France’s circular of 1 August 2017, « Procedure for customs representative registration and registration process follow-up » lays down the implementing conditions for the Order of 13 April 2016 relating to customs representation and the registration of customs representatives.
This Order implements the provisions of Article 18 of the Union Customs Code (UCC) which entered into force on 1 May 2016, introduces the concept of Registered Customs Representatives and defines the criteria for registration.
18 of the UCC stipulates that any person may appoint a customs representative who may be established either in France or in another Member State. Under certain conditions, representatives need not be established in the European Union.
Since 1 May 2016, persons registered as customs representatives have been permitted to carry out customs acts and procedures either through direct representation (i.e., the customs representative shall act in the name of and on behalf of another person) or through indirect representation (i.e., the customs representative shall act in his own name but on behalf of another person).
Effective from 1 January 2018, all operators who wish to provide direct or indirect customs representation services must first complete prior registration and fulfil the criteria laid down in the Order.
The scope of customs representation extends beyond the mere filing of the detailed declaration.
A customs representative may perform the following acts and procedures on behalf of another person:
Filing all customs declarations, temporary storage declarations, entry and exit summary declarations, re-export declarations and notifications, as well as any accompanying documents required for the application of customs legislation
Filing all necessary customs declarations and communication of all information required for the application of provisions governing the customs arrangements under which the goods are declared, as well as the presentation of said goods to customs
All acts of a litigious or non-litigious nature
All approvals, authorisations, agreements or similar documents issued by the departments of the Directorate General of Customs and Excise (DGDDI) to permit the application of customs legislation
All acts or procedures required for the application of customs legislation and the payment of duties and taxes which the DGDDI is tasked with collecting
The applicant is established in another European Union Member State
A specific procedure shall apply when the applicant is established not in France but in another European Union Member State:
- If you hold the status of authorised economic operator for customs simplifications (AEO-C): you must submit your application form to the Ile-de-France Interregional Customs Directorate, along with proof of valid AEO-C status.
- If you are not an authorised economic operator (AEO-C): you must submit your application form to the Ile-de-France Interregional Customs Directorate along with all documents listed in Annex II to the Order of 13 April 2016 relating to customs representation and the registration of customs representatives.
Submissions to the Ile-de-France Interregional Customs Directorate must be addressed to:
Additionally, if you do not hold AEO-C status, the status of Registered Customs Representative is granted upon fulfilment of the following three criteria, as stipulated in Articles 7 and 8 of the Order of 13 April 2016 in reference to Article 39 of the Union Customs Code:
- the absence of any serious infringement or repeated infringements of customs legislation and taxation rules, including no record of serious criminal offences relating to the economic activity of the applicant;
- appropriate customs and commercial management system which allows customs controls;
- professional customs competence.
Fact sheets concerning the conditions for implementing registered customs representative status
Application for registration as a customs representative
For more information