INDUSTRIA DE DISEÑO TEXTIL, S.A.

Inditex’s contribution: “Public Consultation : Revision of the Union Customs Code ” Inditex, a leading company in the textile sector, presents its contributions and recommendations for the revision of the Union Customs Code (UCC) with the aim of improving the protection of the EU Single Market and facilitating trade. The main recommendations focus on three key areas: Trust and Check Traders, the EU Customs Data Hub, and improvements in determining the origin of goods.

…three key areas: Trust and Check Traders, the EU Customs Data Hub, and improvements in determining the origin of goods. 1. Trust and Check Traders:Inditex supports the simplification and facilitation of trade for current Authori sed Economic Operators (AEO) and new Trust and Check (T&C) traders. We recommend a harmoni sed implementation of the T&C program across all EU M ember States, avoiding fragmentation of the S ingle M arket and discrepancies at national level. Inditex emphasi ses the need for real and effective simplifications and trade facilitation , including self - assessments, acknowledgment of “importer’s knowledge” mechanism for claiming preference, and a fully electronic customs environment. We also propose a proportional, risk -based approach to establish differentiated benefits for each operator based on their realities.We endorse that the T&C trader scheme should be put…

AEO should be implemented in advance. A smooth transition from existing AEO holders to T&C traders should be regulated. 2. EU Customs Data Hub:Inditex suggests creating an optimi sed data framework with limited, standardi sed, interoperable, smart, and high -quality data. The EU Customs Data Hub should foster cross -border and cross - sector al interoperability in Europe, ensuring data quality and standardi sation. Instead of gathering a broad amount of data, it is preferable to use purposeful and verified data.

…standardi sation. Instead of gathering a broad amount of data, it is preferable to use purposeful and verified data. Inditex also emphasi ses the need for alignment and coherence with other EU leg islation , particularly with regards to various databases being developed under various European legislative initiativesincluding the Digital Product Passport, databases for the Corporate Sustainability Due Diligence Directive and the Textile Label ling R egulation , and any other new database envisaged in upcoming regulatory proposal s . In this context , we ask for close cooperation among st authorities from the beginning and suggest the participation of DG C NECT in those projects to ensure efficient technical coordination of these proposals.

…suggest the participation of DG C NECT in those projects to ensure efficient technical coordination of these proposals. To ensure data stored in the Customs Data Hub is secure and protected from unauthori s ed access, access rights should be allocated on a need - to -know basis, and only to specific authorities and for specific purposes. Inditex advocates for a progressive, structured implementation of the Data Hub with intermediate improvement milestones that w ould lead to the successful and timely functionality of the hub.A smooth transition phase to the EU Data Hub should be guaranteed through a well -coordinated and programmed transition. Some existing national IT structures are of high quality , advanced and with proven success , so the use of such systems as the starting point would be beneficial for efficiency and cost savings for the new EU Data Hub.

…use of such systems as the starting point would be beneficial for efficiency and cost savings for the new EU Data Hub. Efficiencies achieved over years of collaboration between operators and national customs authorities must be safeguarded. Ref. Ares(2023)7555548 - 07/11/2023 This remarkable relevant transition phase will require investment in infrastructure and technology, as well as seeking regular feedback from EU operators and national customs authorities, including the possibility of carrying out pilot testing with economic operators.

…and national customs authorities, including the possibility of carrying out pilot testing with economic operators. 3. Improvements in determining the origin of goods:Inditex proposes including importer -based certification procedures as an effective alternative to certificates of origin and statements from exporters or suppliers to prove the originating status of goods. The Digital Product Passport (DPP) could be utili sed as an efficient mechanism to leverage the po tential of applying the “importer’s knowledge” concept.Additionally, Inditex suggests connecting EU C hambers of Commerce to the Customs Data Hub to simplify and streamline the issuance of origin certificates for exports from outside the EU. Beyond these recommendations, Inditex also advocates for increased coordination and harmoni s ation within the international trade framework, cooperation with businesses and EU M ember…

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