Reviewed: March Collection of Customs Debts Manual

Transcription

1 Collection of Customs Debts Manual Updated: March

2 Table of Contents 1. Introduction Definitions EU Dimension Establishing the customs debt The debtor Collection of customs debts Appeals Instalment arrangements Reporting of debts Collection of debts receipt of payments Collected debts updating short payment records Debts which are unlikely to be recovered Debts which cannot be recovered...11 APPENDIX I REGISTER OF CUSTOMS DEBTS...13 APPENDIX II WO APPENDIX III CODE TO BE USED TYPES OF FRAUD OR IRREGULARITIES...15 APPENDIX IV CODE TO BE USED CUSTOMS PROCEDURE CONCERNED...16 APPENDIX V CODE TO BE USED METHODS OF DETECTION & CONTROL

3 1. Introduction 1.1 This Manual explains the action to be taken in relation to the collection of customs debts. In the majority of cases import duties are collected at the time of importation of the goods using the electronic customs declaration system (AEP). This Manual is only concerned with the situation where outstanding import duties (i.e. a customs debt) are identified post importation; this will usually arise as a result of a customs audit or other post importation check. 2. Definitions 2.1 For the purposes of this Manual - import duties means: customs duties and charges having an effect equivalent to customs duties payable on imported goods. Such duties also include anti-dumping duty and countervailing duty. - customs debt means: any under payment of import duties, intentional or otherwise, identified by means of post-clearance checks, investigation or audit after the goods have been released for free circulation. This includes a customs debt, identified in such a manner, which was incurred by the non-fulfilment of an obligation or a condition in, or the unauthorised use of, economic customs procedures, as described in Articles 204 and 205 of the Customs Code; a typical example here would be where a trader imports goods in excess of the quantity and/or value authorised in an Inward Processing authorisation. 3. EU Dimension 3.1 Import duties form part of the own resources (known as OR) of the European Union and in effect belong to the EU. Understandably, therefore, the EU has drawn up certain rules and requirements to ensure that the customs authorities of the Member States are diligent in ensuring collection of outstanding customs debts. 3.2 Under Article 325 of the Treaty on the Functioning of the European Union, Ireland is obliged to counter fraud and any other illegal activities affecting the financial interests of the Community. Ireland is also obliged to take the same measures to counter fraud affecting the financial interests of the Community as they take to counter fraud affecting their own financial interests. These obligations are given legal effect in Council Regulation (EC, Euratom) No. 1150/2000, as amended by Council Regulations (EC, Euratom) Nos. 2028/2004 and 105/ The practical effect of the EU rules is that a number of legal steps have to be taken where a customs debt has been identified: - the debt must be established and entered in the accounting records; - within a certain time frame, it must be notified to the Office of the Accountant General who must include the debt in a specific account (known as the B account) which is available for inspection by EU auditors. (In practice inspection of the B account occurs with every EU audit on OR.); 3

4 - the B account must be updated as the position regarding the debt changes (collection, part collection or write-off); and - the Office of the Accountant General must report the account quarterly to the EU Commission by means of the B statement. 3.4 These arrangements are explained in further detail below see in particular paragraphs 4, 9 and 10. Failure to follow the arrangements in relation to each customs debt will result in negative audit findings from EU auditors and possible sanctions being applied to Revenue. 3.5 There are further important implications arising from the fact that import duties form part of the OR of the EU: - where Revenue fails to make all reasonable efforts to collect a customs debt and as a result the debt is not recovered from the person liable, the EU Commission can hold Ireland liable for the debt instead. In these circumstances the Exchequer is required to pay the debt to the EU, notwithstanding the fact that the debt has not been recovered from the person liable; - where there is unwarranted delay in paying the customs debt to the EU (either because Revenue was unreasonably slow in pursuing the debt or because of delays in entering the debt in the accounts) the Commission can impose interest charges on Ireland. The rate of interest is significant and the rate escalates the longer the delay. These interest charges have to be met from the Exchequer. 3.6 It will be appreciated from these explanations that it essential that the rules for recording customs debts are followed correctly and that payment of customs debts are pursued promptly and without unwarranted delays. 4. Establishing the customs debt 4.1 Under EU rules, identifying an amount of duty arising from a customs debt and entering that amount in the local accounting records is known as establishing the debt. The date of entry in the accounting records, referred to as entry in the accounts, is regarded as the date of establishment of the debt. 4.2 Within two working days of a customs debt being determined, details of the sum involved must be registered electronically in ITP (see paragraph 9 for more information). The date of entry in the accounts is the date of registration and is to be regarded as the date of establishment of the debt. As the situation changes (e.g. full payment received, partial payment received, etc.) the record in ITP should be updated. (As well as registering the debt in ITP, it is recommended that a manual register in the format of that in Appendix 1 should also be maintained locally and updated as the situation changes). [Note: All unpaid debts, established before the electronic system became operational, have been transferred to ITP and changes to their status may be made electronically]. 4.3 No customs debt need be established in the following circumstances: (i) where the amount involved is less than 10.00, or (ii) where the duty is legally due but the amount exceeds that determined on the basis of binding information (BTI or BOI) and where the holder of the binding information is entitled to continue to use it for a period of 6 months after it has become invalid in accordance with Articles 12 (6) and 217 (1)(b) of the Customs Code, or 4

5 (iii) where a period of three years has elapsed since the debt was incurred. However, where the debt results from an act that could give rise to criminal court proceedings, this three year time limit does not apply (Article 221 of the Customs Code). 4.4 It should be noted that establishing a customs debt is an important legal step and that this step should not be taken if doubts remain as regards whether or not a customs debt arises. In this regard attention is also drawn to the EU rules on the Right to be Heard which allow a person to respond before an adverse decision (such as raising a customs debt) is taken against them (see the Right to be heard Manual). In any event, Customs Division (Own Resources Unit) can be consulted in any instance where there is doubt as to whether or not a customs debt needs to be established. 4.5 Where imported (non-community) goods, which have been seized and confiscated, are subsequently sold (e.g. by public auction or tender), a customs debt must be established and the amount recovered from the proceeds of the sale. The debt should be calculated by regarding the amount received as the duty paid price and calculating the duty element accordingly. The establishment of the debt and its recovery should be notified to the Office of the Accountant General in accordance with paragraph The debtor Importer 5.1 Where a customs debt has been identified post importation, the importer (as declared on the original customs entry) should normally be regarded as the debtor and collection of the liability should be pursued from the importer. Agent 5.2 Under Article 5 of the Community Customs Code, a person may appoint an agent or representative to deal with his/her customs affairs. This is the legal basis for customs clearance agents or other parties making customs declarations on behalf of an importer. 5.3 A representative may act either directly or indirectly. A direct representative acts in the name of, and on behalf of, another person, whereas an indirect representative acts in his own name but on behalf of another. In completing a customs declaration the representative/agent must state that he is acting on behalf of the individual represented and whether the representation is direct or indirect (this is achieved by inserting the appropriate code in Box 14/1 of the SAD). The agent must also be able to demonstrate, on request, that he is authorised by the importer to so act. 5.4 AEP Helpdesk Notification No.001/2011, dated February, 2011 (aep-notification provides further information regarding the status of agents in relation to import declarations, their responsibilities in relation to declarations and their identification as debtor in certain circumstances. 5.5 In practice most agents declare that they are acting in a direct capacity (i.e. a 2 in Box 14/1) which should generally be accepted at face value except where evidence to the contrary exists. The status of the agent should not be investigated further unless the importer him/herself specifically claims that the agent is liable for the debt or disputes the form of representation declared. 5

6 5.6 Where the importer specifically claims that the agent is liable for the debt it will be necessary to contact the agent to see if he/she accepts liability. In most cases this will not be the case and it will be necessary to consider the legal position under which the agent acted when making the import declaration. This will depend on the status of the agent (as per Box 14/1 of the SAD declaration) and whether the agent had the necessary authorisation from the importer to so act. The overall circumstances (see paragraph 5.11) may also need to be examined. 5.7 It should be noted that the Community Customs Code provides that an agent who makes a declaration as having authorisation to act in a direct representation capacity without being empowered to do so, is deemed to be acting in his/her own name and on his/her own behalf. The EU rules do not specify the type of authorisation required. AEP Helpdesk Notification No.001/2011 does contain a possible wording for an authorisation; however, this is only a suggestion rather than a legal requirement. Generally speaking agents are recommended to have an authorisation in writing. 5.8 It will be appreciated that the determination of the correct legal status of the agent can be difficult to determine with certainty. A situation can arise where the importer maintains the agent is liable for the customs debt and vice versa. Where this happens it is suggested that Own Resources Unit in Customs Division be consulted. In most cases it will be appropriate to continue pursuit of the debt from the importer (who will then be able to use the appeal mechanism if he/she continues to dispute liability). In some cases legal advice may be necessary to finally determine which is the most appropriate approach to follow. 5.9 In the case of one-off imports, where the goods have been purchased by private individuals (e.g. an internet purchase or similar), a situation can arise where the consignor (seller) arranges with an agent (usually an express carrier) to deliver the goods direct to the consignee (purchaser) and to take care of the necessary customs clearance arrangements to import the goods into the Community. Where this situation arises it is clear that the agent is not empowered on behalf of the consignee (purchaser). In such cases therefore the agent should normally be regarded as the debtor and the collection of the liability should be pursued from the agent in the first instance As a result of these agent/representative rules a legal situation can arise where importer and agent are jointly liable for the customs debt (e.g. where the agent is acting indirectly). In such situations the debt should initially be pursued from both parties unless it is clear that one of them is unlikely to be able to meet the debt. (Note: In this joint liability situation care should be taken when reporting the debt to the Office of the Accountant General (see paragraph 9) to ensure that, while there is more than one debtor, only one debt is recorded) The paragraphs above set out the general situation in relation to agents and the circumstances under which they (rather than the importer) may become liable for a customs debt. However, when dealing with agents it is important to bear in mind that an agent may have been provided with incorrect information by his/her principal so the situation needs to be carefully considered before reaching the conclusion that the agent is liable for payment of the debt. 6

7 6. Collection of customs debts 6.1 For the reasons outlined previously (see in particular paragraph 3 above), arrangements should be made to ensure outstanding customs debts are pursued promptly. 6.2 Following establishment of the debt, the person liable for payment is to be advised in writing and payment within 10 days is to be requested. The person is to be further advised that if payment in full is not received within the 10-day period, interest on the amount will accrue. If payment is not received within the 10-day period, a further demand, titled Final Demand should be issued, indicating that interest is now accruing and that enforcement action will be initiated if payment is not immediately received. 6.3 Article 232 of the Community Customs Code provides for the charging of interest on late payments; however, the collection of interest may be waived where it would be likely to cause serious economic or social difficulties for the debtor and satisfactory evidence is produced to that effect. The rate of interest charged is the same as that for compensatory interest in the Inward Processing procedure. At present, this rate is the 3-month money market rate shown in the monthly bulletin of the European Central Bank. This may be accessed in the Bank s website: European Central Bank by proceeding as follows: In the menu at the left hand side, click on monthly bulletin ; Scroll down and click on the relevant year and month: the rate to be used is that which was in force 2 months prior to the month in which the customs debt is established. This rate should be used for calculating the interest payable any subsequent change in the rate can be disregarded; In the PDF file which opens, click on Euro Area Statistics in the index at the left hand side; Scroll down to the Contents and then to Financial markets and go to the page titled Money market interest rates ; Read off the appropriate rate of interest in the column headed Euro Area 3-month deposits (EURIBOR). 6.4 Where there is no satisfactory response to the final demand consideration should be given to the most appropriate form of enforcement action to ensure payment of the debt. Currently the only forms of enforcement available for import duties are to seek payment through the Courts by way of civil action or to carry out an attachment. Finance Act 2010 brought import duties within the tax clearance regime so restricting the issue of a tax clearance certificate is also an option. (Note: It is the intention that the upcoming Customs Bill will bring other forms of enforcement into play for import duties). 6.5 Details of established uncollected debts should be recorded in CRS Notes. This will ensure that other Revenue staff dealing with the case will be aware that there is an outstanding customs debt in the case and may lead to possibilities for recovery. 6.6 Customs Division (Own Resources Unit) can be consulted in any instance where there is doubt about the best way to pursue the debt. 6.7 The officer who entered the debt in the accounts should continue to monitor progress in relation to collection of the debt. In the event that the initial attempt at enforcement is not successful, consideration should be given to alternative possibilities. In any event unwarranted delays in pursuing the debt are to be avoided. 7

8 6.8 If the officer becomes aware that a debtor has been judged insolvent (i.e. liquidated or bankrupted) or that an examiner has been appointed, he/she should immediately advise the Insolvency Section, Office of the Collector General, Sarsfield House, Limerick, that a customs debt exists. This will ensure that the customs debt can be taken into account in any action being taken to recover tax debts. 6.9 Collected amounts must be brought to account and details communicated immediately to the Office of the Accountant General (see Collected debts - updating short payment records, paragraph 11 below). 7. Appeals 7.1 Under EU rules the debtor has the possibility of appealing against the customs debt. The European Communities (Customs Appeals) Regulations 1995 (S.I. No. 355/95) provide for a national appeals procedure as required by Article 243 to 245 of the Community Customs Code. See Appeals Manual for further information on customs appeals. 7.2 Under Article 244 of the Community Customs Code the lodging of an appeal does not suspend collection of the customs debt and the collection procedure described in paragraph 6 must be continued pending determination of the appeal. However, where the officer considers that the disputed decision is erroneous and inconsistent with the customs legislation or that implementation of the decision might cause irreparable damage to the appellant, security to cover the debt (e.g. a bank guarantee) can be provided while the appeal is being heard. However, even this security requirement can be waived if its provision would, owing to the appellant's circumstances, be likely to cause serious financial difficulty for him/her. Where such a waiver has been authorised, evidence of the circumstances of the trader must be entered on the file. This evidence should take the form of copies of audited accounts or bank statements, however, in the absence of independent evidence, a statement from the officer regarding his/her opinion of the appellant's circumstances will suffice. In practice, Customs Division (Own Resources Unit) will advise when a valid appeal is considered to have been received and whether collection of the debt or provision of security may be waived. 8. Instalment arrangements 8.1 Article 229 of the Community Customs Code provides for the granting of payment facilities in the form of payment by instalments. Instalments may be granted in circumstances where a debtor can demonstrate that he is unable to meet the customs debt immediately. It should be noted that interest is also payable in these circumstances (see paragraph 6.3 above). It should also be noted that the granting of payment facilities in the form of payment by instalments is conditional on the provision of security to cover the amount of the debt. This condition (and the charging of interest) may, however, be waived where its application would be likely to create serious economic or social difficulties for the debtor who must provide written, substantiated, evidence to that effect. This evidence or, failing it, a note/memo signed by the case officer confirming the debtor s situation should be entered on the file. 8

9 9. Reporting of debts 9.1 From July 2011, all customs debts arising from post clearance activity, amounting to or more must be registered electronically using ITP. Under new EU reporting rules this reporting requirement also includes debts paid within 10 days of notification to the debtor. It should be noted that in ITP the words short payment have the same meaning as the words post-clearance customs debt. The following material is either exempt from or not required to be published under the Freedom of Information Act [ ] 9.2 On a quarterly basis, the AGs report all details of established debts (not paid within 10 days) to the EU Commission by means of the B Statement. 9.3 Reporting debts less than 10,000: Section 1 only of the Short Payment input screen will open when the amount of duty established is less than 10,000. Where a number of debts have been incurred by one trader or by a group of closely-related traders, and where the first four digits of the tariff codes for the goods involved in each debt are the same, the amounts should be totalled and they should be reported as one debt. Where there are a number of debts and the first four digits of the tariff codes for the goods are not the same, for each different four-digit tariff code, a separate debt must be reported. Additional details relating to the debt should be entered in the Notes field in Section 1 of the input screen, and all back-up documentation relating to the debts being reported should be held on file at the customs station for possible future scrutiny. 9.4 Reporting debts of 10,000 or more: In addition to Section 1, Section 2 of the Short Payment input screen will open for input of data where the amount of duty established is 10,000 or more. Where a number of debts have been incurred by one trader or by a group of closely-related traders, each of which is less than 10,000 but which in aggregate equal or exceed that sum, and where the first four digits of the tariff codes for the goods involved in each debt are the same, Section 2 of the input screen will also open for data. Where there are a number of debts and the first four digits of the tariff codes for the goods are not the same, for each different four-digit tariff code, a separate debt must be reported. Additional details relating to the debt should be entered in the Notes field in Section 1 of the input screen, and all back-up documentation relating to the debts being reported should be held on file at the customs station for possible future scrutiny. 9

10 10. Collection of debts receipt of payments 10.1 The trader may agree to pay the customs debt from his deferred payment account or may make payment by cheque or E.F.T. In the latter cases, the cheque/e.f.t. payment must be recorded in the trader s C&E account in ITS Where the underpayments are recovered by cheque or E.F.T., the related Short CI must be immediately input following the recording of these payments in the trader s C&E account in ITS. Where the trader indicates that the payment is to be made by debiting the trader s deferred account, the officer should check ITP to ensure that there is a sufficient balance to discharge the liability before the Short CI is input In all cases (where a short payment has been input on ITP in connection with underpayments of customs duty), the recovery of the customs duty must be accounted for by way of a Short CI (Proforma SAD type), whether relating to one or many SADs. The existing screen on ITP for the inputting of a Short CI has been enhanced to include additional validation for short payment recoveries. It is critical that a link is made between the short payment record and the Short CI at this stage as this is the only way the short payment details can be updated with the recovery details Where practical, the Short CI and SAD(s) should be cross-referenced by putting the SCI entry number in the remarks field of the SAD(s) concerned and the SAD number(s) in the comments box of the Short CI It is also important to ensure that the optional data on Short CIs (e.g. comments field) should accurately reflect the reason why the Short CI was required. 11.Collected debts updating short payment records It is important that the recovery of all or part of a customs debt is recorded promptly on ITP. This is achieved by using the Short CI functionality in ITP and ensuring that the Short CI is linked to the correct Short Payment. It is essential that the Short CI is linked to the Short Payment at this point, as this is only way the Short Payment details can be updated with the recovery details. It also ensures that the information reported to the EU by the AGs is up to date and accurate. The following material is either exempt from or not required to be published under the Freedom of Information Act [ ] 11.2 The reporting of debts which have been recovered within 10 days of notification to the debtor is done in the same fashion. The ITP system will isolate such debts, which are reported to the EU by the AGs on the A statement rather than on the B statement It should be noted that where a short payment record has been input in ITP a corrected SAD should not be used for the purpose of collecting the debt (because a corrected SAD will not update an existing short payment record). Instead, the Short CI functionality in ITP should be used by 10

11 linking the Short CI to the short payment in order to update the short payment with the collected amount. Further guidance is available on Revnet/Guidelines/AEP 11.4 Updates are required: Where all of the debt has been recovered; Where part of the debt has been recovered; and Where the record has been entered incorrectly, it may be cancelled and re-entered. Where security for a debt has been accepted, this may be recorded in the Notes field. 12. Debts which are unlikely to be recovered 12.1 Under the Own Resources legislation, Revenue is required to supply the EU Commission annually in the fourth quarter with the total amount of customs debts in the B account which case managers consider are unlikely to be recovered. To fulfil this requirement Customs Division will seek this information separately from Regions/Divisions and forward it to the Office of the Accountant General for transmission to the Commission. 13 Debts which cannot be recovered 13.1 Revenue is not obliged to make available to the EU Commission customs debts which have not been collected and which are irrecoverable for reasons of force majeure or for other valid reasons. Valid reasons in this context effectively means that the debt is suitable for write-off in accordance with the rules that apply in the case of other taxes Debts are also deemed to be irrecoverable where a period of 5 years has elapsed from the date of establishment, or from the date of conclusion of an appeal, or from the date of receipt of any partpayment of the debt Where the conclusion is reached that a debt is irrecoverable because, despite all reasonable effort, it cannot be collected, or a debt is deemed irrecoverable because five years have elapsed since establishment or an appeal or receipt of part-payment Form WO1 (Customs) (see copy at Appendix II) should be completed and signed off at the appropriate level, viz. Debt not exceeding 10,000 HEO approval, Debt not exceeding 25,000 AP approval, Debt not exceeding 50,000 PO approval, Debt exceeding 50,000 A/Sec approval following case review by PO. 11

12 13.4 The status of the debt on ITP at this stage should be updated to Write-off Requested by the user and the case file and the completed Form WO1 (Customs) should then be referred to Customs Division (Own Resources Unit) where the case will be reviewed. The purpose of this review is primarily to consider whether it is necessary to pay the import duties to the EU notwithstanding the fact that it has not been possible to collect the debt. Failure to satisfactorily justify the decision to write-off could result in the EU Commission seeking payment of the debt from the Exchequer In addition, where the amount of the debt exceeds 50,000, formal application must be made to the EU Commission for approval of the decision to write-off the debt. Where necessary, this application will be made by Customs Division (Own Resources Unit) If write-off is approved, the status should be updated to Written Off by the user. The following material is either exempt from or not required to be published under the Freedom of Information Act [ ] 13.7 In line with the approach in other taxes, all proposals to write-off debts will be submitted by Customs Division (Own Resources Unit) for the approval of the Chairman. 12

13 APPENDIX I REGISTER OF CUSTOMS DEBTS [NB Details of the debt and changes in relation to that debt must be recorded in ITP see paragraph 9 above. This document is intended to be used as a local record only] Date Duty Liability Established Importer/ Exporter and Agent SAD Number Description of Goods including Tariff Codes Type of Duty Amount of Duty Recovery position Remarks 13

14 APPENDIX II WO1 Form WO1 (Customs) Proposed write off - Import Duty Debtor s Name: Trading As: Address: Tax Ref.: Shortpayment Ref: Please provide the following information. 1. Amount of customs duty proposed for write off:. 2. Circumstances giving rise to this customs debt: 3. Action taken to collect the debt: 4. List any outstanding liabilities and / or amounts written off in other tax heads: 5. The specific reason why the customs debt is declared to be irrecoverable: The proposal that the customs duty is irrecoverable is made by: Caseworker : Grade VPN Date Supervisor: Grade VPN Date In Agreement: Grade VPN Date 14

15 APPENDIX III CODE TO BE USED TYPES OF FRAUD OR IRREGULARITIES 70 Smuggling and the like 701 Smuggling and the like 702 Smuggling Seized and confiscated goods 71 Import/export without declaration 711 Import without declaration 712 Export without declaration 72 False declaration 721 Incorrect origin or country of dispatching 722 Incorrect value 723 Incorrect classification/misdescription 724 Other incorrect commercial documents 725 Other cases of irregular documents 726 Incorrect use of preferential arrangements 73 Fraud and irregularities in the transit procedure 731 External transit - T1 document 733 Internal transit - T2 document 735 TIR system 737 Other abuses of the arrangements governing the movement of goods 738 Customs warehousing 74 Failure to meet commitments and fraudulent practices 741 Failure to fulfil commitments entered into 742 Abuse of end-use 743 Unjustified claim to customs procedure 744 Removal of goods from customs control 745 Failure to observe a customs procedure 746 Failure to observe quotas 749 Other 75 Incorrect estimation of duties 751 Error in calculating customs duties 752 Error in calculating compensatory levies or anti-dumping duties 754 Error involving rates, coefficients, exchange rates 76 Irregularities involving the sugar levy 760 Any irregularity involving sugar levy 79 Other 791 Counterfeiting and piracy (subsidiary code) 15

16 APPENDIX IV CODE TO BE USED CUSTOMS PROCEDURE CONCERNED 01 Inward processing 02 Outward processing and standard exchange system 03 Processing under customs control 04 Temporary admission 05 Customs warehousing 06 Free zone or free warehousing 07 Release for free circulation 09 Community transit 10 Exportation 11 Re-exportation 12 Destruction 13 Abandonment to the Exchequer 16

17 APPENDIX V CODE TO BE USED METHODS OF DETECTION & CONTROL 104 Tax audit 207 Audit of the accounts 301 Voluntary admission 70 Primary national inspections 700 Comprehensive (basic) physical inspection 701 Individual (detailed) physical inspection 702 Physical inspection after preselection 703 Physical inspection after preselection and sampling 704 Normal inspection of documents 705 Normal inspection of preselected documents 706 Physical inspection of goods placed under the arrangements governing the movement of goods. 709 Other primary national inspection 71 Post-clearance national inspections 711 Inspection on operator s premises 712 Check of observance of customs or other procedure 713 Check of observance of transit procedure 714 Inspection of transit documents 715 Inspection at request of other Member State 716 Inspection of documents requested by other Member State 717 Inspection of documents requested by issuing country 719 Other national post-clearance inspections 72 Inspections by fraud-prevention authorities 721 Inspection by local investigation offices 722 Inspection by regional investigation offices 723 Inspection by central investigation offices 729 Other inspections by anti-fraud services 73 Inspection 731 Inspection by general customs inspection service(s) 732 Inspection by services or bodies other than customs 74 Community controls 741 Associated inspections 742 Autonomous inspections 17