Thai AEO & MRA (1/2)

CBRA carried out an AEO&MRA study for the Royal Thai Customs during 2012-13, it becomes public this week. Here is a sneak preview of the key results.

Mandate for the “Authorized Economic Operator, AEO & Mutual Recognition Agreements, MRA” -study came in fall 2012 from the Delegation of the European Union to Thailand, as part of Thailand-EU Cooperation Facility Phrase II (TEC-II), Policy Support Dialogue Component (PDSC) on “Implementation of international standards on Supply Chain Security leading to a secure Trade Environment and to increased Trade Facilitation” (Activity Code : TRA 4). This followed the request from the Royal Thai Customs, RTC asking for a technical assistance with two main objectives:

• Assisting Royal Thai Customs, RTC, to improve the popularity of the Thai AEO program among the economic operators.
• Guiding RTC in preparing for a future AEO MRA negotiations, primarily with the European Union / European Commission Directorate General of Customs and Taxation (EC DG TAXUD) by conducting gap analyses between the Thailand and the EU AEO scheme and recommending a roadmap for the future MRA.

This week´s CBRA blog entry comes in two parts: today Monday we share the summary recommendations regarding the first question: How to make AEO more attractive for economic operators in Thailand? Below is the recommendation list with seven main action points, with up to four sub-points under each recommendation:

1.Make the application process as smooth, low cost and fast for the economic operators as possible:

• Expand on current RTC AEO-guidelines, with more detailed content on what is expected from the economic operators; examples on how to comply in a cost-efficient and security-efficient manner and so forth.
• Recognize existing governmental and business certifications, authorisations and standards as part of the AEO approval process; and encourage companies to exploit their existing security policies, guidelines and work instructions during the process.
• Consider exemptions on AEO requirements for Small and medium sized enterprises, SMEs, due to the nature of their business and operations, which can differ significantly to those of large and especially multinational companies.
• Ensure that “effective and efficient supply chain security measures” are encouraged and appreciated during the process; this might require some internal crime prevention and security management training, covering also organizational management aspects of supply chain security, with RTC AEO staff.

2.Invest in systematic design, implementation and monitoring of AEO-benefits / incentives:

• Consider a broad portfolio of benefits and incentives to AEO companies, in particular company-level benefits and shipment-level benefits granted directly by RTC.
• In particular, analyse carefully AEO benefit suggestions by key internal organisations, including World Customs Organisation and International Chamber of Commerce, while considering their feasibility in Thai AEO context.
• Ensure that AEO status of companies is explicitly recognized within RTC risk management, assessment and profiling procedures, especially within the risk management information systems and tools.
• Establish a system for continuous measurement and improvement of AEO benefit delivery towards the AEO companies in Thailand; this should be done in close co-operation with Thai industries, including key Thai industry associations.

3.Drive towards multi-agency co-operation “under the RTC AEO-umbrella”:

• First study current developments for example in the EU and in the US, particularly with aviation security and food inspection agencies.
• Get together one or more other Thai agencies – e.g. food safety and/or aviation security – and start exploring co-operation options and requirements, including legal frameworks required; and consider first steps in operationalization in terms of how to avoid duplications in company applications, audit visits, shipment inspections and so forth.
• Establish first pilot project with one select agency, and a handful of Thai companies; expand after that, based on lessons learned during the pilot, as well as based on a broader framework on “intra-agency collaboration, and how that can benefit economic operators in the future”.

4.Consider shifting towards system-based and audit-based principles and practices

• Aim to complement and/ or replace transaction-based approaches with systems-based and audit-based approaches in the future.
• Aim to remove barriers, and aim to enforce drivers, when it comes to e-customs development and adoption among the Thai economic operators.

5.Consider expanding to additional types of actors eligible for AEO-status

• Start expansion towards the logistics sector, including freight forwarders, transport carriers and warehouse keepers.
• While expanding especially to the logistics sector, consider the specific risk factors and their implications to security requirements per actor type, e.g. in postal logistics.

6.Continue and possible expand in active interaction with Thai industries

• Discuss regularly on security requirements, if they make sense for the variety of economic operators; procedures throughout AEO lifecycle, if they could be further streamlined; AEO benefits, if they could be expanded and made more concrete; and so forth.
• Use models and tools from literature to facilitate discussions and opinion sharing, also to discuss on differing stakeholder interests.

7.Start driving towards several AEO MRAs with third countries and regions

…. The second blog entry on this topic (part 2/2), to be published on Thursday this week, will focus on the MRA related recommendations. We plan also to make the full report downloadable from the CBRA web-site, by the end of this week.

PS. More information on the PICARD program can be found at: http://www.wcoomd.org/en/topics/capacity-building/activities-and-programmes/cb_picard_overview.aspx