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22

Once the application is ready, the second step starts when the applicant submits its application

with all the supporting documents (namely compliance program as it was presented above,

self-check sheet, corporate registration certificate and all other relevant documents).

Third, the application is examined in order to check whether the applicant satisfies all the

criteria required. If it is accepted, the Customs Authorities head to an on-site inspection to

confirm the security measures (locking devices, facilities, cargo segregation, lighting, access

control, automation and all other components of the aforementioned compliance program).

Finally, the applicant is approved to become an AEO by the Director-General of Regional

Customs. Along with the annual internal audit, the AEO is subject to a post-authorization audit

by Customs where the latter conducts on-site interviews, reviews the internal audit and checks

all the facilities. If a problem is identified, the Customs Authorities give an “Administrative

order for improvements”. When not implemented, the status of AEO is revoked.

After presenting the whole process of authorization, two steps do matter in the

implementation of the AEO. First, the prior consultation with Customs is crucial as it helps

potential AEOs fulfill the requirements and comply with various criteria determined by the

Japanese Customs. This makes the procedure much quicker as, on average, this process takes

up to 6 months in different countries, while it takes only 1-2 months due to voluntary

consultation and preparation prior to application. Second, the audit process is crucial in

maintaining the quality of AEOs in terms of infrastructure, compliance and facilities.

Benefits of the AEO Program

According to the Japanese Customs, benefits depend on the type of the operator. However, the

benefits can generally be summarized into two main categories: increased reputation as a

compliant and security-oriented company, and a preferential treatment within Customs.

Furthermore, the following are the benefits for different types of AEOs:

For AEO importers and AEO exporters

: Their benefits are mostly compliance-related

reduced examinations and inspections. Additionally, while AEO importers are granted a

“pre-arrival lodgment of import declaration and permission”, “release of cargo before

duty/tax payment declaration” and “periodical lodgment of duty/tax payment

declaration”, AEO exporters benefit from a waiver in the obligation to deposit cargo into

the Customs area before export permission.

For AEO warehouse operators

: They have the ability to launch additional new bonded

warehouses by just informing it to Customs compared to non-AEO warehouse operators

that must obtain a permission to do so. Furthermore, Customs conducts compliance-

related reduced audits of warehouses, making the task easier and quicker. Finally, AEO

warehouse operators do not pay the monthly fee for keeping Customs warehouses.

For the AEO logistics operators

: The procedures for Customs transit are more simplified for

forwarders, shipping companies, airlines and transportation companies. For instance, for

every Customs transit, AEO carriers and forwarders are not obliged to get permission

leading to less uncertainty and more effectiveness in dealing with transit time.

For AEO Customs brokers

: Goods are released before duty/tax payment declaration and

duty/tax payment in case a non-AEO importer delegates its import clearance to an AEO

Customs broker. Similarly, if a non-AEO exporter delegates its export clearance to an AEO