Response by Norway on the public consultation on the draft implementing provisions concerning new security and safety measures

Norway appreciates the opportunity of providing comments and views on the draft implementing provisions concerning new security and safety measures.

As underlined in several meetings with representatives of the Commission services, Norway welcomes the Commission’s initiative to enhance security in cross-border trade. Norway’s concern is, however, that the new procedures, particularly the introduction of pre-arrival and pre-departure declarations, may create barriers to trade between Norway and the Community. In this respect, it should be noted that Norway, through the Agreement on the European Economic Area (the EEA Agreement), is a part of the EU Internal Market, and that any procedure applicable in trade between Norway and the Community should comply with the provisions laid down in the EEA Agreement.

In order to avoid any negative impact for operators involved in trade between Norway and the Community, pragmatic and practical solutions should be found. In our view, trade facilitation, by harmonising, standardising and modernising trade procedures, would increase security. Norway believes that this view is shared by the Commission. Norway is pleased to note that the Commission at several occasions has explicitly stated that an appropriate solution is necessary in respect of trade with Norway.

It is appreciated that the draft Implementing Provisions provide for the establishment of international agreements in order to reduce the time limits for the submission of summary declarations, or to carry out security checks in the country of export. Norway is of the preliminary view that the pragmatic and practical solution for trade between Norway and the Community ought to be laid down in a bilateral agreement between Norway and the Community. Norway would suggest that the parties should meet as soon as possible in order to examine the content of such an agreement. In this respect, it should be noted that an agreement on customs co-operation between Norway and its neighbouring EU Member States already is in place. This agreement, which entered into force on 1 March 1997, could be extended to also cover security and safety measures.

Norway has noted with interest the proposed concept of Authorised Economic Operators, as well as the Commission’s intention of extending this concept to third countries. Norway finds these ideas interesting and is prepared to enter into a dialogue with the Commission on a possible co-operation based on reciprocity in this respect. However, Norway questions whether the proposed concept in respect of security and safety offers the necessary advantages for economic operators.

The preliminary views outlined above are not exhaustive. Thus, Norway reserves its right to provide further comments later and looks forward to discussing these issues with the Commission services at upcoming occasions.

Yours sincerely,

Copy:
Ministry of Foreign Affairs
Ministry of Trade and Industry
Directorate of Customs and Excise