Monitoring AEO Status: Key Requirements for Maintaining and Securing Certification in Day-to-Day Practice

AEO (Authorized Economic Operator) certification, or “trusted partner of the customs authority,” is currently held in Romania by over 250 companies – importers, exporters, customs agents, or carriers.

By Mihai Petre, Director, International Trade, EY Romania, and Cosmin Dincă, Manager, International Trade, EY Romania

How important are the requirements for maintaining certification? For example, after 3 years from the authorization date, is a company still considered a trusted AEO certified partner? The answer to this question is clarified by the European Commission through the Customs Code and related guidelines, which stipulate the obligation to fully or partially reevaluate the conditions that led to the certification, based on regular monitoring by both the economic operator and the customs authority.

In the case of an authorized economic operator, monitoring must be integrated into their internal control processes. Specifically, they should be able to demonstrate how this monitoring is continuously carried out and what its results are. For example, if there are changes in internal procedures, new IT systems, changes in ownership, or changes in employees responsible for customs or security processes, these must be immediately communicated to the customs authority, which decides whether a total or partial reevaluation is necessary.

In recent years, there has been a consistent practice by the customs authority to continuously verify the fulfillment of these criteria by companies applying for AEO certification, especially those subject to reevaluation. Specifically, such companies must designate a person responsible for disseminating AEO requirements within the respective company and ensuring that all relevant departments comply with the requirements to which the AEO holder claims to adhere (e.g., supply chain security requirements).

Maintaining AEO certification is extremely important, as companies benefit from several advantages in their day-to-day customs activities. For example, the deferral of VAT payment on imports applies directly to those holding AEO status without the need for a separate, recently reduced-term certificate, which went from 12 to 6 months. This change was made precisely to give the customs authority better visibility over those benefiting from this cash flow facility who do not hold AEO certification. It would not be surprising if the decision were made to discontinue this facility for companies that do not hold AEO certification. Among other benefits, we mention the reduction of the overall customs guarantee to 30% of the amount, easier access to special regimes (e.g., temporary storage) or customs simplifications, as well as fewer physical inspections.

In conclusion, it is recommended that importers analyze and implement AEO status monitoring requirements in advance to avoid the risk of losing authorization and, consequently, associated benefits.