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Jennifer F. Revis

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The recent amendments to the Russian iron and steel sanctions that came into effect across Europe on 30 September 2023 have had a significant impact across sectors. We previously reported on the business consequences and recommendations on the tightened restrictions in our blog post available here. Although the latest restrictions are still in their early days, it is becoming increasingly clear that cooperation between sanctions and customs teams within businesses is crucial to ensure that…

On 21 September 2023, the European Court of Justice (“ECJ”) gave its judgment in a case concerning the non-preferential rules of origin (“ROO”) as laid down in the European Commission’s Union Customs Code Delegated Act (“UCC DA”), which supplements the Union Customs Code (“UCC”). The ECJ concluded in this case that the ‘Change of Tariff Heading’ (“CTH”) ROO laid down in the UCC DA can be deemed invalid in the light of the Treaty of…

The UK government published an evaluation report for the six pilot initiatives on an ‘Ecosystem of Trust’ (“EoT”) on 29 August 2023, which was first set out in the government’s 2025 UK Border strategy. Aimed at using technology to create the so called EoT around the border, the UK proposed an automated assurance and reliability model that could allow a simplification of the current customs and border processes. Such an ecosystem would be built on…

The UK government has released its final plans for the new Border Target Operating Model (“the Model”). The Model was initially set for implementation from October this year and has now been delayed to January 2024. The UK Government has agreed to this delay of three months following input from public consultation from the private sector and stakeholders. The Model which introduces the remaining sanitary and phytosanitary controls, as well as full customs controls for…

On June 19, the UK’s new DCTS entered into force, replacing its previous Generalised Scheme of Preferences (GSP) regime. Under the WTO Agreements, developed countries can grant non-reciprocal preferential treatment to products originating in developing and least developed countries, referred to as “special and differential treatment” (S&D) provisions, normally referred to as a GSP. Countries that grant preferential treatment through a GSP determine eligible countries and S&D provisions unilaterally. Along with a rebrand, the DCTS simplifies…

World Trade Organization (“WTO”) Members laid out several key principles for determining the customs value of imported goods in the 1995 Customs Valuation Agreement (“CV Agreement”) with the aim of ensuring that the value of Members’ tariff concessions would not be nullified or undermined. Nonetheless, the WTO is – incorrectly – seldomly considered as a relevant forum for addressing customs valuation issues. This blog post highlights two avenues at the WTO for dealing with customs…

Introduction of an EU Customs Agency is becoming more and more tangible. This idea of a “European Customs Agency” was first proposed on 31 March 2022 by the “Wise Persons Group on Challenges Facing the Customs Union”. More recently, on 28 February 2023, during the 62nd Plenary Meeting of the Trade Contact Group set up by the European Commission, the creation of an EU Customs Authority was once again discussed alongside the introduction of an…

The UK government announced on 15 March 2023 that customs valuation rulings, so-called Advance Valuation Rulings (“AVR”), would soon be a feature of the UK Customs regime (please see our earlier blog here). On 27 April 2023, the UK government published guidance on submitting applications for an AVR with the system going live. This is despite the necessary legislative amendments not yet coming into force. An AVR is a legally binding ruling held by the…

On 31 March 2023, the UK announced that it will join the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), joining 11 countries (including Mexico, Japan, Canada and Australia) across the Asia-Pacific region and becoming the first European country to do so. While the UK already has existing bi-lateral trade agreements with 9 of the 11 CPTPP countries, the biggest benefits will arise as other countries join the bloc (with applications to join by countries…