EOCC second contribution on TRACES

Considering that Control bodies will be in front line in the implementation of TRACES, EOCC follows-up closely the discussions on the design and implementation of TRACES. EOCC generally welcomes the introduction of eletronic certificates of imports. In this contribution, it raises some concerns about the amendements to Reg. 889/2008 and Reg. 1235/2008 which provide for the introduction of TRACES.

Specific remarks are made on the following issues:

Definition of processed/unprocessed products

Provisions leading to uncertainty on the definition of “exporter”

Cases of force majeure and exceptional circumstances

Access rights to and use of TRACES

Issuance of the certificate

Link to OFIS

Changes in products’categories (Annex IV)