Customs procedures as a SEZ preference: things to know
If a company opts for SEZ as a localization site, it intends to use the preferences provided by SEZ tenant status. However, even the most convenient tools must be learned to be used properly.
Olga Kovaleva, Temporary Storage Warehouse Director in SEZ Technopolis Moscow
To begin with, getting a tenant status does not imply automatically getting the right to adopt the procedures of a special customs zone. The tenant status is only a ground for application. Learn more about how to become a SEZ tenant here.
In other words, a tenant has the right to apply to a customs authority for a permit to adopt these procedures. For that there are several consecutive steps to be made.
The first step for a tenant is applying to the customs authority to get the requirements for setting up a customs control zone within their territory so that the procedures of a special customs zone could be adopted.
When designing the special customs zone area, it is crucial to satisfy all of the requirements to the infrastructure of the SEZ area and SEZ tenants’ land plots as per part 4 of paragraph 37.2 of Federal Law N 116-FZ dated 22.05.2015 “On Economic Zones in the Russian Federation” and Order N 817 of 30.04.2015 of the Federal Customs Service.
In simple words, you have to read the law to know exactly what you will have to face. For example, not everyone knows that there are three options of setting up a location for a customs control zone – a standalone building, a building with adjacent territory, and a part of a building, and the whole customs control zone has to be under video surveillance. Now, imagine a tenant wanted to set up a customs control zone within a building with one entrance. It is most likely that the Federal Customs Service will demand that cameras be installed in all of the rooms within these building. Not only will everyone inside end up being constantly watched by customs service officers, but also any kind of delivery – be it stationary or pizza – will have to be documented in a special way since delivering to a customs control zone is actually like delivering to a customs post at the border. Is it convenient? Of course not. This is why you have to put a lot of thinking into setting up a customs control zone.
At this stage I suggest you consult a specialist in the area. This will help you save your nerves and time. Any SEZ managing company has a specialized department for such matters.
The second step is to start implementing the requirements. It is important to understand that there can be different requirements to different types of production, which is why it’s no use trying to analyze someone else’s experience and apply it to your own company.
The third step is to pass the inspection of the customs control zone territory by the Federal Customs Service commission. This is quite a fast procedure if a tenant has fulfilled all of the requirements. Otherwise the commission can demand refitting of the territory.
The fourth step is issuing a Federal Customs Service order allowing the tenant to adopt customs controlled zone procedures. This takes a month, and after the order is issued and has come into force, your customs controlled zone can start functioning.
And the most important thing: the process of getting a permit for adopting the customs controlled zone procedures is very long and complicated. Before making this decision it may be best to calculate its economic efficiency and decide on the pricing matrix of output production made in the customs controlled zone. This, however, is a topic for a separate article.
SEZ "Technopolis "Moscow" is a subordinate structure of the Department of Science, Industrial Policy and Entrepreneurship of Moscow.