As part of the reform of the legal framework in this area European Union customs law initiated by the European Commission on last spring with a specific proposal ( of 18 May 2023), the European Shippers' Council, the European Community Association of Ship Brokers and Agents, the European Sea Ports Organisation, the Federation of European Private Port Companies and Terminals and the World Shipping Council report the parts of the framework legal system which, in the opinion of the five associations, require Improvements.

Calling for a review of these issues, ESC, ECASBA, ESPO, FEPORT and WSC urge the European Parliament to address several Crucial points, starting with the one relating to custody regimes: Referring to the bonded warehouse, the five associations highlight whereas 'the proposed reduction of the storage period from 90 days to three days could have a negative impact on the fluidity of goods flows (import and export), on the competitiveness of the transhipment port system with respect to non-EU ports and the effective management of Loader logistics chains. In addition, they point out, this would lead to increased administrative and IT costs for terminal operators'.

ESC, ECASBA, ESPO, FEPORT and WSC emphasize the need for that legal continuity is also ensured: 'Until the until the new Digital Customs Centre is operational secondary legislation and data annexes of the current Union Customs Code should remain in place to facilitate the operation of the main systems UCC IT Regulations for the entry of goods into the EU. Without transitional provisions, economic operators do not would be able to use these systems and manage these processes'.

On the subject of goods safety, the five associations note that 'the introduction of new powers into the proposal to prevent a carrier from unloading goods in the event of data could significantly disrupt trade and appear superfluous in the light of the current powers to prohibit a carrier to load goods'. According to ESC, ECASBA, ESPO, FEPORT and WSC, "to minimise these risks, this power should only be invoked in extremely limited circumstances'.

Still about the possibility that the new rules will hinder the flow of trade, the five associations consider that, with regard to the presentation of the goods in the absence of advance transmission of goods data, 'Parties other than the carrier should also be legally Obligated to provide data on missing goods in advance upon arrival of the goods'.

About the cargoes remaining on board ships in relation to the goods which are intended to be unloaded at a port, ESC, ECASBA, ESPO, FEPORT and WSC note that 'the current proposal requires that all cargo on board be placed in custody temporary or subject to a customs procedure in the first port and not where it will eventually be disembarked'.

Finally, the five associations point out that 'the European Digital Customs should enable interoperability with the environment of the EU Maritime Single Window for ensure that it can be used for the fulfilment of the customs formalities' and that 'it is essential to that terminal operators receive the necessary data to Storing goods in a bonded warehouse well before the goods reach the port'.