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EU Importers: Handling Express Bills of Lading

EU Regulation Deep-Dives 8 min read
EU Importers: Handling Express Bills of Lading

Quick answer

An express bill of lading (express BOL) is a simplified customs document used in the EU to facilitate faster clearance of goods under specific conditions. EU importers using express BOLs must comply with detailed identification, documentation, and procedural requirements to ensure customs compliance and benefit from streamlined import processes.

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Key takeaways

  • An express BOL is a customs document enabling expedited clearance for certain shipments within the EU single market.
  • The procedure applies primarily to importers who receive goods under express BOL terms and to exporters authorised as approved exporters.
  • Importers must provide accurate identification numbers such as EORI and ensure proper documentation accompanies shipments.
  • The role of the approved exporter is crucial in issuing invoice declarations and guaranteeing the origin of goods.
  • Importing by instalments under express BOLs requires submission of a single proof of origin for qualifying goods.
  • Compliance with Union Customs Code rules and national customs authorities’ conditions is mandatory for express BOL use.
  • Best practices include verifying exporter status, maintaining accurate records, and timely customs declarations.

Defining the Express Bill of Lading in an EU Context

In the context of the European Union, an express bill of lading (express BOL) refers to a customs-related document that expedites the importation process by simplifying the required paperwork and customs formalities. It is a form of transport document that, when combined with specific customs authorisations and procedures, allows for faster customs clearance of goods entering the EU single market.

The express BOL is distinct from a traditional bill of lading (BOL) in that it is linked to customs simplifications that reduce the administrative burden on importers and exporters. This document often forms part of a broader customs procedure designed to facilitate trade flows, especially for frequent shipments or goods originating within preferential trade arrangements.

The express BOL serves both as evidence of the contract of carriage and as a document supporting customs declarations. It is particularly relevant where the exporter holds approved exporter status, enabling invoice declarations to be made without the need for full certificates of origin for each shipment, thus streamlining customs processes [1].

Who is Affected by Express BOL Procedures?

Express BOL procedures primarily affect the following parties:

  • EU Importers: Companies or individuals receiving goods into the EU single market who rely on express BOLs to facilitate quicker customs clearance.
  • Approved Exporters: Exporters established within the EU customs territory who have been authorised by customs authorities to issue invoice declarations for products originating in the Union. These exporters provide guarantees regarding the origin and compliance of goods, enabling the use of express BOLs [1:1].
  • Customs Authorities: National customs administrations in EU Member States that oversee the authorisation, monitoring, and enforcement of express BOL procedures.

The procedure is relevant for importers dealing with frequent shipments of Union-originating products or those benefiting from preferential trade arrangements. It also applies to importers who receive goods in instalments, subject to the conditions laid down by the customs authorities of the importing Member State [2].

Key Obligations for EU Importers Using Express BOLs

EU importers using express BOLs must adhere to several concrete obligations to ensure compliance with the Union Customs Code and its implementing regulations:

  1. Accurate Identification: Importers must provide the EORI number (Economic Operators Registration and Identification) of the exporter or consignor as required in customs declarations. Where the exporter lacks an EORI number, a Member State may assign an ad hoc number for the declaration concerned [3].

  2. Documentation: Importers must ensure that the express BOL is accompanied by the necessary supporting documents, including invoice declarations issued by approved exporters. These declarations confirm the origin of the goods and compliance with preferential trade rules [1:2].

  3. Customs Declarations: Importers must submit customs declarations containing all required data elements, including the full name and address of the last seller and consignor, the exporter’s authorisation number if applicable, and the relevant commodity codes [3:1].

  4. Proof of Origin: When goods are imported by instalments, a single proof of origin must be submitted upon importation of the first instalment, provided the goods fall within specified Harmonised System sections or headings [2:1].

  5. Compliance with Conditions: Importers must comply with any conditions imposed by the customs authorities of the importing Member State, including those related to the timing and manner of submitting customs declarations and supporting documents [2:2].

Failure to meet these obligations may result in delays, penalties, or withdrawal of customs simplifications.

The Role of the Approved Exporter in Express BOL Shipments

The approved exporter plays a pivotal role in shipments involving express BOLs. According to Commission Implementing Regulation (EU) 2015/2447, an approved exporter is an exporter established within the EU customs territory who frequently ships products originating in the Union and who offers sufficient guarantees to customs authorities regarding the origin and compliance of those products [1:3].

Key responsibilities of the approved exporter include:

  • Issuing Invoice Declarations: The approved exporter is authorised to make out invoice declarations irrespective of the value of the products concerned. This replaces the need for full certificates of origin for each shipment, simplifying customs formalities.
  • Guaranteeing Origin: The exporter must provide guarantees that the products meet the origin criteria set out in the relevant preferential trade arrangements.
  • Maintaining Authorisation: Customs authorities assign an authorisation number to the approved exporter, which must appear on invoice declarations. Authorities monitor the use of this authorisation and may withdraw it if conditions are not met or if misuse occurs [1:4].

For EU importers, dealing with an approved exporter means benefiting from streamlined customs procedures and reduced documentary requirements when using express BOLs.

Identification Numbers and Documentation Requirements

Identification numbers, particularly the EORI number, are fundamental to the express BOL process. The EORI number identifies economic operators involved in customs activities within the EU and must be correctly included in customs declarations.

  • Exporter Identification: The EORI number of the exporter or consignor must be entered in the customs declaration. If the exporter does not have an EORI number, the customs administration may assign an ad hoc number for the specific declaration [3:2].
  • Consignor Identification: The consignor’s full name and address must be provided, especially when acting as the exporter in trade with special fiscal territories [3:3].
  • Data Accuracy: Customs declarations must include accurate and complete data according to the data requirements tables, covering exporter, consignor, and last seller details [3:4].

Documentation accompanying express BOL shipments typically includes:

  • The express bill of lading itself.
  • Invoice declarations issued by approved exporters, including the customs authorisation number.
  • Proof of origin documents, especially for preferential tariff treatment.
  • Customs declarations filed with the relevant national competent authority.

Ensuring that these identification numbers and documents are accurate and complete is essential for smooth customs clearance.

Importing by Instalments with Express BOLs

Importation by instalments is a procedure whereby dismantled or non-assembled products, falling within certain Harmonised System sections or headings, are imported in multiple shipments. Under the express BOL procedure, importers may submit a single proof of origin for all instalments, provided they comply with conditions set by the customs authorities of the importing Member State [2:3].

This approach reduces the administrative burden on importers by avoiding the need to submit proof of origin with each instalment. However, it requires:

  • A formal request by the importer.
  • Compliance with customs authority conditions.
  • Submission of the proof of origin upon importation of the first instalment.

This procedure is particularly relevant for goods classified under Sections XVI and XVII or headings 7308 and 9406 of the Harmonised System, which often include metal products and furniture [2:4].

Compliance and Best Practices for EU Importers

To maintain compliance and optimise the use of express BOLs, EU importers should adopt the following best practices:

  • Verify Exporter Status: Confirm that the exporter is an approved exporter authorised to issue invoice declarations under the relevant customs procedures [1:5].
  • Check Identification Numbers: Ensure that all EORI numbers and other identification codes are accurate and included in customs declarations [3:5].
  • Prepare Complete Documentation: Maintain all necessary documents, including express BOLs, invoice declarations, and proof of origin, readily available for customs inspection.
  • Understand Instalment Import Rules: If importing by instalments, verify that the single proof of origin procedure is properly requested and accepted by the customs authorities [2:5].
  • Monitor Customs Notifications: Stay informed of any conditions or changes imposed by the national competent authority regarding express BOL use.
  • Maintain Records: Keep detailed records of all shipments and customs declarations to facilitate audits and compliance verification.

Adhering to these practices helps ensure that express BOL shipments are processed efficiently and in accordance with EU customs regulations.

Next steps

  1. Confirm whether your exporters hold approved exporter status and obtain their customs authorisation numbers.
  2. Verify the EORI numbers of all parties involved in your express BOL shipments and ensure they are correctly entered in customs declarations.
  3. Collect and review all required documentation, including invoice declarations and proofs of origin, before submitting customs declarations.
  4. If importing dismantled or non-assembled goods by instalments, formally request acceptance of a single proof of origin from the relevant customs authority.
  5. Submit accurate and complete customs declarations to the relevant national competent authority, ensuring compliance with express BOL procedures.

FAQ

What is an express BOL?
An express BOL (express bill of lading) is a simplified customs document used within the EU to facilitate faster customs clearance by reducing paperwork and allowing approved exporters to issue invoice declarations instead of full certificates of origin [1:6].

What does BOL mean in delivery?
BOL stands for bill of lading, a legal document issued by a carrier to acknowledge receipt of cargo for shipment. It serves as a contract of carriage and a document of title for the goods [3:6].

What is the difference between BL and Express BL?
A traditional bill of lading (BL) is a standard transport document, while an express bill of lading (express BOL) is linked to customs simplifications allowing faster clearance, often involving approved exporters and invoice declarations instead of full certificates of origin [1:7].

What does BOL mean in shipping?
In shipping, BOL means bill of lading, which is a document issued by a carrier to confirm that goods have been received for transport. It outlines the terms of carriage and is essential for customs clearance and delivery [3:7].

Sources


  1. Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 laying down detailed rules for implementing certain provisions of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union Customs Code, Article 120

  2. 2013/94/EU: Council Decision of 26 March 2012 on the conclusion of the Regional Convention on pan-Euro-Mediterranean preferential rules of origin, Article 25

  3. Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council as regards detailed rules concerning certain provisions of the Union Customs Code

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