IMI: HOW TO WORK WITH RUSSIAN CUSTOMS AT ST. PETERSBURG'S PULKOVO AIRPORT

1. SUMMARY: ON FEBRUARY 17, 1995 FCS ST. PETERSBURG ATTENDED THE SEMINAR "HOW TO WORK WITH RUSSIAN CUSTOMS" IN ST.PETERSBURG, RUSSIA. THE SEMINAR WAS ORGANIZED BY CABNIS GRANTEE THE WORLD TRADE INSTITUTE OF THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, AND THE ST. PETERSBURG UNIVERSITY OF ECONOMICS AND FINANCE. THE SESSION FEATURED GUEST SPEAKERS FROM THREE CUSTOMS HOUSES IN ST. PETERSBURG. THE FOLLOWING IS AN OVERVIEW OF CUSTOMS ISSUES COVERED BY THE PULKOVO AIRPORT CUSTOMS REPRESENTATIVE, AS WELL AS KEY CONTACTS. END SUMMARY.

2. ON FEBRUARY 17, 1995 CO MAY AND FSN MINKEVICH ATTENDED THE SEMINAR "HOW TO WORK WITH RUSSIAN CUSTOMS", IN ST. PETERSBURG, RUSSIA. THE SEMINAR WAS ORGANIZED BY THE WORLD TRADE INSTITUTE OF THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY (PANY), AND THE ST. PETERSBURG UNIVERSITY OF ECONOMICS AND FINANCE. PANY IS ONE OF THREE CABNIS GRANTEES IN ST. PETERSBURG WHICH HAS AN ONGOING CURRICULUM OF TRAINING SEMINARS THROUGH ITS WORLD TRADE INSTITUTE. THREE FEATURED SPEAKERS GAVE PRESENTATIONS ON ISSUES PERTAINING TO SEA AND RAIL CUSTOMS, CUSTOMS CHECKS ON BORDER CROSSINGS AND CUSTOMS ISSUES AT ST. PETERSBURG'S PULKOVO AIRPORT. OTHER SPEAKERS INCLUDED LOCAL BUSINESS PEOPLE WHO PROVIDED INSIGHT ON THEIR EXPERIENCES WORKING WITH RUSSIAN CUSTOMS. THERE ARE THREE MAJOR CUSTOMS HOUSES IN ST. PETERSBURG: BALTIC CUSTOMS (SEA CARGOS), PULKOVO AIRPORT CUSTOMS (AIR CARGOS), ST. PETERSBURG CUSTOMS (INTERNAL CUSTOMS, GROUND- TRANSPORTED CARGOS, PASSENGER CARGOS AND BAGGAGE), THIS REPORT FOCUSES ON TOPICS COVERED BY THE PULKOVO AIRPORT REPRESENTATIVE INCLUDING SOME GENERAL RUSSIAN CUSTOMS ISSUES.

3. MR. ALEXANDER PUCHKOV, DEPUTY CHIEF OF PULKOVO AIRPORT CUSTOMS GAVE A PRESENTATION ON MAJOR ISSUES WHICH FOREIGN COMPANIES SHOULD CONSIDER FOR SUCCESSFUL RELATIONS WITH RUSSIAN CUSTOMS. MR. PUCHKOV NOTED THAT IN GENERAL, RUSSIAN CUSTOMS LEGISLATION IS ANALOGOUS TO EUROPEAN LEGISLATION BUT IN ADDITION, IT HAS MORE CUSTOMS MODES AND MORE PREFERENTIAL DUTIES. IT ALSO HAS MANY PROBLEMS. ACCORDING TO MR. PUCHKOV, THE MAIN PROBLEM IS THAT RUSSIAN CUSTOMS ARE SUBJECT TO TOO MANY DECREES, RULES, LAWS, CIRCULARS, AND OTHER REGULATIONS WHICH ARE OFTEN WRITTEN IN VAGUE AND AMBIGUOUS LANGUAGE. THIS DEARTH OF LEGISLATION OFTEN SLOWS THE CUSTOMS PROCESS AND CAUSES CONFUSION IN DETERMINING THE APPROPRIATE LAWS TO APPLY. ALSO THERE ARE MANY RUSSIAN GOVERNMENT DIRECTIVES WHICH CONTRADICT ONE ANOTHER. HE GAVE THE FOLLOWING EXAMPLE: UNDER CUSTOMS LEGISLATION, THE TEMPORARY IMPORTATION MODE PROVIDES FOR DUTY FREE IMPORTATION OF GOODS FOR A PERIOD UP TO TWO YEARS FOR SHORT TERM VISITORS TO RUSSIA. CUSTOMS MODES CAN BE CHANGED BY CONSIGNEE AT ANY TIME BY PAYMENT OF DUTIES IN ACCORDANCE WITH THE RATES ON A DATE APPLIED. HOWEVER, A LETTER OF THE STATE CUSTOMS COMMITTEE SAYS THAT IN SUCH CASE IT IS ALSO NECESSARY TO PAY PENALTY CHARGES FOR THE PERIOD OF DELAY FOR DUTIES PAYMENT. IN SUCH CASES, MR. PUCHKOV ADMITS THAT CUSTOMS OFFICERS DO NOT KNOW WHICH REGULATION TO APPLY.

4. IN GENERAL, THE PROCEDURE FOR PASSING THROUGH RUSSIAN CUSTOMS CONTROL IS DIVIDED INTO THE FOLLOWING FIVE STAGES:

THE FIRST STAGE INVOLVES OFFICERS OF THE CUSTOMS DEPARTMENT FOR STATISTICS. THEY CHECK THE ACCURACY OF CUSTOMS DOCUMENTATION AND ASSIGN A REGISTRATION NUMBER.
THE SECOND STAGE INVOLVES OFFICERS OF THE CUSTOMS DEPARTMENT FOR CUSTOMS COST AND CURRENCY CONTROL. THEY CHECK THAT THE GOODS AND THEIR COSTS CORRESPOND TO THE CUSTOMS DOCUMENTAT ION.
THE THIRD STAGE INVOLVES OFFICERS OF THE CUSTOMS DEPARTMENT FOR CUSTOMS PAYMENTS. THEY CONFIRM WHETHER THE CORRECT AMOUNT OF DUTIES ARE PAID TO CUSTOMS.
THE FOURTH STAGE INVOLVES OFFICERS OF THE CUSTOMS CARGO DEPARTMENT. THEY INSPECT THE GOODS TO BE IMPORTED AND MAKE A DECISION WHETHER TO ALLOW GOODS INTO RUSSIA.
THE FIFTH STAGE ALSO INVOLVES OFFICERS OF THE CUSTOMS DEPARTMENT FOR STATISTICS WHO RECHECK THE CORRECTNESS OF THE COMPLETED DECLARATION AND USE THE DATA FOR THE PURPOSE OF COMPILING STATISTICS.

4. SINCE THIS PROCEDURE CAN BE TIME CONSUMING (UP TO ONE WEEK) MR. PUCHKOV STATED THAT THE PULKOVO CUSTOMS HAS CHANGED ITS PROCEDURES. DUE TO THE NEED FOR QUICK CUSTOMS CLEARING OF AIR CARGOS, PULKOVO CUSTOMS HAS A SIMPLIFIED PROCEDURE WHEREBY USUALLY ONLY ONE CUSTOMS OFFICER FORMALLY CHECKS THE CARGO AND DOCUMENTATION AND MAKES A DETERMINATION WHETHER TO ALLOW THE GOODS TO ENTER RUSSIA. AFTER THAT, CUSTOMS PROCEEDS WITH A DETAILED CHECK OF DOCUMENTATION. IN SPITE OF THE VISUAL EASINESS OF THE REVISED PULKOVO PROCEDURE, MR. PUCHKOV WARNED CONSIGNEES TO BE CAREFUL IN COMPLETING DOCUMENTATION. IF THE GOODS HAVE ALREADY PASSED THROUGH THE CUSTOMS CONTROL, THERE IS NO WAY BACK AND THE CONSIGNEE WILL BE RESPONSIBLE UNDER CURRENT RUSSIAN LAW IN THE EVENT CUSTOMS FINDS ANY DISCREPANCY IN THE SUBMITTED DOCUMENTS DURING THEIR DETAILED INSPECTION.

5. IN ORDER TO HELP THEIR CLIENTS PASS THROUGH CUSTOMS CONTROL, RUSSIAN CUSTOMS HAS SET UP A NETWORK OF CUSTOMS BROKERS WHICH INCLUDES RUSSIAN AND FOREIGN FIRMS PROVIDING A FULL RANGE OF CUSTOMS SERVICES. THESE SERVICES ARE NOT FREE OF CHARGE. IF A CLIENT DOES NOT WANT TO PAY FOR CUSTOMS FACILITATION SERVICES, THEY CAN APPLY TO THE ST. PETERSBURG CUSTOMS INFORMATION SERVICE, ALTHOUGH MR. PUCHKOV COULD NOT GUARANTEE THE QUALITY OF THEIR SERVICES. IN CASES OF COMPLICATED CUSTOMS PROBLEMS WHEN THE CONSIGNEE AND CUSTOMS OFFICER CAN NOT REACH A COMMON CONCLUSION, HE RECOMMENDS THAT THE CONSIGNEE APPLY TO THE REGIONAL CUSTOMS ADMINISTRATION BY SENDING AN OFFICIAL LETTER- REQUEST. THE ADMINISTRATION SHOULD REPLY IN TEN DAYS, AND THEIR REPLY HAS THE STATUS OF AN OFFICIAL DOCUMENT AND SHOULD BE ACCEPTED BY ANY CUSTOMS OFFICER.

5. MR. PUCHKOV ALSO PROVIDED SOME EXPLANATIONS CONCERNING THE RUSSIAN MODE OF TEMPORARY IMPORTATION OF GOODS. IN PARTICULAR, HE STATED, THAT OFFICIALLY REGISTERED FOREIGN BUSINESSES IN RUSSIA CAN IMPORT GOODS OR EQUIPMENT FOR TEMPORARY USE WITHOUT PAYMENT OF DUTIES FOR THE PERIOD OF THE VALIDITY OF THE FIRM'S REGISTRATION CERTIFICATE IN RUSSIA. THE TERM CAN BE EXTENDED AFTER PROLONGATION OF THE FIRM'S REGISTRATION CERTIFICATE. THE TEMPORARY IMPORTATION MODE REQUIRES A COMMITMENT FROM THE CONSIGNEE TO RETURN GOODS OR EQUIPMENT AFTER EXPIRATION OF THE TEMPORARY USE PERIOD. IT ALSO REQUIRES A CERTIFICATE THAT THE FOREIGN ENTITY IS THE OWNER OF GOODS OR EQUIPMENT.

6 WHEN PROBLEMS ARISE IN THE DETERMINATION OF THE HARMONIZED SYSTEM CODES FOR PRODUCTS, RUSSIAN CUSTOMS RECOMMENDS THE SHIPPER TO CONTACT A RUSSIAN CUSTOMS LABORATORY WHICH ASSIGNS CODES FOR ALL PRODUCTS. THE LABORATORY'S DECISION IS FINAL AND SHOULD BE ACCEPTED BY ANY CUSTOMS. IN CONCLUSION MR. PUCHKOV NOTED THAT THE MAJOR CONDITION OF SUCCESS IS CONSULTATIONS WITH CUSTOMS OFFICERS PRIOR TO THE ARRIVAL OF THE CARGO.

7. CONTACT INFORMATION:

FOLLOWING IS THE LIST OF CUSTOMS BROKERS WHICH HAVE A PULKOVO CUSTOMS GENERAL LICENSE:

AEROBALTSERVICE
12 SHTURMANSKAYA ST.
198242 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-3841; 122-9788
FAX: (7-812)-104-3684

GRUZ-EXPRESS (CARGO-EXPRESS)
12 SHTURMANSKAYA ST.
198242 ST. PETERSBURG, RUSSIA
TEL. :(7-812)-104-3523; 104-3526; 104-3527
FAX: (7-812)-104-3685
CONTACT: IGOR E. KOLTSOV, GENERAL DIRECTOR

AKTO-VNESHTRANS
4 ZAOZYORNAYA ST.
196084 ST PETERSBURG, RUSSIA
TEL.: (7-812)-294-8675; 294-8083
FAX: (7-812)-252-7701
CONTACT: GEORGY V. IVANOV, GENERAL DIRECTOR

VNESHTRANSAVIA
8 PILOTOV ST.
196210 ST PETERSBURG, RUSSIA
TEL.: (7-812)-104-3497; 104-3725
FAX: (7-812)-104-3498
CONTACT: ANDREI I. GASTEV, GENERAL DIRECTOR
TEL.: (7-812)-104-3477

DHL INT'L ST. PETERSBURG
5 KANAL GRIBOEDOVA, OFF. 325
191186 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-311-2649; 210-7545; 210-7654
FAX: (7-812)-314-6473
CONTACT: PETER PANDURO, GENERAL MANAGER

TNT EXPRESS
12 SHTURMANSKAYA ST., AVIAGORODOK
196210 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-104-3531
FAX: (7-812)-104-3684
CONTACT: KONSTANTIN REMIZOV, CHIEF OF THE CUSTO]S
SERVICE DEPARTMENT.

UPS-SOVTRANSAVTO
31 SALTYKOVA-SCHEDRINA ST.
191123 ST PETERSBURG, RUSSIA
TEL.: (7-812)-275-4405
FAX: (7-812)-275-8878
CONTACT: MARGARITA KOUCHINSKAYA, GENERAL MANAGER

BSZR ROSVNESHTERMINAL
11 BELINSKOGO ST.
191104 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-279-7586
FAX: (7-812)-279-7562
CONTACT: VICTOR BUROV, GENERAL DIRECTOR

CUSTOMS CONSULTING FIRMS:

RUNO-SILMARILL
7 SHKOLNAYA ST.
197183 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-315-7512; 119-8054
FAX: (7-812)-239-8052; 119-8105
CONTACT: IGOR PRUGUN, GENERAL DIRECTOR

ERNST & YOUNG ST. PETERSBURG
13 GALERNAYA ST.
190000 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-311-0539; 312-3864; 119-8100
FAX: (7-812)-850-8500
CONTACT: JOHN GLASS, OFFICE MANAGER

BAKER & MACKENZIE
57 BOLSHAYA MORSKAYA ST.
190000 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-119-8308
FAX: (7-812)-119-6013
CONTACQ" ARTHUR GEORGE, GENERAL REPRESENTATIVE

ST. PETERSBURG CUSTOMS INFORMATION SERVICE DEPARTMENT
10, 9TH LINE, VASILYEVSKY OSTROV
199034 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-213-7563; 213-0157
FAX: (7-812)-213-8017
CONTACT: VLADIMIR STEPANOV, HEAD OF THE DEPARTMENT.

OTHER CONTACTS:

PULKOVO CUSTOMS
ST. PETERSBURG'S PULKO^O AIRPORT.

AIRPORT PULKOVO-2, 196210 ST PETERSBURG
TEL.: (7-812)-104-3403; 122-9537
FAX: (7-812)-104-3294
CONTACT: ALEXANDER PUCHKOV, DEPUTY CHIEF OF THE CUSTOMS

REGIONAL CUSTOMS ADMINISTRATION.
THE NORTHWEST DEPARTMENT OF THE STATE COMMITTEE OF THE RUSSIAN FEDERATION ON CUSTOMS CONTROL
1 FURMANOVA ST., 191187 ST. PETERSBURG
TEL.: (7-812)-275-7695
FAX: (7-812)-275-3154
CONTACT: VLADIMIR BOBKOV, HEAD OF DEPARTMENT

CUSTOMS LABORATORY
71A SAVUSHKINA ST.
197188 ST. PETERSBURG, RUSSIA
TEL.: (7-812)-239-1173; 239-0851; 239-4332
FAX: (7-812)-239-4332
CONTACT: EVGENY KOROVKIN, HEAD OF LABORATORY.