The VNACCS/VCIS “Vietnam Single Window” customs system was established in 18 months, a relatively short period, and we feel that we need a period of training, testing, and de-bugging before mandatory implementation. Both customs officials and business users need to understand the system, to minimize errors through training and/or modifications of the system.
Below is a summary of concerns we expressed to Vietnam Customs regarding the April 1, 2014 implementation of VNACCA/VCIS.
“Thanks to participation in a number of Customs-Business Dialogues, most recently on November 29, 2013 in HCM City, we have received some feedback from our members concerning the VNACCS/VCIS implementation, much of it positive, but with some concerns as well. With little time remaining, we would like to share with you some of the main concerns and our key recommendations.
“The system was established in an 18-month period from the signing of the contract with NTT Data on September 12, 2012 and mandatory implementation on April 1, 2014. This is a relatively short period, and we feel that we need a period of training and testing from an interface/user point of view and the systems architecture before mandatory implementation. Both customs officials and business users need to understand the key areas and errors that users are making, so we can minimize those through increased training and / or modification of the interface.
“We believe there should be a “grace period” or moratorium before applying sanctions in the form of administrative fines or penalties due to inadvertent errors based on misunderstandings by users or instances of noncompliance by importers, exporters, customs brokers or logistics providers caused by systems issues; the moratorium should last until 270 days (three quarters of a year) after defined targets, such as publication of the circular(s) providing regulatory guidance, and testing of the system based on a statistically appropriate sample of users under the principle of customs risk management.
“Starting as soon as possible, and continuing up until the end of the moratorium, we would deeply appreciate a strong Customs-Business Partnership, with dialog meetings by Vietnam Customs with both Vietnamese and FDI enterprises on a regular monthly basis, and an extensive public outreach education and training to ensure that companies fully understand all new legal requirements of VNACCS/VCIS. ”
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