In recent months, the issue of issuing long-term supplier declarations (LLE) and the associated new requirements from the Union Customs Code has been the subject of lively discussion. The suspension on the date of issue for the beginning of the validity of the LLE has caused irritation and a not to be underestimated organisational effort.
The EU Commission has accepted the objections and has tabled a proposal for an amendment to Article 62 of the Implementing Regulation. This proposal has yet to be confirmed by the Member States. This is expected shortly. However, an amendment to the implementing regulation will be made in the package, so that final adoption is not expected before the summer. The following text has been formulated by the EU as a proposal (Article 62 (2) DVO):
“… A long-term supplier’s declaration shall be made out for consignments dispatched during a period of time and shall state three dates:
(a) the date on which the declaration is made out (date of issue);
(b) the date of commencement of the period (start date), which may not be more than 12 months before or more than 6 months after the date of issue;
(c) the date of end of the period (end date), which may not be more than 24 months after the start date. …”
In a nutshell, three dates will be required:
- Date of issue
- Date of start of validity
- Date for the end of validity
Thus, as before, an explicit date for validity can be specified again, which does not have to coincide with the date of issue (e.g. January 1). In this context, it should be noted that the date for the commencement of validity may not be more than 12 months before or more than 6 months after the date of issue.