‘Recovering the Costs of Customs’ Goods Clearance Activities’ Discussion Document

Pricing Review

We appreciate the fact that NZ Customs has had the costing and pricing methods verified by an independent third party. We are satisfied the new fees structure is a fair reflection of the actual costs of good clearance activities undertaken by NZ Customs.
Without further analysis of New Zealand Customs operational costs and budgets, we would not be able to scrutinise New Zealand Customs’ fiscal control, but trust that these are being managed appropriately.

As mentioned above, our organisation supports a more ‘user pays’ method of operation, as such believe that these fees are simply a cost of doing international business to and from New Zealand. We note that the fees do not reflect full cost recovery, but that what is proposed is balanced approach. We would be concerned if the end goal was full cost recovery, given significant cost shifting consequences it could cause to business and the end consumer.

We agree with the proposed monitoring system. We would note that 13 years between fee reviews is far too long and the time between reviews is reflected in the large increases that some fees will have. While the fee increases are understandable and justifiable, some companies may be surprised at the increase. We would recommend that Customs put in place robust communications to support the changes and explain the fee changes to customers.

We support the proposed three-year review of clearance fees, however we would also welcome an annual review adjustment with any cost recovery increase kept within inflationary pressures. Our organisation will want more discussion and detail about how fees will be adjusted in the future. We understand that a review of fee values and allocation framework could not have been undertaken due to the Customs Act being updated in 2018.

Recommendation: Support for the proposed three year reviews, but any future fee increases be kept within inflationary pressures.

New Zealand Customs is expected to ensure customers (both importers, exporters, and freight forwarders) are well informed of any decisions resulting from the clearance fees review and there is a long lead in period to any changes.

Good communication with the business community is a necessity and the New Zealand Chambers of Commerce are committed to help New Zealand Customs notify businesses of the changes to the clearance fees, as we have done in the past with the 2018 Act and implementation of the infringement regime.

Impact on business

The obvious impact for importers is an increased cost to import goods, whether these businesses absorb that cost or pass it on to the buyer/customer is up to them. If it is the latter this may have consequences for the end consumer who would have to pay higher prices for goods and commodities...

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