Dealing with system problems in accordance with Circular 39/2018/TT-BTC

The professional operation at the Customs Sub-Department managing the investment-processing goods (the Customs Department of Hanoi). Photo: N.Linh.

The Customs Departments: Thanh Hoa, Hanoi, Ho Chi Minh City request the General Department to publish the procedures which have already been loaded in the system and have functioned to meet the requirements of electronic information transmission; To guide the implementation roadmap and contents for the procedures which have not been loaded in the system or have been loaded, but have not functioned to meet the requirements of information transmission yet.

According to the guidance in Appendix II of Circular 39/2018/TT-BTC, the enterprises must carry out the declaration operations such as: Notice about separating the bills of lading for imported goods (Form No. 12), Notice about the information on the imported goods in case of no bill of lading (Form No.13), Notice about the information on expected export goods (Form No. 14), Notice about the same container packing of goods in many export declarations (Form No. 15)… However, the enterprises have not performed these functions on the system at the present.

Regarding this issue, the Customs Departments of Quang Nam, Can Tho and Quang Ninh reflected that Forms 17, 18 and 19 of Appendix II to Circular No. 39/2018/TT-BTC only stipulate on the electronic declaration criteria, and does not give information regarding forms in paper for implementation. Therefore, they suggest to have the general guidance on the content of these forms when implementing paper forms for the units.

In response to the questions from the local customs, the General Department of Customs says that they are working with the software development companies to complete, and add the functions on the system and put it into operation soon. After completion, the General Department will organize training and guidance on the implementation methods for the officers. When waiting for official procedures to be put into operation on the system, the General Department requests the units instruct the enterprises to use the forms issued with the Circular or through the online Public Service Portal.

The Quang Nam Customs Department reflects: The enterprises have been carrying out the declaration for the processing contract and appendices of processing contract and sent them to the customs data processing system to get the receipt number. However, the unit has not been able to look up information on the processing contract, appendices of the processing contract on the system.

In response to this problem, the General Department of Customs says that in order to look up the information on the processing contract declaration on the goods management system of processing and production for exporting, the units can perform the function VI. Look up information => 1. Look up declaration information => 1.02. Look up processing contract.

The Quang Ninh Customs Department asks the following question: The declaration for the criterion on certificates of the export declarations has not been made yet because the VNACCS software has not been upgraded and updated. During the time the system has not been upgraded, the Sub-Departments have guided the enterprises to temporarily declare the certificates for coal and bauxite ore in the Notes section on the declarations.

The General Department of Customs answer to the above question: The declaration for the criterion on export certificates is specified at Point 2.33 of Annex I to Circular No. 39/2018/TT-BTC, replacing Appendix II issued together with Circular No. 38/2015/TT-BTC, the units should guide the customs declarers to comply with regulations strictly.

For the goods not subject to management by export or import certificates or the specialized inspection agencies, do not issue the notices of results of specialized inspection or the equivalent documents, but only regulate that the declarers must present the documents to prove that the goods are eligible for exporting and importing (for example, dossiers proving the lawful origins of export coal...), the units should guide the customs declarers to declare the serial number / date of the documents at the criterion of the note on the customs declarations.

The Hai Phong Customs Department reflects: Box 2.19, Annex I of Circular No. 39/2018/TT-BTC replacing Appendix II of Circular No. 38/2015/TT-BTC guides the declaration of importers' names: “In the case that a purchasing contract with a clause stipulating the receipt of goods in Vietnam (on-the-spot export), the name of the importer will be the name of the purchaser in foreign countries, the person who is designated to receive the goods (in Vietnam) will be written in the box titled, import trusting name”. However, there is no box to declare the import trusting name on the export declaration, so the Customs Department of Hai Phong proposes to add the box to declare the import trusting name on the export declaration.

In response to this problem, the General Department of Customs says that under the guidance in Form 02, Appendix I of Circular No. 39/2018/TT-BTC replacing Appendix II of Circular No. 38/2015/TT-BTC, criterion 2.19. Importer's name: “In case that the purchase contract contains a clause which designates the receipt of goods in Vietnam (on-the-spot export), the name of the importer is the name of the purchaser in the foreign country; Write the designated person (in Vietnam) in the box titled, Note”. The General Department of Customs requests the provincial / municipal Customs Departments to guide the customs declarers in implementing the regulations strictly.

The Quang Ngai Customs Department asks: Regarding the declaration of the quantity of goods with a decimal fraction in excess of 2 characters, according to the provisions at Point 1.83 of Form No. 01, Appendix II, “In case the actual quantity has a decimal fraction in excess of 2 characters, the customs declarant performs the rounding to two decimal digits after the comma..., and at the same time, declares the actual quantity and unit price of the invoice in the box "Description of goods" on the principle: "Item description # & quantity" (do not declare the unit price in the "Invoice price" box). According to the instruction, the invoice price will be stated in the "goods description" box, however, when instructing the declaration, it does not guide on the declaration of unit price on this line. On the other hand, according to the feedback from enterprises, with the above principles, the description of the goods name is declared before, the content of quantity will be lost when data is transmitted to the system of the Customs, so that, the information which the Customs receives is only "# & quantity" content.

In response to this problem, the General Department of Customs says that in cases where the quantity of goods has a decimal point in excess of 2 characters, the customs declarer shall round it to 2 decimal digits after the comma. At the same time, declares the actual quantity and unit price of the invoice in the box "Description of goods" on the following principle: "Description of goods # & quantity". The invoice price shall be declared in the box describing the goods after the implementation of the above contents and separated by a stop (.).

According to the design of the "Description of goods" indicator system, the customs declarers may declare a maximum of 200 characters. In cases where the information is declared in the "goods description" criterion exceeds the allowed characters, the customs declarers may be requested to add in the "Notes" section or use the attached file (HYS) to record the contents which should be declared.