CINOA supports the provision of any help and resources aimed at its members – which are small companies – to help them apply what is complex legislation. However, it appears that the published note seems to be more adapted to national authorities than in practical terms to a sector that needs to be supported.

In any case, it would be helpful if the 43 questions in the Q&A were to be organised by topic. In particular, the document alternates back and forth between import licences and importer statements in a way that readers unfamiliar with the text of the regulation may find confusing.

Given the importance of this document for the national authorities, we make the following recommendations and comments download document