Douane Export Special DOC

Export Customs Customer Sales Service

START

Introduction

Customs wordings / Pilars

An Arkema Customs network : Why ?

Why do we Issue special documents ?

Handling of Samples and returns of goods

Follow-up of the customs clearances

QUIZZ

INTRODUCTION

Customs

Outside : Third countries.

Customs territory of the Union

27

members

Switzerland + UK + Norway

Physical movement of goods that crosses the border of the European Union (EU).

Customs

Import

Export

Vocabulary / Customs Wording

EORI

A status : AEO – full

• = FR319 632 790 00857 = Arkema France.

• Unique/SINGLE customs identification number, compulsory since January 1, 2017 in the EU for import and export formalities.

Authorized Economic Operator from March 2020

• Confidence and reliability label
• Quality Label for Customs, Safety & Security

REX

• = FRREX20170421 du 30/SEPT/2020 :

Allows to mention the European preferential origin on the commercial documents

Stakes :

• Complex customs regulations
• Customs duties
• Authorized Customs Representives

EA

Risks:

• Adjustment by the customs authorities : on past 3 years
• Heavy penalties / customs offenses
• Loss of the AEO status

• = FR003410/0114

Allows to mention the European preferential origin on the commercial documents

Customs wording : 3 pilars

Customs Classification

Origin

• HS CODE / Tariff(perimeter : Classification analyst)

Community status

Non preferential = Made in

• ATR

• LTD made in
• COO

Preferential = Free trade agreement

• REX/DOF/EUR1/ Standard LTD

Value

• Of the products

The Customs network :

CORPORATE SUPPLY CHAIN

CORPORATE CUSTOMS DEPARTMENT customs@arkema.com

BU Customs Representatives :

Purchasing customs representatives : DAMPE / GASP

Data Management Origin : Hélène LEBON

Classification Specialists : Hélène LEBON

Sites Customs Representatives

Subsidiary Customs Representatives

Customs & regulatory monitoring

Sensitive countries

Regulary monitoring

• Link intranet https://legal.ic.corp.local/fr/ethique-conformite/page/index.html

• Work flow : RESTRICOM

Agreements, digitalization Yammer: (https://web.yammer.com/main/groups/eyJfdHlwZSI6Ikdyb3VwIiwiaWQiOiIxNTc1MjIxMyJ9)

Incoterms

CCIP / Exporter

• The Export Country files are updated in real time

=> Country constraints = a verification habit

• Export information tables

• DDP + EXW forbidden / Corporate Incoterm Policy

https://supplychain.ic.corp.local/fr/index.html

• Communication with the customer at destination is essential : COO must not be a custom.

=> Anticipation & adaptation to context are essential

Why do we issue special documents?

Origin ( ≠ Provenance of a commodity)

The origin of a commodity

It never changes if there is not a sufficient substantial transformation.

Provenance is a logistical and geographical notion.

Goods acquires a Community customs status by paying customs duties and taxes in the EU. Perimeter : Data Management / Origin

Origin is the nationality of the products.

• NON PREFERENTIAL ORIGIN-Made in

• PREFERENTIAL ORIGIN-Free trade agreement with EU

• Community status

If : Non preferential origin

• A product always has a common law origin which is determined according to:

Certificate of origin :

- the origin of the raw materials,

• Portal GEFI of the CCIP
• Numerical - for each expedition
• FEE TO PAY

- the transformations of the raw materials,

LTD :

- the place of the transformation..

• (= made in)
• Isotarget - 1 YEAR MAXIMUM

IF FTA : FREE TRADE AGREEMENT WITH EU => PREFERENTIAL ORIGIN

Origin is determined on the basis of the rules contained in the free trade agreements signed with the EU.

It allows to obtain a reduced or zero customs duties for the customer based in the countries

EA : Authorized Exporter

DOF : Declaration of Origin on invoice or commercial document

• EUR1 : preferential origin certificate
• EUR MED : Paneuroméd REX : (Registered exporter) certifies the origin of the UE goods

Example : free trade agreement UE / Canada Japon

• ON Packing list (FOR DDP UK) or on invoice (for all incoterms except DDP)

(ex: Switzerland)

DLT preferential origin :

Free trade agreement EU / Türkiye

This agreement allows

The importation of goods without customs duties, regardless of their origin.

ATR : Circulation certificate

Endorsed by FR customs : Certifies the Union or Turkey customs status of the goods.

The sites have a pre-authentication authorization stamp to avoid going through a customs office again

GOOD PRACTICES: US / Egypt

USA : I.S.F.(Importer Security Filing)

Mandatory

Egypt : Cargo x

Fines

Nafesa portal

Global account : Arkema France

Example of preferential origin at ARKEMA - sales

14

Focus UK & CH back to back sales

Custom status : Registered Exporter

Customer

Declaration on Packing List Removal of EUR1

16

Samples & Return of goods

SAMPLES

Any good that crosses a border has value, even if it is free sample. The customs value = market value

SAP

In SAP: Transaction ZSAM

• It must be communicated by the seller
• It cannot be 0 or 1 euro

Error of value = False declaration → Penalties and sanctions

OOSAP

Exports of R&D products (including mixtures) through OOSAP Isotarget Tool.

...

An invoice is mandatory for any international file.

Product returns (import from third countries to the EU)

The import customs clearance instructions to be sent to the RDE :

08:00

For product return = Import => Customs duties

• Explanatory letter for the return

08:00

To obtain an exemption from customs duties and taxes,

• The customer's proforma:

- Unit price identical to that of the export commercial invoice

08:00

the procedure is as follows :

...

- Mention : "Value for customs purpose only"

• The export commercial invoice

• The export declaration which must have ESO status

Why monitor clearances?

3/18/2025

Presentation Title

20

Customs activities at sites

Site or warehouse : Non-Export Customs ClearanceAs of today, the declaration is submitted by an RDE mandated by Arkema, based on export clearance instructions.

Action : Customer Service Representative or BCU

Third Country

Incoterms FCA to DAP

The order is complete and ready for dispatch :

Action : Customer Service Representative

BCU with Export Customs Clearance Procedure (PDDE) : The declaration is submitted via GTS.

Action : BCU

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Customs activities at sites

Without Customs approval, the goods cannot leave the site/warehouse/customs office.

Third Country

Incoterms FCA to DAP

Request a copy of the export customs declaration and perform verification.

Action : Customer Service Representative or BCU

Non-PDDE warehouse or site

BCU with PDDE:

Make sure the export declaration has ESO Exit status.

Action : BCU

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Export operations: key points (scope: BCU)

Retrieve the export folder for archiving perimeter : BCU/CC control

Clearance of declaration : + BCU Control + Customer service representatives for alternative evidence

Conservation of export documents: 10 years in a secure location

Verification of declaration clearance when crossing the EU border

The BCU checks the declarative data and requests rectifications if necessary

Monthly monitoring of tax risk Arkema France Action: customs department

22 |

CLEARING – TAX RISK

For all exports => document cleared.

Without this justification, Arkema is liable to pay VAT (i.e. 20%).

Non-clearance = tax risk

List of alternative evidence to be presented to the customs office :

A declaration signed or authenticated by the company that took the goods out of the customs territory of the Community.

A copy of the delivery note (DB) signed or authenticated by the consignee located outside the customs territory

Proof of payment, invoice or delivery note duly signed or authenticated by the economic operator who took the goods out of the customs territory of the Community

A document certified by the customs authorities of a Member State or a country located outside the customs territory of the Community

Documents EX / EU -

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RAPPEL :

Powers of attorney :

Only the person authorized by power of attorney can file a customs declaration in the name and on behalf of Arkema.

A RDE can act on behalf of Arkema

Only if he has a power of attorney or a customs representation mandate signed by the customs department.

Single RDE:

• For any export in FCA incoterm
• For any import and any incoterm

=> Product return SEALOGIS / GEODIS

3/18/2025

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Quizz

Questions/Réponses

DDP : Incoterm Prohibé

Pourquoi l’incoterm “DDP” est il proscrit au sein d’Arkema à l’export et à l’import?

ON Request : Long-term declaration for preferential origin (LTD)

Beyond 90 days, if the declaration is not cleared, alternative proof of the goods leaving the territory is requested. If doubts, alternative proofs must be presented to customs department for acceptance before SI registration

European goods are delivered outside the European Union

Declaration on packing list

DLT preferential origin :

TOOL : Isotarget

https://isotarget2.ic.corp.local/DLT/ExtMain2.aspx

Only for transactions within the EU : Essential traceability

Valid for 1 year after original analysis carried out at the beginning of the year

Denunciation: if a change of raw material or supplier

https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region/negotiations-and-agreements_en

Third party goods are delivered within the European Union.

Declaration of Origin on invoice

The mention of origin on the invoice is possible because Arkema has the status of

• Authorized Exporter (most agreements) or
• Registered Exporter (Canada, SPG, OCT).

(SPG : Système des Préférences Généralisées : categories of developing countries

ATR movement certificate