Export: Basic Process

The process for exporting basic goods is a series of straightforward, sequential steps.

Italy is a member state of the European Union (EU), a political and customs union that harmonizes and standardizes most customs procedures among its members. Much of the following process, therefore, is the same for all EU member states. Any country-specific procedures are noted. The following process applies to articles being imported from third countries outside the EU. Movement of articles across EU member states is largely free and unregulated.

Export Protocol

The customs authority in Italy is known as the Customs and Monopoly Agency (Agenzia Dogane e Monopoli or ADM) (www.adm.gov.it).

Documentation Package

The exporter prepares a documentation package consisting of the customs declaration, known as the Single Administrative Document (SAD), and accompanying documents, which is submitted to Italian Customs. Traders exporting articles for which a customs declaration is not required must submit an Export Summary Declaration (EXS) that includes the articles’ safety and security data (i.e., number of items, consignor, consignee, weight, etc.), along with the other required documentation.

Single Administrative Document (SAD)
The exporter or its representative is responsible for declaring articles to be exported from the EU on a SAD. The SAD and all accompanying documents are submitted to the customs authority in the EU country of export (which is the location where the articles are packed/loaded and customs controls are performed, even if other EU countries/ports are visited before ultimately leaving the EU). In the case of exports out of Italy, the SAD is submitted to the relevant Customs office electronically (see Electronic Filing below). Upon filing and validation of the SAD, a unique 18-digit alpha-numeric reference number, called a Movement Reference Number (MRN), is automatically assigned by Customs to the exporter.

Exit Summary Declaration (EXS)
If required, the carrier is responsible for submitting the EXS and any accompanying documents to the customs office of export. A third party (such as the exporter) may file the EXS with the knowledge and contractual consent of the carrier, but must include the carrier’s EORI in the submission as well as its own EORI. Ultimately the carrier is held responsible for submission.

In the EU, two simplified customs procedures are available to traders: Simplified Declaration Procedure (SDP) and Local Clearance Procedure (LCP).

Documentation Review

Customs reviews the documentation to check for:

• Authority of the entity to export
• Consistency of information across documents
• Legality of the proposed export
• Proper product classification

Customs also:

• Establishes whether to order an inspection of the shipment
• Computes duties, taxes, and other fees
• Refers documentation to other governmental agencies for exports of controlled products
• Establishes any special requirements for final clearance of the shipment

Most exporters engage the services of a logistics firm or a customs broker to handle export documentation and procedures.

Time to File

The SAD or EXS, as required, must be submitted within the following timeframes:

• Containerized maritime cargo: At least 24 hours before commencement of loading in each foreign load port
• Bulk/break bulk maritime cargo: At least four hours before arrival at the first EU port
• Short sea shipping: At least two hours before arrival at the first EU port
• Short-haul flights (less than two hours in duration): At least by the time of takeoff of the aircraft
• Long-haul flights (two hours or more in duration): At least four hours before arrival at the first EU airport
• Rail and inland waterways: At least two hours before arrival at the EU customs office of entry
• Road traffic: At least one hour before arrival at the EU customs office of entry

Electronic Filing

The customs declaration (SAD) may be submitted to customs electronically. If submitting an EXS, it must be filed electronically via the EU's Export Control System (ECS). In Italy, the ECS is accessed using the web-based Digital Customs Service (EDI) at www.adm.gov.it/portale/en/dogane/operatore/servizi-online/servizio-telematico-doganale-e.d.i.. Registration for the Italian EDI is available online using the Customs Telematic Service (Servizio Telematico Doganale) at http://stdru.agenziadogane.it/SchedaWeb/RegistrareUtenteServlet?UC=16&SC=1&ST=1.  

Export License, Commodity Clearance, Certificate of Exemption

Export license(s) and/or commodity clearance(s) may be required for certain restricted articles. A certificate of exemption may be obtained for certain prohibited, banned, or controlled articles. Any required license, permit, etc. should be submitted together with the SAD.

Export Documentation

All exports of physical articles require the following basic documentation:

• Single Administrative Document (SAD)/Exit Summary Declaration (EXS)
• Commercial Invoice (CI)
• Freight Document: Bill of Lading (B/L), Air Waybill (AWB), Rail Waybill, or Road Waybill
• Packing List (P/L)

Some exports may require specialized documentation:

• Export Accompanying Document (EAD)
• Certificate of Origin (CoO)
• Insurance Document
• Export Licenses, Permits, Certifications
• Documents as may be requested/required by the subsequent importer
• Documents as may be required by the terms of a bank letter of credit (L/C) or documents against payment (D/P) provision

Restricted and Prohibited Articles

The export of restricted and prohibited articles may require an export license or clearance from the governmental agency that regulates that article. Restricted articles include certain arms and armaments, certain technology products, plants, animals, food products, natural resource products, currency, and radioactive materials. A certificate of exemption may be obtained for certain prohibited, banned, or controlled articles.

Prohibited articles include certain plants and animals, especially those of endangered species. Some restricted and prohibited articles may need to be appraised prior to export in order to determine if they are exportable. (See the Restricted and Prohibited page for further information.)

Inspection

Upon submission of the SAD or EXS, the ECS automatically identifies articles that require documentary and/or physical inspection. This security risk analysis is based on EU-wide risk profiles.

Exported articles may be subject to inspection when:

• The seal on the shipping container has been tampered with
• The container is leaking
• The shipment’s details in the shipping documents differ from that in the manifest
• An alert or a hold order has been put on the shipment

Customs may also perform random spot inspections.

Payment of Duties and Taxes

In general, articles being exported from the EU are not subject to duties and taxes, but may be subject to various fees. Any assessed duties, taxes, and fees must be paid or secured to be paid before a shipment will be released for export.

Export Regimes

The EU has one unified export control regime, governed by Regulation (EC) No. 428/2009, which provides for common EU control rules, a common EU control list, and harmonized policies for implementation for the proposed export of certain arms, armaments, dual-use technology, and nuclear materials and equipment. EU Member States are also required to individually take certain complementary measures for implementing some of its provisions (e.g., breaches and applicable penalties). World Trade Press recommends consulting with logistics and legal specialists for more information.

Clearance and Release of Shipment

The customs office of export releases the shipment for export by issuing an Export Accompanying Document (EAD), which contains the shipment’s MRN. On release of the shipment, the customs office of export will transmit the necessary particulars of the export movement to the declared customs office of exit.

The office of export is the place designated by customs authorities where the customs export processing takes place. Normally, this is the office close to where the exporter or its representative is located or where the articles are packed/loaded. This is where the customs declaration (SAD) is lodged, where risk analysis is completed, and where the MRN is issued to the exporter. After completing all necessary procedures, the office of export issues an ‘anticipated export record’ message to the office of exit. After the articles are released by the customs office of export, the articles and a copy of the SAD are presented to the customs office of exit.

The customs office of exit is the last customs office visited before the articles leave the EU customs territory (e.g., the port, airport, or railway station). The office of exit is likely in a different Member State than the office of export. If an EXS is lodged, it is the office where all exit procedures are carried out before releasing the shipment. For articles covered by a SAD, it is the final location where articles are presented before they leave the customs territory of the EU.

Where the customs office of export is the same as the customs office of exit, no EAD is issued and the export procedure is completed by that one office.

Export Support

For more information, contact the European Commission using their online contact form at https://european-union.europa.eu/contact-eu/write-us_en or Italian Customs and Monopoly Agency using their electronic form available at www.adm.gov.it/portale/en/scheda-urp.

Note: The above information is subject to change. Exporters are advised to obtain the most current information from a customs broker, freight forwarder, logistics professional, or the local customs authorities.

Sources: European Commission (www.ec.europa.eu); Italian Customs and Monopoly Agency (Agenzia Dogane e Monopoli or ADM) (www.adm.gov.it)

Article written for World Trade Press by Brielle Burt and Brittony Hubbard.
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