DIGITALEUROPE Statement - Practical standards of competence or professional qualifications for application of Authorised Economic Operator [“AEO”] under the proposed Union Customs Code (“UCC”)  

DIGITALEUROPE, the voice of the European digital industry would like to clarify whether a company, with multiple European sites and/or multiple European legal entities, will be able to wholly or partially ‘umbrella’, i.e. centralised focused responsibility, under a single competent person, for example within their European HQ or other site, their requirement to meet the practical standards of competence or professional qualification under AEO.

UCC Article IA-I-2-27 (123-08-IA) clearly sets out the criteria to be met for the practical standards of competence or professional qualifications to make application, or renewal, of AEO. These criteria may be open to local interpretation or further revision. The practical standards of competence are a minimum of 3 years practical experience on customs matters. Professional qualifications are required to be consistent with the extent of the involvement in customs activities and covering customs legislation. The qualifications need to be provided by a recognised establishment.

It is unclear within the practical standards required for AEO authorisation whether a person can act in the capacity of several sites and/or several legal entities within their European group and therefore Digital Europe would like to request clarification. In addition can we confirm whether clear guidelines will be published on how the criteria should be met.