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Creating significant duty savings: autonomous tariff suspension and quotas

07 May 2019
On 17 April 2019, the Commission published a notice in the Official Journal of the European Union (EU) informing economic operators of the various requests it received for this half-yearly round of autonomous tariff suspensions and quotas.  The deadline for objections against the new requests is 12 June 2019.

The multi-annual suspension of EU import duties for an unlimited quantity (called tariff "suspension") or for a limited quantity (called tariff "quota") allows the total or partial waiver of the EU import duties, thereby contributing to significant savings for EU manufacturers that import raw materials or semi-finished products. Tariff suspensions are only granted to products that are not produced in the EU.  If they are produced but not in sufficient quantities to cover the entire domestic demand, a duty-free tariff rate quota may be granted by the EU.

Our International Trade Team here in Brussels has invaluable experience representing businesses on both sides: assisting several EU manufacturers in filing suspension/quota applications to realise cost savings or, conversely, in objecting against tariff suspensions/quotas requested by others.  For applicant EU manufacturers, we conduct an audit of imported materials to assess the possibility to request new tariff suspensions or to take advantage of existing suspensions or unutilised tariff quotas.  We then take all required action before the EU institutions (European Commission's DG TAXUD and Member States' representatives in the Economic Tariff Questions Group - ETQG) to ensure success. This results in significant cost savings for applicants.  For EU objectors, we closely monitor the new suspension/quota applications lodged by others and object whenever suspensions are requested for EU-produced goods or quotas are requested for unjustifiably high quantities. Apart from the mechanics of the procedure, we maintain an excellent working relationship with the DG TAXUD staff and the ETQG members.

This EU administrative procedure takes place twice a year.  Once completed, the list of suspension/quota requests is published.  If no objections are lodged by EU manufacturers, the requested tariff suspension or quota is usually granted.  By way of an example, we attach a partial list of the most recent requests under Chapter 29 (organic chemicals) of the EU's customs combined nomenclature.  Several other chapters of imported goods are included in the most recent list.

Either as an applicant to obtain a suspension/quota or as an objector to stop a suspension/quota that adversely affects your interests, tariff suspensions and quotas significantly impact the competitiveness of EU manufacturers and form a potent industrial tool.

For more information on tariff suspensions and quotas, feel free to contact our team below.

Further Reading