KCS Introduces System of “Batch Submission of Data on Customs Value Declarations”

A person obligated to pay duties must report the value of the goods imported to the head of a customs office when filing an import declaration, and submit data for determining the customs value (the “customs data”) (Articles 27 (1) and 27 (2) of the Customs Act (the “Act”)). However, the current customs data submission requirement has previously been subject to criticism, as it (i) applies to all duty payers that file customs value, irrespective of whether a duty payer is subject to customs valuation, (ii) requires repeated submission of customs data at the time of import, regardless of whether such customs data have already been submitted, or when such data have been created, and (iii) only provides abstract details on the requisite submissions information, despite the various forms of trade and transactions.

The Enforcement Decrees of the Customs Act were amended on February 28, 2025, and accordingly, on July 1, 2025, the Korea Customs Service (the “KCS”) partially amended the Notification on the Operation of Customs Valuation (the “Amended Notification”) to improve the submissions process for customs data, and to specifically define the scope of customs data required to be submitted, thereby introducing a system of batch or consolidated submission of customs data. The new system took effect since September 1, 2025.

The key details of the batch submission of customs data, which applies to import declarations from September 1, 2025, are as described below.

Requirement to Submit Customs Data Once Annually, at the Time of Initial Import

In order to improve the process for submitting customs data, the Amended Notification provides that if goods are repeatedly imported by the same seller and buyer, under the same terms and conditions, customs data may be submitted only for the initial import in a given year. Further, when filing another value declaration within the same year, the duty payer must indicate the import declaration number of the initial customs declaration in the given space in the value declaration form in lieu of submitting the customs data for each filing. Different types of goods imported under the same customs data will be deemed to have been imported under the “same terms and conditions.”

List of Customs Data to Be Submitted

The Amended Notification has streamlined the requirement for submitting the customs data to eight different sectors. If a transaction does not fall under one of the sectors, an importer is required to submit a statement of reasons for non-submission, along with a customs value declaration form.

Sector	Customs Data (One or More Data per Sector)
(1) License Fee	Agreement stipulating payment of license fees for the use of patents, utility model rights, design rights, trademarks, or similar rights
(1) License Fee	Statement detailing the calculation or payment of royalties
(2) Production Support	Production support agreement
(2) Production Support	Statement detailing the calculation or payment of commissions or brokerage fees
(3) Commission or Brokerage Fee	Commission or brokerage agreement
(3) Commission or Brokerage Fee	Statement detailing the calculation or payment of commissions or brokerage fees
(4) Freight, Insurance Premiums or Other Transportation Expenses	Agreement covering freight, insurance, or other transportation expenses
	Statement of calculation or payment for these expenses
(5) Container or Packaging Costs	Overseas packaging service agreement and/or container lease agreement
(5) Container or Packaging Costs	Statement of calculation or payment for packaging services and container lease expenses
(6) Post Import Proceeds	Agreement specifying the amount of proceeds from the resale, disposal, or use of the imported items that is directly or indirectly attributable to the seller
(6) Post Import Proceeds	Statement of calculation or payment of post-import proceeds
(7) Indirect Payment	Documentation regarding set-off of imported item price against seller’s debt
	Documentation of any seller’s debt repaid by the buyer
	Other supporting documentation related to indirect payments
	Statement of calculation or payment of indirect payments
(8) Related Party Transaction	Data required for determining the customs value of imported items under the Customs Act
(8) Related Party Transaction	Reports or explanatory materials related to transfer pricing for imported goods

Ex-Post Facto Submission of Customs Data (30 days) Allowed

The Amended Notification allows companies to submit a statement of reason for delayed submission within 30 days from the date the import declaration is accepted where unavoidable circumstances may cause delays in customs clearance, such as when more time is needed for a company to prepare customs data or for a customs broker to review the customs data.

Exemptions from Customs Data Submission

Companies that are in good standing in duty payment cooperation programs such as Authorized Economic Operator (“AEO”) and Advance Customs Valuation Agreement (“ACVA”), and small-sized importers with a duty payment of less than KRW 500 million in the previous year are required to file a customs value declaration, but are exempt from submitting customs data.

Measures Against Companies Failing to Submit Customs Data

The Amended Notification allows customs offices to take measures against duty payers failing to submit customs data, such as (i) cancelling the approval for a business that pays customs duties monthly, (ii) suspending exemption from the provision of security, (iii) conducting a customs audit or a tax audit, and (iv) other measures under the Customs Act.

As explained above, the Amended Notification introduces the system of “batch submission of data on customs value declarations.” As a result, we expect that the KCS and the customs offices will utilize the system to secure customs data from the initial point of import declaration by the duty payer and effectively support systematic tax evasion management procedures after the declaration has been processed. Therefore, importers and exporters should fully understand and respond to the changes arising from the Amended Notification to avoid any disadvantages and carefully follow how these changes in customs administration may affect their business operations going forward.

[Korean Version]

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