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CONFIAD - Confédération Internationale des Agents en Douane

CONFIAD

The CONFIAD Pan European Network (Confédération des Agents en Douane), International Federation of Customs Brokers and Customs Representatives, was founded in 1982 as organization of the European Customs Brokers, with the purpose to defend and coordinate the professional interests of its members, supporting a harmonization of the legislative, professional and customs regulations at European level.

Lobbying Activity

Response to Revision of the Union Customs Code

23 Oct 2023

CONFIAD welcomes the efforts of the European Commission to modernize the Union Customs Code with the ultimate goal of making procedures simpler and more efficient. CONFIAD also welcomes the establishment of the EU Customs Authority, which should ensure the uniform application and interpretation of the EUs customs law. Nevertheless, there are concerns in relation to the status of Trust and Check Trader, which, if implemented as it is now, will not be only negative for the customs agents profession, but will put at risk its existence. The key elements of the UCC reform proposal are further discussed in the position paper.
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Response to The reporting obligations during the transitional period of the carbon border adjustment mechanism.

11 Jul 2023

CONFIAD generally supports the efforts of the European Commission to respect environmental protection and meet the green agenda objectives. CONFIAD nevertheless would like to submit the following observations to be taken into account in the preparation of the final text of the Implementing Regulation: - There seems to be pressure to put into force reporting obligations as early as from October 2023, however the preparatory period is too short to adapt to complex reporting requirements. One of the solutions is to postpone the implementation of reporting obligation for one year until October 2024. In the meantime, the European Commission should intensify its efforts in cooperation with non-EU and EU businesses, as well as third counties, to ensure proper understanding of the EU requirements; invest in projects supporting the proper reporting and recording of carbon emissions, which also contribute to the reduction of carbon emissions; build capabilities of partners, especially outside EU, in meeting green transition goals. - Ensure that when reporting declarants, including customs representatives, face difficulties in meeting the CBAM obligations, for instance when they cannot obtain data from the operator of installation or data may not be verified or subsequently turned out to be incorrect, they are provided with adequate assistance from the Commission. - Ensure that the customs representative profession is not put at risk by imposing an additional CBAM obligation. It should not turn into burden in case it is not possible to meet the requirements under CBAM regime, thus depriving customs representatives, especially those who are SMEs, from having a possibility to work in CBAM-affected sectors. The so-called de facto exclusion is not acceptable. Ensure that data provided by the operator/manufacturer of a third country is certified by an accredited body at the European level, which checks its truthfulness during the inspection and validation phase. - Ensure simplifications for reporting declarants who are SMEs, especially for those who cannot verify data received from third countries. - It should be specified in the Implementing Regulation that if the indirect customs representatives find out after agreeing to carry out reporting obligations that the importer supplied incorrect or incomplete information, they may refuse at any time to carry out these reporting obligations of the importer under Implementing Regulation. - The draft Implementing Regulation provides for penalties for incomplete or incorrect CBAM reports and failure to submit a CBAM report in the form of a fine from 10 to 50 EUR per tonne of unreported embedded emissions. There should be no fines in the transition period, let alone retroactive review of declarations submitted during the transition period which may potentially lead to financial penalties. - In the alternative, there should be no fines in CBAM reports submitted in 2024, whereas for reports submitted in 2025 a fine may be established at the level of 5 to 10 EUR per tonne. - The European Commission should present the default values as soon as possible. - The European Commission should ensure that transitional period is a genuine transitional period rather than hidden sanctioning for not fulfilling CBAM obligations. Thus, the transitional period should genuinely serve as a pilot and learning period for all stakeholders (importers, producers and authorities).
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