Titel:
Evaluation of Electronic Transport Dokumentation Projekt
Resume:
Simplification of the administration of export refunds in connexion with direct exports from Danish harbours.
Udgiver:
Direktoratet for FødevareErhverv
Ansvarlig institution:
Direktoratet for FødevareErhverv
Forfatter:
Direktoratet for FødevareErhverv
Sprog:
Dansk
URL:
http://www.netpublikationer.dk/DFFE/6650/index.htm
Digital ISBN nr:
87-91904-93-5
Version:
1.0
Versionsdato:
20-06-2006
Dataformater:
html,htm,jpg,gif,pdf,css,js
Udgiverkategori:
statslig
Emneord:
report, employ, electronic, transport documentation, export, farm produce, agricultural products, refund, subsidy of export, control, evaluation
Copyright:
Direktoratet for FødevareErhverv
The electronic transport documentation project has been in preparation over several years and has, by virtue of close cooperation among - in particular - three parties: common carriers, the customs authorities, and the DFFE, seen the light as a pilot project in early 2005.
Interest on the part of auditing agencies in the project and the development of electronic documentation in general has been great. The project represents the sole follow-up on Special Report No. 7/2001 from the Court of Auditors, which recommends - i.a. - a focus on container movements and ”tracking information” in connection with the approval of differentiated refunds. As soon as the information is available on paper, many identified sources of errors arise. In that light it is somewhat ironic that this project was not launched by the Commission, in that it underlines the inadequacies of the present paper-based procedure in connection with protecting the European Agricultural Guidance and Guarantee Fund ("EAGGF") against financial risks; a paper-based Bill of Lading provides no guarantee or validity with regard to payments from EAGGF - in that no rules have been adopted to show when the document must have been issued, when the check must be carried out, or whether the information has been updated in relation to transhipment, transport route and destination. By contrast, the authorities' access to the carriers' databases provides the security that the auditing authorities can rightly expect from the paying agencies.
Government authorities - especially the funding authorities - have shown great interest in the project because budgetary savings, digitalisation and rationalisation have gone hand in hand with improved quality.
Finally, and not least, great interest has been shown by the users because of the possibilities of simplification and digitalisation inherent in the project and the derived effects it might have.
Derived effects
One of the crucial focal points has been the fact that no appreciable IT development has been started. Instead, the basis is the utilisation of third-party favour and commercially-based systems for the benefit and in the interest of all parties.
At the present time already, potential derived digitalisation benefits can be discerned within the administration of export refunds and customs and other public administration, where the information is to be verified (assessed as being valid) and exchanged under protected conditions:
Suggested improvements
An overall list of suggested improvements has been drawn up in connection with the evaluation of the project (Schedule 3). Most of these proposals have already been incorporated in the procedures or are being implemented, especially as regards the new approval procedure.
During each constituent evaluation, suggested improvements have been accumulated; these will be included in the further work when an effort is made to make the scheme permanent. These proposals are summarised in Schedule 3.
The overall opinion of the project is positive, although the scope of its application is still lower than expected. Virtually all exports from Danish ports may, in principle, be covered by the project. Qualitative and target-oriented information to the users is the foremost means of ensuring its more widespread application. Maersk Sealand has made large-scale use of the system, and Hapag-Lloyd to a somewhat lesser extent. P&O Nedlloyd has used the procedures only to a minor extent, which is likely to change when, as expected, that group merges with Maersk Sealand. The company has made it clear that, as from March 2006, P&O Nedlloyd will use the same system as Maersk Sealand.
The barriers preventing participation in the project are believed to be related to lack of information, including lack of focus or proper priorities in-house at the users. Probably because, in the short term, new procedures involve added use of resources, although simplification and rationalisation gains will be evident fairly early. This, however, is not an unknown phenomenon in the administration of export refunds, where a certain inertia has always been evident in connection with the introduction of new procedures - a natural consequence of the cost and time consumed in the development of employee qualifications, information retrieval, etc.
Suggested improvements:
IT interfacing (homepages) and security procedures.
Generally speaking, IT user interfaces have proved to be operational and fulfilling the minimum requirements of the authorities. Furthermore, some carriers have changed the functionalities en route for the purpose of increasing the authorities' user satisfaction. In certain cases the security procedures have been seen as somewhat ponderous, especially in the case of introduction of new users and/or a reshuffling of officials with the authorities. However, compared to the situation before access to electronic databases was established, there is great satisfaction.
It has been paramount for SKAT to ensure that the electronic scrutiny can be made with few references and with the viewing of few screen images. In other words, that the essential information is available in one place.
Suggested improvements:
Approving and changing passwords, etc.
No problems recorded as to SKAT's access rights. No appreciable access or updating problems were recorded for the transactions dealt with in the project.
In the case of one carrier there has been unlimited access to information on B/L details and tracking – based on general access for the authorities. As this problem may be a matter solely between the carrier and its customers, the authorities have not attached importance to this in connection with the assessment of the validity of the information.
User-friendliness
Some homepages are arranged in such a manner that several references are required and without ensuring the necessary degree of transparency. In that light the authorities have recommended that the design of the pages should be amended or revised. For the time being the problem is being tackled with more detailed instructions to the responsible officials.
Suggested improvements:
Training
Entries and log procedures have been a focal point of the training of the staff earmarked to handle the new system. The internal guidelines have been revised, and manuals have been prepared for the authorities' use of the systems (screen-based); these are updated when homepages are altered.
Furthermore, those regions which carry out export control have a material interest in the continued existence of the steering group established with representatives of SKAT, main office, the DFFE and the customs territories - as a permanent steering group with access to evaluate the work and to adjust the inter-ministerial agreements on an ongoing basis. Practical problems have been avoided by virtue of a relatively high information level and an unproblematic contact between the local and the central authorities.
Problem areas – destinations, routes, etc.
Supporting aids have been obtained for the purpose of determining/detecting geographical problem areas in connection with the bills of lading - especially in cases where there is no through B/L from the port of loading to the final destination but where the port of arrival is the starting point for further transit. If the port of arrival is not located in the country of destination, a special procedure has been initiated where the file is sent to the DFFE for further processing, in that - normally - this requires additional documentation2.
Atlas as internet site has been made accessible for the administrative procedures.
Rapid clarification of problem areas involving destination, quantity and ”date jumps” (such as between the cargo manifest and the B/L or in the case of unloading over several days) has been successfully tackled, so that the rectifying procedure in the DFFE has not been initiated.
There are also repeatedly problems in one port of departure as regards always to indicate the name of the “feeder vessel” in the electronic system. Clarifications are sought “on the spot” by contacting the carriers, or a paper Bill of lading is requested.
Use of resources
In those areas where the administration has been implemented there is a tendency towards a reduction in the use of resources - first and foremost because special administrative procedures have been established where the cargo manifests and bills of lading of whole ships can be examined simultaneously. In other words, there is a need to arrange the administrative procedure in a manner requiring as few entry references as possible on the various homepages.
A good deal of resources has been spent on training for the new procedures. At the same time, the dual procedure employed so far (paper/electronics) has implied that immediate resource gains have failed to materialise. However, as soon as a single electronic procedure has been implemented, this will change. Thus some resources are still being used on the triple procedure in connection with bills of lading (registration, administrative processing, approval).
Improvement potential (general)
User-friendliness.
There are certain inexpediencies in connection with the layout of the relevant homepages that cause the administrative procedure to be delayed or made difficult. One of them is that all relevant details and references are not available on the same page/screen image on all homepages. It is a matter of layout and transparency which is likely to be able to be resolved concurrently with the normal updating of homepages.
Degree of application.
The scope of the new scheme is one of the major potential areas of improvement. It is significant that it takes so much external information to convince relatively big and professional players of efficiency gains that will benefit themselves.
If the percentage of application reaches close to 100, it will be far easier for SKAT to arrange the administrative procedure and to train its staff accordingly.
SKAT also proposes that the following be carried into effect:
The day-to-day use of the procedures, including the underlying procedures that support the planning of conversion checks, if any, is explained in Schedule 2. The description applies to the internal procedures at the East Jutland Region (Port of Århus). Schedule 3 contains the internal procedures of the carriers participating in the project.
Delegation.
A major part of the electronic transport documentation project has consisted - as far as the DFFE is concerned - in controlling an overall delegation of the scrutiny of differentiated refunds for small export consignments from Danish ports. The aim has been the dual one of, on the one hand, carrying out an actual delegation (thereby streamlining the administrative procedures and easing the exporters' administrative burdens) and, on the other, of ensuring that SKAT is at all times given the optimum assistance and support for the continued administration of the scheme. A quite crucial feature has been to be instrumental in ensuring that practical initiatives or auditing considerations will not involve an added burden on SKAT but, on the contrary, should contribute towards a steamlining and increased security on account of the foundation in electronic documentation.
Extended cooperation with regions/areas
The DFFE has initiated a form of cooperation with customs regions/areas in connection with implementation which has proved to be both useful and necessary and which has also been used in resolving other issues with SKAT. The formal mode of cooperation has been instrumental in extending institutional and personal networks for the benefit of the DFFE as well as customs areas and SKAT, main centre.
In this manner the cooperation has underlined the need for a more permanent forum between the DFFE and SKAT (areas) in terms of exchange of experience between the practical control work and guidelines/decisions in cases. Not least, the areas often have a need for extended debriefing on the scrutiny reports submitted. Especially the explicit purpose of avoiding problem cases through a preliminary hearing and thus avoiding subsequent technico-practical problems in connection with the electronic transfer of the files can be applied, straight away, to other areas of the administration of the control of export refunds.
Overall, it is the DFFE's opinion that the ad hoc group which has been established to deal with matters in connection with the implementation of the electronic transport documentation project should be made permanent and, as the case may be, should extend its responsibilities.
Improved service to the customers
Coordination initiatives between SKAT and the DFFE which have proved necessary in connection with the preparation and implementation of the project have had a definite derived effect on the customers in the export refund scheme - particularly the exporters, but also the carriers. The customers should be entitled to expect efficient organising of the control tasks when the administration of the area is integrated between two authorities in the legal foundation. In return, the authorities must also be entitled to expect that a relatively strongly organised exporter industry can offset this effort by means of initiatives that make it possible to utilise this service. Here, it is the DFFE's opinion that trade organisations as well as individual undertakings should intensify their efforts to make use of the great simplification potential inherent in the scheme.
Accrediting procedure
The DFFE has considered - in the light of the past period, comments from carriers, customs authorities and internal and external audit bodies - that the existing accrediting procedure should be adjusted.
The evaluation is per se an example of a successful method which is based on an annually recurring accrediting - which gives the authorities an opportunity to increase or relax the demands and to renew or revoke approvals. However, this can also be done within the period if the circumstances so warrant. It should be noted again, however, that the safety net extended under the pilot scheme and the future permanent arrangement still takes the form of a demand for paper-based documentation in the event of any doubt concerning the documentation.
A new procedure for the approval of enterprises for the delivery of electronic transport documentation will be launched in early 2006.
Distinct criteria for approval
The criteria for approval will be determined anew and published prior to accrediting rounds. Special weight will be attached to positive indications with regard to:
The DFFE is aware of the fact that the checklist used for the scrutiny of the carriers' routines, IT systems and administrative procedures must be made operational in terms of exact evaluation and a weighting of the various parameters with a view to ascertaining if the criteria are fulfilled.
It should be noted in this context that there must be enough documentation to allow a rejection - with grounds - of a request for approval, and that the further processing must comply with national laws governing rights of complaint - as there is no EU regulation in this field.
It must be emphasised that, at this point already, an initiative has been launched for a new approval procedure of which the Commission's recommendations from the audit visit in June of 2005 form part. Prior to the new approval round the DFFE will publish a number of minimum criteria for the authorities' approval of the carriers' IT systems. These will include, i.a.:
The DFFE will look into the possibility of incorporating the Directorate's Internal Audit and/or certifying agency in the checking of the carriers.
A screen-dump of the check carried out is, in the Danish authorities' opinion, a very poor alternative - both in terms of the purpose of eliminating paper procedures and of the validity of the information, which is much higher in electronic form.
If the Commission is concerned about the lack of documentation showing that the check has been made, the Danish authorities will instead indicate two other possibilities:
The DFFE's spot checks
As the delegation of control from the DFFE to SKAT is based, in part, on the access to a subsequent check of the correctness of the documentation, and in part on SKAT's control, it is necessary to lay down unambiguous guidelines for the spot checks to be carried out by the Directorate prior to and after disbursement.
Over the first six-month period the DFFE has made spot checks of about 10% of the export transactions covered by the system.
The results of these spot checks have been highly unambiguous. There have been no cases of inconsistency - neither with regard to SKAT's control in relation to the guidelines provided nor with regard to substance. Nor have any cases been noted where the information on which the approval (and thus the disbursement) is based has changed. The checks were based, partly, on a scrutiny of the Bills of Lading for any updatings or adjustments, and partly on a check at container level (based on the Bill of Lading or booking) in the container-tracking part.
During the audit visit by the EAGGF the DFFE discussed the scope of spot checks and, in particular, the nature of the spot check control - spread over a priori checks and a posteriori checks. There was no unambiguous conclusion, but the DFFE argued in favour of the advantages of a posteriori control in most cases, except where a specific risk can be identified. A posteriori control makes it possible to ascertain - at a much later stage of the shipment - any changes in the transport route, destination, cargo, etc., whereas a priori control will often collide with administrative processing times and disbursement demands if the same information is to be obtained before payment can be made. At the same time this also reflects an extra check compared with the paper-based procedure without access to container-tracking information and electronic Bill of Lading register.
On that background the DFFE has reduced the incidence of spot checks but maintained it at not less than 5 %.
Risk analysis
The DFFE will develop a risk analysis model focusing on the matter of differentiated refunds and the lack of demand for proof of arrival. As it is, typically those destinations where it is demonstrably difficult to obtain that type of documentation - or where the commercial sectors and the enforcement of these are not so well-developed as in the EU - will be singled out for spot checks. But exporters or carriers, too, may be included in a possible risk analysis model.
Thus, the combined risk analysis model for differentiated refunds includes a design of spot checks in conjunction with an evaluation of risk of:
Administrative procedure
The administrative procedure in the DFFE per se consists of inquiries/surveys (results) in relation to the statements of homepages shown in Box 44 on the declaration.
Subject to reference to the agreements or contracts with the carriers there is security present in the use of the electronic access to the relevant homepages. In addition to the carriers' own security measures in the form of digital certificates to the DFFE and SKAT, there is - in-house at DFFE - user names and password identification implying that the access can be documented and restricted. The DFFE has pointed out, however, that there must be at least four (4) authorised users at the Export Refund Office if it is to be possible to arrange the administrative procedures in a sensible and efficient manner.
Training
In most cases the responsible officials and others who are granted access to the systems in question have received instruction in inputs and log procedures for the various systems. In the light of recommendations from EAGGF auditors the DFFE has elaborated a supplementary screen-image-based precept for the processing of cases.
Problem areas – destinations, routes, etc.
There have been cases where it was difficult to complete the spot check because of unknown destinations - either unknown port destinations or unknown inland destinations where the country of destination is different from the country with the port destination, and where the goods are carried on by road or by rail.
In those cases the matter is always investigated in more detail. Obviously, the DFFE has more experience with this matter than SKAT, and the problem is resolved by the ongoing administrative processing, where the responsible officials' qualifications are upgraded.
It goes without saying that there is no separate opinion from those exporters who have - for one reason or the other - not yet participated in the scheme.
For those exporters who have been part of the scheme from the outset the opinion has been favourable - although it is admitted that changing a number of in-house procedures and, especially, changing the awareness thereof among staff members who were used to the paper procedure has been costly in terms of effort and resources.
The - initially - relatively low degree of application is thus linked with the process of change which is necessary in order to reap the benefits. Not all exporters have had sufficient overview to make this short-term investment in the long-term gain inherent in the scheme. Pilot enterprises will therefore have an ongoing, great impact on the degree of application. Several exporters have begun to use the DFFE's checklist in connection with contract negotiations with the carriers - which goes to show that at any rate the awareness of the advantages of the project is present.
The DFFE has focused on rapid disbursement as the most significant incentive when promoting the scheme, and it is the exporters' opinion that precisely the bottom line is the most important motivation. The exporters have therefore demanded specific information concerning the financial advantages of using the system, where the exporters' overhead costs as well as disbursement timing will be of interest.
The perspective of the exporters' future reduced use of resources in terms of administration is also essential. The potential for improvement, which means that eventually all potential suppliers of transport services are included and that there will be no manual administrative processing, has also been a feature of interest to the exporters.
The carriers/hauliers' own opinion of the project has been closely linked with the expectations that the exporters may rightly have from the positive consequences for the official processing time for refunds. It has therefore been essential for the carriers to obtain unambiguous declarations from the authorities as to their requirements with regard to computer systems, documentation and legal validity, so that it will be possible to use one's own computer systems as a factor in the market for transport services.
There has been particular focus on the EU Commission's reception and evaluation of the project, in that many players are multinationally based and would like to see similar arrangements for the other Member States.
Economies in the field of administrative costs - not least because the electronic documentation is gradually becoming a market-based demand, or that the carriers are already obligated to provide a number of different details to other authorities (USA) - have been instrumental in the carriers' interest in and commitment to the project.
The project's potential for improvement containing the prospect of total digital administration is a factor that weighs heavily on the carriers' more strategic observations in connection with the project.
Internal Audit at the DFFE has been part of the steering group concerning electronic transport documentation and in that context has accepted the various procedures for documentation, audit trails and administrative processing. However, in one area - certification of the carriers' computer systems - they have declared that they lack the capacity or qualifications necessary for an evaluation of the components of the project, especially as regards accrediting.
Two different models have been indicated by Internal Audit for the further work with accrediting: either to trust an auditor's report from external auditors - or an ISO certification, or that the DFFE - with, as the case may be, external assistance - more methodically examines the various components of the carriers' computer systems and the validity of the information to which access is given.
The Commission has been continuously updated on the progress of the project. Furthermore, the EAGGF has paid an audit visit to Denmark in June of 2005, where the administration was discussed.
The Commission supports the Danish initiative, which will lead to a more efficient and swift administration - and reduced risk for the Fund - when it has been implemented.
It had also been clear to the Commission that so far there has been a parallel/duplication of efforts where the paper procedure as well as the electronic processing have been used in connection with the approval of payments. The Commission considered that, on that background, it would be possible to dispense with the paper handling, in that Denmark emphasised that a safety net would in any case be present in the form of a demand for the forwarding of paper Bills of Lading.
It was the Commission's opinion of the accrediting procedure that:
The Commission believed in that connection that Denmark might consider the increased use of standards (e.g. ISO) – but also increased emphasis on the use of the companies' internal audits. Besides, a more active incorporation of external auditors (perhaps the certifying agency) might replace the role of the DFFE's Internal Audit and, as the case may be, address matters of computer security, validity, etc.
Turning to documentation for the accrediting criteria and the process in general, the Commission recommended an investment in improved and more exhaustive reporting on the results in connection with the accrediting visits. For example, an advanced template with mandatory attitudes towards all the elements of the checklist might be part of every future reporting.
Potential for improvement
In relation to the accrediting procedure, in particular, the Commission believed that the project might be improved:
New accreditings
In connection with the formal end to the one-year approval for delivery of electronic transport documentation granted to certain carriers the Danish authorities will institute a new accrediting round in the light of this evaluation report.
Announcing minimum requirements
So that the suppliers of transport services can be well prepared and so as to ensure uniform possibilities and prevent limitations the DFFE and SKAT will - approx. two months prior to approval - announce the possibility of participation in the scheme and, at the same time, explain the minimum requirements for approval that will be in force as from 1 April 2006 and henceforth.
During the period between such announcement and the granting of approval or refusal, control visits will be paid to the enterprises that wish to participate in the scheme. Debriefing on the results, outlines and documentation submitted, as well as a review of a number of spot checks, will be made on an ongoing basis to the steering group provided. After a final series of meetings the DFFE will grant approval or indicate refusal to the individual carriers/hauliers.
Control/accrediting visits
The control visits will include a testing of access conditions (testing of access criteria, digital certificates, etc.) which will be made, as before, in the light of a number of specific current export transactions. If the carriers have not already obtained clearance to pass on exporter information to the authorities, they will have to take steps in that regard in connection with their affirmation of willingness to participate in the scheme.
A revised checklist will be used for the visits.
In connection with the new round of accrediting visits the DFFE is considering the use of external expertise to complement the DFFE's Internal Audit with regard to computer security and other auditing problem areas.
Steering group between SKAT and the DFFE
The evaluation unambiguously emphasises the expediency of close contact with the authorities on the implementation of the pilot scheme. The effort to make the scheme permanent therefore implies an obvious incentive to give the steering group a permanent character, too, and a formal rooting in the contractual basis between SKAT and the DFFE.
The control framework for the checking of exports will have this feature of the cooperation added to it, and the Master Agreement will also be revised if the circumstances so warrant.
Any practical problems, outstanding legal matters, financial questions (such as information technology development) will be handled in the steering group.
Information Technology Development
One of the considerations entertained by SKAT and the DFFE already before the EAGGF's audit visit was to secure an electronically based audit trail by specifying the B/L No. in the electronic approval image in connection with the control of export transactions. After the audit visit from the EAGGF it was decided to initiate the necessary IT development at SKAT in order to make allowance for this improvement of the documentation. According to the plan the technological development will be ready by early April 2006.
The general conclusion from the pilot period is that the project and the scheme work as intended. The procedures have been further developed on an ongoing basis in close dialogue with carriers (such as the question of combined access). Owing to the positive evaluation and the results of the spot checks carried out, paper handling as a parallel procedure from the transition period will then be eliminated.
There is one predominant negative element in the evaluation, namely the number of clients joining the project, which is still limited - although steadily rising with a few big exporters as pioneers. Exporters who, indeed, use the checklist for carrier accrediting as the basis for contract negotiations with these. Perhaps the immediate simplification in the sense that exporters needed to send Bills of Lading only to one authority has initially had such an impact that from the outset they have not considered going "all the way" by eliminating paper documentation - despite the fact that there were no significant technical barriers associated with that.
The fact is that security in the administration and, therefore, the basis of disbursement have now been elevated to a totally different and far higher level than before.
The crucial conclusion is therefore that the scheme is given a permanent status with the decisive qualification that the accrediting arrangement and the annual approval procedure are maintained. In connection with the evolution from pilot project to permanent scheme a number of constraints will have to be introduced to this accrediting procedure so that the comments and suggested improvements that are contained in the evaluation report can be incorporated as far as possible in the future administration.
The evaluation also shows that the prospects of synergy effects are good for the testing and determination of risk criteria for the rest of the administrative processing. Consequently, risk analysis models (risk assessment + random checks) should be developed for the purpose of obtaining an overview.
Results of the spot checks (a priori checks and a posteriori checks) show that so far no inconsistency has been found compared with the checks performed by SKAT in connection with their scrutiny of exports. But on several occasions the information on the tracking systems has been helpful in the administrative processing of proofs of arrival from ”problematic destinations” in third countries.
Efficient cooperation with third parties in the form of carriers has been instrumental in implementing and continuing the project.
The auditors' notes (EAGGF/Internal Audit and external auditors) have been incorporated, together with suggested improvements resulting from the evaluation, in the forthcoming revision of the administrative procedures. See Schedule 3:
Information about and promotion of the scheme – also assistance to other Member States. It is reasonable to expect that there are exporters who - in the light of the electronic transport documentation scheme - will choose to seek refunds in Denmark. A transaction with differentiated refund under € 2,400/12,000 per product line which is exported from a Danish port will be disbursed, on average, fourteen days after departure. At the same time, the associated licence guarantee will have been released by then. This gives the exporting firms significant cash-flow benefits - in that the amounts drawn on their overdraft facilities will be reduced - and will at the same time entail administrative economies for the exporters and for the authorities.
Perspectives
Until full recognition of the system as proof of arrival is given, the following possibilities exist for a simplification of the administration of the refund arrangements for administration and for exporters:
Long-term Perspectives
The project shows new aspects of the private-public interaction that are necessary to ensure an efficient and secure administration of subsidies. The financial risk for the Fund is significantly reduced, and this has been done on the background of close private-public cooperation. There is a substantial easement of the customers' (exporters') administrative burdens where the electronic access to necessary information and the validity, which is guaranteed by third parties (carriers), replace a cost-consuming paper-based or electronic communication with the authorities.
The perspective of eliminating paper procedures and even file transfers among private operators and the authorities is also a principal feature of the new EU strategy of e-customs, which is scheduled to be implemented in 2009. This project shows that the perspective of eliminating even file transfers among private operators and the authorities can be implemented, with a sensible dialogue, with great gains for all parties.
Finally, an initiative demanding - in the accrediting procedure - access to subsequent import of data to the authorities in different file formats could maintain the perspective of a completely e-based public administration - untouched by human hand - reaching much further than simply to the end of the export refund scheme in the EU's common agricultural policy. These are the perspectives that present and future customs administrations are facing.
1 Cf. regulations Nos. 456/2003 and 800/99.
2 As regards Bill of Ladings with indication of the final destination, which is situated in another country and the port of arrival, the carrier does have the legal responsibility for this part of the total transport route. Either the identification of the transport means and the container will appear from the Bill of Lading, or additional documentation of the transport from the port of arrival to final destination is requested.
