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Switzerland: New customs compliance requirements for authorized consignors/consignees (ZV/ZE)

Switzerland: New customs compliance requirements

The Swiss customs administration must, following amendments to the Common Transit Procedure Convention, review and re-evaluate permits relating to authorized consignee and consignor status in Switzerland—Zugelassener Versender [ZV] / Zugelassener Empfänger [ZE]. Companies with AEO status are excluded from this review process because they are deemed already to satisfy the applicable conditions.


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Beginning 1 July 2019, all current ZV/ZE holders as well as new applicants will be subject to the stricter conditions.

New requirements

  • The requirement that ZV/ZE holders must not have committed any serious or repeated infringements of customs and tax law is expanded to include aspects of commercial activity such as fraud, corruption, bribery, money laundering, environmental crimes, and involvement in criminal organizations.
  • Each ZV/ZE holder must have a documented Internal Compliance Program—Internes Kontrollsystem [IKS]—in all customs-relevant areas.

Not complying with these requirements within the deadline could trigger the suspension or removal of the license.


  • ZV/ZE license holders (except AEO entities) before 2019 were to have received a letter from the Federal Customs Administration informing them of the legal changes and the need for reassessment. The letter will include a questionnaire asking license holders to submit a binding statement as to whether the company meets the new licensing conditions.
  • By 15 February 2019, ZV/ZE license holders must complete and return the questionnaire with the signature of an authorized signatory. The customs administration then is to evaluate the questionnaires and verify whether the company still meets the requirements for ZV/ZE status. Unless a company is informed otherwise, approval for the ZE/ZV procedure and the acceptance report remain valid.

By 1 July 2019, ZV/ZE holders must comply with the new requirements.

Read a January 2019 report prepared by the KPMG member firm in Switzerland

For more information, contact a KPMG trade and customs professional in Switzerland:

Michel Anliker | +41 58 249 68 17 |

Or for more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner, Global Practice Leader
T: 312-665-1022

Andy Siciliano
Partner, National Practice Leader
T: 631-425-6057

Irina Vaysfeld
T: 212-872-2973

Robert Waldrop
T: 212-954-8117 

Christopher Young
T: 312-665-3229

George Zaharatos
T: 404-222-3292

John L. McLoughlin
Principal, East Coast Leader
T: 267-256-2614

Luis (Lou) Abad
Principal, WNT
T: 212-954-3094

Amie Ahanchian
Managing Director
T: 202-533-3247

Gisele Belotto
Managing Director
T: 305-913-2779

Andy Doornaert
Managing Director
T: 313-230-3080

Jessica Libby
Managing Director
T: 612-305-5533

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