanism and provide credit repair to enterprises according to law";  Second, trust-breaking enterprises not included in the list of serious trust-breaking subjects can correct trust-breaking behaviors and eliminate adverse effects, and meet the corresponding conditions, can apply to the customs in writing for credit repair and submit relevant certification materials.  If the customs considers that the enterprise meets the conditions for credit repair after examination, it shall make a decision on approval of credit repair within 20 days from the date of receiving the enterprise's application for credit repair.  Third, if the trust-breaking enterprise has not had any trust-breaking incidents for two consecutive years, the customs shall make a decision on the credit repair of the trust-breaking enterprise.  Meanwhile, if a trust-breaking enterprise has been included in the list of serious trust-breaking subjects, it shall be removed from the list and notified to the relevant departments.

European Union: New customs codes for dual-use goods

A new dual-use regulation came into force on 9 September. This Regulation (EU) 2021/821 also means a change of document codes if you are making an export declaration for dual-use goods. Until 9 September, all dual-use goods were subject to the document code X002. This code has been replaced by new document codes. The new codes are linked to the various authorisations.

European Union: Safety and security requirements on imports and exports

From 1 July 2022, safety and security declarations will become due on goods being imported from the EU and other territories that did not require these before 1 January 2021 to Great Britain. This will reflect the existing model already in place for trade between Great Britain and countries outside the EU.

From 1 October 2021, safety and security declarations will become due on goods leaving Great Britain in vehicles, and for empty containers, pallets and vehicles moving to the EU under a transport contract. This will reflect the existing model already in place for Great Britain trade with countries outside the EU.

Safety and security requirements for goods moving from Great Britain to Northern Ireland are in place as of 1 January 2021 and are covered in the Northern Ireland section.

Safety and security declarations continue to be required for goods entering and leaving the UK from countries outside the EU.

The UK is committed to upholding the principles of the World Customs Organisation (WCO) SAFE framework. Any references to Great Britain within this document include the 3 island territories off the coast of Great Britain which are Crown Dependencies. These are:

  • the Isle of Man
  • the Bailiwick of Jersey
  • the Bailiwick of Guernsey (which includes Alderney and Sark)

EU e-commerce package

The EU’s e-commerce package will introduce changes from 1 July 2021 in respect of the movement of goods from Northern Ireland to the EU and imports of low value goods into the EU or Northern Ireland. The package also introduces new rules for supplies made through online marketplaces, similar to those already applying in Great Britain and partly in Northern Ireland. For more information, please click here

Japan: Entry into force of Customs Mutual Assistance Agreement (CMAA) between Japan and the Oriental Republic of Uruguay

The Contracting Parties shall assist each other through their Customs Administrations to ensure proper application of Customs laws, and to prevent, investigate and repress any Customs offence, in accordance with the provisions of this Agreement.  The Contracting Parties shall through their Customs Administrations make cooperative efforts for simplification and harmonisation of their customs procedures. This Agreement shall be implemented by the Contracting Parties in accordance with the laws and regulations in force in each country, and within the competence and available resources of their respective Customs Administrations. The provisions of this Agreement shall not affect the rights and obligations of the Contracting Parties under any other international agreements.

Turkey Introduces New Amendments to Customs Regulations

Turkish Ministry of Trade amended the Customs Regulation (“Regulation“). The amendments to the Regulation introduced a simplified procedure of “permitted consignor authorization” for transit regimes and clarified the scope of the crimes relevant persons must not have a final conviction of to open a temporary storage site or a bonded warehouse. The Ministry of Trade also regulated the transition process regarding permitted consignor authorization and site authorizations granted prior to the subject amendment within the scope of the Regulation on Facilitation of Customs Procedures. As part of the Communiqué on Import Quota And Tariff Quota Administration dated September 11, 2021 (“Communique“), the Ministry of Trade introduced tariff quotas as an exemption from the additional financial obligation which is applied as a protective measure within the scope of the Decision on the Implementation of Safeguard Measures for the Import of Polyester Fibre (“Decision“). The Decision was put into effect with the President’s Decision No. 4412 dated August 23, 2021 for the import of goods with the HS code 5503. As per the Communiqué, tariff quota can be requested via electronic signature under the “Import Transactions” section on the website of the Ministry of Trade. Tariff quotas will be granted based on the first come, first served basis.

United Kingdom: Financial sanctions, Iraq

The Iraq (Sanctions) (EU Exit) Regulations 2020 ensure sanctions for Iraq are implemented effectively after the UK leaves the EU. The Iraq (Sanctions) (EU Exit) Regulations 2020 put in place sanctions measures to ensure the UK continues to meet its obligations under United Nations Security Council Resolution 661 (1990) and 1483 (2003). Resolutions 661 and 1483 established a sanctions regime relating to Iraq, under which certain measures are imposed upon those named on the UN’s Iraq Sanctions List.

The UK sanctions list

New UK sanctions regimes came fully into force under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act) at 11pm on 31 December 2020. The regulations establishing these regimes apply in the whole of the UK, including in Northern Ireland. Some of these regimes contain sanctions measures (for instance asset-freezes or travel bans) which apply in respect of persons or ships which have been designated or specified. The UK government publishes the UK sanctions list, which provides details of those designated under regulations made under the Sanctions Act. The list also details which sanctions measures apply to these persons or ships, and in the case of UK designations, provides a statement of reasons for the designation. HM Treasury’s Office for Financial Sanctions Implementation provides a consolidated list of persons and organisations under financial sanctions, including those under the Sanctions Act and other UK legislation.

United Kingdom: Transiting animals and animal products through Great Britain

Rules to follow if you’re moving animals or animal products from one third country to another third country and transiting Great Britain (England, Scotland and Wales), known as ‘landbridge’ movements. Requirements for animals or animal products moving between EU countries or Northern Ireland and transiting Great Britain are being introduced in 3 stages:

  • January 2021
  • January 2022
  • July 2022 onwards

Products of animal origin (POAO) are animal products for human consumption. Animal by-products (ABP) are not for human consumption.


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