New Approach to Comprehensive Guarantee Equalization: Transactions Permitted Even with Linked Declarations

New Approach to Comprehensive Guarantee Equalization: Transactions Permitted Even with Linked Declarations

A circular published by the Directorate General of Customs dated August 12, 2025 provided clarification on operational issues encountered in guarantee equalization procedures within comprehensive guarantee files. The circular emphasizes that rejecting equalization requests on the grounds of linked declaration checks, particularly in cases where no guarantee refund has been requested, causes grievances for operators.

According to the Directorate General of Customs, in certain situations where no guarantee refund is requested and the required guarantee amount exceeds the remaining balance, operators may apply for guarantee equalization on the grounds that the guarantee has not been utilized. However, it is noted that in practice, linked declaration checks are also being conducted for such requests, and cases have been observed where operator requests are not being met due to the existence of linked declarations.

Under the new assessment, two distinct scenarios are highlighted.

1. Where a guarantee refund is requested, it is mandatory to check whether linked declarations and open transactions exist.
2. Where no guarantee refund is requested, guarantee equalization must be carried out even if linked declarations and open transactions exist, in order to prevent the guarantee balance from falling into deficit, to avoid excessive utilization, or to remedy operator grievances.

This regulation aims to resolve amount discrepancies in comprehensive guarantee files more swiftly and to eliminate unnecessary correspondence. It has now been clarified that equalization should no longer be suspended on the grounds of linked declarations in transactions where no guarantee refund has been requested but a amount discrepancy exists in the system.

For this reason, it is important that companies operating under comprehensive guarantees take the provisions of this circular into account when submitting guarantee equalization requests and managing guarantee refund processes.