European Association Automotive Suppliers

The European Association for Automotive Suppliers (CLEPA) fully supports the European Commission Proposal for Regulation COM(2023)258, concerning the Revision of the Union Customs Code. We recognise the reform’s potential to facilitate trade, reduce costs and improve market surveillance through enhanced risk management. CLEPA supports the main features of the proposal:  EU customs data hub  Trust and Check  EU Customs Authority CLEPA represents over 3,000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over €30 billion yearly in research and development. Automotive suppliers in Europe employ directly 1.7 million people across the EU. Centralisation should target in particular the areas of tariff classification, customs valuation, origin declaration, IT interface.

…should target in particular the areas of tariff classification, customs valuation, origin declaration, IT interface. A central repository of all EU and member state measures, including import and export restrictions, quota and duty suspension. However, it will be crucial that a duplication of efforts by member states and Commission will be avoided. The EU Customs Data Hub could lead to harmonised interfaces and would benefit automotive suppliers operating across multiple countries and relying on a dense network of suppliers across the EU and abroad. The EU Customs Authority will play a central role in ensuring a more harmonised implementation of customs procedures across member states. So far, harmonisation has been limited to a couple of areas (decisions, authorization and valuation) and data exchange and alignment between national customs authorities falls short of what’s needed.

…and valuation) and data exchange and alignment between national customs authorities falls short of what’s needed. Regulation will impose further pressure on customs authorities (e.g., CBAM, (deforestation) due diligence requirements). The ambition for Trust and Check Traders to release their goods into circulation into the EU without any active customs intervention at all sounds promising. Benefits to the T&C should be proportionate to investments done to be part of the scheme, which is not always the case for the existing AEO scheme. The ability of non-EU manufacturers to comply with the data requirements in the EU Customs Data Hub will be another challenge. In sum, CLEPA supports the reform and is convinced that economic benefits will outweigh initial investment costs in IT and coordination of efforts among member states.

…that economic benefits will outweigh initial investment costs in IT and coordination of efforts among member states. The European Commission should ensure that mutual recognition of AEO schemes with third countries are maintained, including the UK, US and Japan. Reform efforts should be coordinated, where possible, with key trade partners such as the UK and PEM Convention partners. Ref. Ares(2023)5323275 - 01/08/2023

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