According to data released by the General Department of Vietnam Customs, there have been so far approximately 231 thousand enterprises adopting e-customs. However, local enterprises and customs branches face difficulties in implementing this.
For example, as for export processing enterprises (EPEs), it was said by Dong Nai Department of Customs, which has offered e-customs services to local EPEs since early May 2013, that during implementation, the Department as well as EPEs involved in processing, production for export are facing some difficulties following regulations prescribed in Circular 196/2012/TT-BTC dated November 15, 2012 by the Ministry of Finance.
Specifically, Article 38, Item 5, Point C of the above Circular stated that “The export, import goods registered in the Declaration of Export, Import must be in accordance with those indicated in the receipt forms ins and outs kept by the enterprises in terms of codes, types, unit, and quantity”. It was said by EPEs that some materials were purchased in one kind of unit but quoted in the declaration in another unit. Besides, the Article 38, Item 5, Point B stipulated that: “The consumption rate of materials notified to the customs branch should be relevant to the actual production in enterprises”. In reality, given the norm without consumption, the enterprises have always followed the production formula at guaranteed quality. However, the difficulty is how to identify the consumption rate that suits actual condition when declaring registration as there are many production materials and a material used for different products will have different consumption rates.
In addition, there are many products produced on a continuous basis, of which some can be exported several days after production or have part of the volume exported while the other part of inventory. During production process, the consumption always varies due to repeated installation for each type of product, incidents with machines, operation, defects in package and difference in consumption between new products and old ones owing to instability etc, which, therefore, makes it very hard to determine the relatively accurate consumption rate.
It was recommended by enterprises that the declaration on norms should be made in the direction of skipping consumption rate of norms but declaring usage norms of materials on each finished product unit; then the volume of materials in consumption rate will be in the volume difference between actual inventory and record. Given the explanation of enterprises, the customs branches consider accepting such difference in material volume, allow adjust data in the records in accordance with the actual inventory for consequent follow-up, provided that the enterprises observe the laws, make commitment to be free of frauds and customs offices detect no domestic consumption of the enterprises.
The identification of consumption rate is also involved with the implementation of Article 38, Item 5, Point D which specifies that: “The actual inventories EPEs declare during liquidation with customs office should match with the inventories recorded in their accounting documents and “Summary of exports-imports-inventories” monitored by customs office in the same reporting period”.
Another cause is the consumption rate is hardly quantified at a specific time but always varies depending on production status, material quality and package. Thus, it cannot be a fixed number but only the average after a period of time. Moreover, the material inventories in factories can be in forms of waste, scrap; finished goods; semi-finished goods, material inventory etc. The accountants conduct inventory at the end of the year to identify the inventories volumes of materials, semi-finished products while enterprises are requested by customs office to convert from finished goods, semi-finished goods, waste, scrap into materials when preparing liquidation reports of EPEs according to the regulation on required quarterly reports, which make up a challenge for implementation.
Given the questions and wonders of EPEs and responses by General Department of Vietnam Customs at Official Letter No.1554/TCHQ-CCHDH date March 28, 2013 to cities’ customs branches, Dong Nai Department of Customs finds that the separate regulations for EPEs rather than others (which are not EPEs) but also involved in processing, production for export, cause complexity in management of customs office.
Such management mechanism will also makes up difficulties when customs sector are adopting customs procedures on system VNACCS/VCIS in 2014. On the other hand, the sector modifying Laws on Customs to suit the system VNACCS/VCIS, which means comprehensive adoption of only one method for management of exports and imports by enterprises which import materials for processing, production for export (including EPEs), and drop the current complicated division into types (processing, production for export, EPE).
It is recommended by Dong Nai Department of Customs, e-customs procedures should be applied consistently for both EPEs and others (which are not EPEs) for convenience and fairness among enterprises that import materials for processing, production for export and suitability towards modification of Bill of Customs.
Hien Thinh
Đăng ký: VietNam News
