Today, we propose to consider some of the most pressing issues that a foreign trade entity faces when obtaining the special simplification ‘Independent application of special type seals’
So, what is the ‘Independent application of special type seals’?
This is a transit simplification that allows authorised enterprises to seal vehicles with goods transported under the common transit regime without presenting them to the customs authorities.
Who can apply the simplification ‘Self-sealing of special type seals’?
A company that has received authorisation from the AEO and is permitted to apply the special simplification ‘independent application of special type seals’ in accordance with the Customs Code of Ukraine;
an enterprise that has been granted permission to apply the special transit simplification ‘independent application of special type seals’ in accordance with the Law of Ukraine ‘On the Common Transit Regime and the Introduction of the National Electronic Transit System’.
The mandatory conditions for obtaining this simplification are:
Compliance with the requirements of the customs and tax legislation of Ukraine, as well as the absence of facts of criminal prosecution;
proper system of accounting, commercial and transport documentation;
ensuring practical standards of competence or professional qualification of the responsible official of the company.
‘What goods are subject to special type seals?’
Special type seals are applied to goods, individual cargo places or other packages, containers, commercial vehicles until the customs declaration is submitted to the customs authority. Information about such seals shall be included in the customs declaration.
‘What are the technical characteristics and specifications of seals?’
The seals must meet the requirements of DSTU ISO 17712:2015 ‘Freight containers. Mechanical seals’ or ISO 17712:2013 ’Freight containers. Mechanical seals’ and be of the following types in terms of security:
a seal with a high security guarantee (‘high security seal’);
a seal with a security guarantee (‘security seal’);
indicative seal.
*The company independently chooses the type of seals, taking into account external factors that affect the seal during the entire period of its use, as well as the requirements of carriers of the respective modes of transport.
Special type seals have the following main characteristics
remain undamaged and securely attached during use;
easy to check for integrity;
be manufactured in such a way that any breakage, tampering or removal will leave traces visible without the use of special tools;
be designed for single use;
have easily readable unique identification numbers.
In accordance with paragraph 5 of Section II of the Requirements for the characteristics of special type seals, their accounting and storage, approved by the Order of the Ministry of Finance of Ukraine dated 29.10.2021 No. 568, the structure of the unique identification number of a special seal has the format UA/0000000000/УУУУУ, where:
UA is the letter code of Ukraine;
0000000000 – the company code according to the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organisations. For the purposes of marking the seal, the code of the legal entity in accordance with the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Associations shall be supplemented at the beginning with zeros up to 10 characters;
UUUUUU – the registration number of the seal in ascending order, starting from one.
The company shall independently keep records of seals by entering information into the register by the officials responsible for the accounting and storage of seals, including
type of seal;
unique identification number of the seal;
information on the use, damage, loss of the seal.
It should be noted that the availability of the ‘Self-sealing of special type seals’ simplification is a prerequisite for obtaining such types of special simplifications as: ‘release at the location’ (for companies with AEO authorisation) and/or the special transit simplification ‘authorised shipper’ (for the common transit regime (NCTS)).