Dispatching of customs declarations in the Russian Federation: problems of legal justification

Бурыгин А.А., Шкиперов А.А., Винькова Т.В., Агамагомедова С.А.

doi:10.7256/2454-0595.2025.1.72952

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Administrative and municipal law

Reference:

Burygin , A.A., Shkiperov, A.A., Vin'kova , T.V., Agamagomedova, S.A. (2025). Dispatching of customs declarations in the Russian Federation: problems of legal justification. Administrative and municipal law, 1, 1–17. https://doi.org/10.7256/2454-0595.2025.1.72952

Dispatching of customs declarations in the Russian Federation: problems of legal justification

Burygin Alexey Anatolyevich

Expert; Expert Group of the Public Council at the Federal Customs Service of Russia;
Deputy Director General for Development, Scientific and production organization ‘HYDRO-PRIVODSPETSMASH’

20/2 Kominterna str., Moscow, 129327, Russia

burygin.madi@yandex.ru

Other publications by this author

Shkiperov Anton Aleksandrovich

ORCID: 0000-0003-0411-6513

Assistant to the President of the Fishery Shipowners Association (FSA);
Advisor to the General Director Association of Business Partners in the Field of Foreign Economic Activity (ABP FEA);
member of the Committee on Customs Issues of OPORA RUSSIA

12 Trubnaya str., Moscow, 107045, Russia

Shkiperov@fsarf.ru

Other publications by this author

Vin'kova Tat'yana Viktorovna

Head of the System Analysis Department; Software and Information Technology Support Service; Central Information Technology Customs Administration of the Federal Customs Service of Russia

11/5 Novozavodskaya str., Moscow, 121087, Russia

Tatyana-vinkova@mail.ru

Agamagomedova Saniyat Abdulganievna

Associate Professor of the Department of Administrative and Customs Law, Associate Professor; Russian Customs Academy

4 Komsomolsky Ave., Lyubertsy, Moscow region, 140015, Russia

sa.agamagomedova@customs-academy.ru

DOI:

10.7256/2454-0595.2025.1.72952

EDN:

CTDXKP

Received:

03-01-2025

Published:

10-01-2025

Abstract: The subject of this study is the regulation of public relations proposed by the Federal Customs Service and the Ministry of Finance of the Russian Federation related to the automatic distribution of electronic customs declarations for goods between authorized electronic declaration centers using the customs information system, in particular, provided for by the current version of the draft order of the Ministry of Finance of the Russian Federation "On the powers of customs authorities to register customs declarations". Special attention in terms of argumentation of the need and specifics of the legal justification and regulatory consolidation of dispatching is paid to the positive effects of such a mechanism, which, in the author's opinion, are an integral manifestation and condition of full-scale digitalization and automation of customs authorities, established as a target for the development of the customs service of the Russian Federation until 2030, designed to ensure operational regulation and redistribution of the declarative array. To optimize the burden on officials, shorten the period of release of goods, simplify and accelerate customs operations, ensure uninterrupted registration of electronic customs declarations, and eliminate the possibility of interaction between declarants and customs officials is aimed at reducing the likelihood of corruption offenses. The authors used both general scientific methods (abstraction, induction, deduction, hypothesis, analogy, synthesis, typology, classification, systematization, generalization, and others) The same applies to special methods of scientific knowledge typical of jurisprudence (comparative law, historical, formal law, legal hermeneutics, system-structural, legal modeling, and others). The novelty of the scientific research lies in the applied proposals developed on the basis of the results of a comprehensive analysis of the existing sources of the EAEU law and the legislation of the member states on customs regulation, law enforcement practice regarding the legal justification of dispatching customs declarations in the Russian Federation as an integral direction in the implementation of strategic directions for the development of the customs service, providing for the formation by 2030 of a qualitatively new, rich "artificial intelligence", a rapidly reconfigurable, informationally connected with internal and external partners, a "smart" customs service that is invisible to law-abiding businesses and effective for the state, especially in terms of creating a "smart", flexible, information-rich, self-adjusting risk management system, as well as implementing and improving the effectiveness of the anti-corruption mechanism in in the customs sphere.

Keywords:

customs declaring, electronic declaring center, registration of customs declarations, dispatching of customs declarations, customs declaration, customs authorities, digitalization, automatization, declarant, information system
This article is automatically translated.

In 2020, the creation of a unified network of electronic customs offices and electronic declaration centers (hereinafter referred to as CED) was completed, ensuring the processing of more than 95% of all declarations for goods submitted in electronic form. The reduction of declaration sites (from over 670 active declaration sites in 2018 to 16 CED in 2020 (see Table 1) required the refinement of the software tools of the Unified Automated Information System of Customs Authorities (hereinafter referred to as the EAEU), which provides for the introduction of dispatching of customs declarations submitted in electronic form (hereinafter referred to as electronic customs declarations). between customs authorities (Order of the Federal Customs Service of Russia dated 26.06.2018 No. 988 "On the Decision of the Board of the Federal Customs Service of Russia dated May 29, 2018 "On the creation of a unified network of electronic customs offices and electronic declaration centers. Problems and ways to solve them"). This mechanism has been used by the customs authorities of the Russian Federation since 2021.

Table No. 1

Stages of creation of electronic declaration centers

in the Russian Federation

No. p / p	Name of the CED	City
Stage I (2018)
1.	Privolzhsky CED	Nizhny Novgorod city
2.	Ural Central Economic District	The city of Yekaterinburg
3.	North Caucasian Central Economic District	G. Mineralnye Vody
4.	Vladivostok CED	the city of Vladivostok
5.	Novorossiysk CED	Novorossiysk
6.	Kaliningrad CED	Kaliningrad
Stage II (2019)
7.	Siberian Central Economic District	city of Krasnoyarsk
8.	Baltic CED	St. Petersburg
9.	Moscow Regional CED	The city of Moscow
10.	Specialized Excise Tax Center	The city of Moscow
11.	Aviation CED	the city of Khimki
12.	Energy CED	The city of Moscow
Stage III (2020)
13.	Central CED	The city of Moscow
14.	Far Eastern CED	G. Artem
15.	North-Western CED	St. Petersburg
16.	Southern CED	Rostov-on-Don

Source: official website of the Federal Customs Service of Russia [https://customs.gov.ru/press/aktual -no/document/221823] (date of request: 17.12.2024)

The mechanism for dispatching electronic declarations for goods provides for their automatic (in accordance with established criteria) distribution between the CED, as well as within the CED between CED officials "depending on their workload and competence." These dispatch criteria follow from the competence of individual customs authorities to register customs declarations (Orders of the Ministry of Finance of the Russian Federation dated 03/31/2021 No. 51n "On the powers of Customs authorities to register Customs declarations", dated 09/08/2020 No. 185n "On the competence of Customs authorities to perform certain customs operations and perform specific functions in relation to excisable and certain types of goods", from 19.10.2020 No. 238n "On the competence of customs authorities to perform certain customs operations in respect of goods"). This competence of the customs authorities for the registration of customs declarations is determined depending on the presence (absence) of one or more features, which can be divided into a number of groups (see Table No. 2).

Table No. 2

The signs depending on which the competence is determined

customs authority for registration of customs declarations

№ n/a	A group of features	Signs
1.	The Declarant	- registration with the tax authorities of the Russian Federation as a taxpayer; - the category of a person (an individual, a representative of a legal entity, a legal entity (its separate subdivision), etc.).
2.	Product	- the location of the goods (relative to the region of activity of the customs authority); - the classification code of the product in accordance with the Customs Code of Foreign Economic Activity of the EAEU (in terms of product items, subheadings, subheadings, etc.); - product category (express cargo, international transportation vehicle, excisable goods, processed products of certain goods used as supplies, etc.); - the status of the product (foreign product, Union product); - the purpose of the goods (for use in the framework of international cooperation in the field of space exploration and use, for the implementation of the international medical cluster project, etc.).
3.	Customs authority	- the region of activity (the territory of the federal district/regional customs administration, a subject of the Russian Federation, is limited exclusively to a checkpoint across the State border of the Russian Federation or another place that is the place of movement of goods, etc.); - specialization (certain types of transport, certain categories of goods, etc.)
4.	Features of placement under the customs procedure	- declaration form (electronic or written (using transport (shipping), commercial and (or) other documents), using ATA carnet, etc.); - other features of the declaration (with the presentation of licenses (lists) of the Federal Customs Service of Russia, with the presentation of a document confirming the intended purpose of raw materials and components, etc.); - the territory of the premises under the customs procedure (on the territory of the SEZ in Kaliningrad, Magadan, regions, the Republic of Crimea, etc.); - the legality of the previous transfer; - other features (the release of goods was previously made upon an application for the release of goods before submitting a declaration for goods in the form of a paper document, etc.).
5.	Features of the movement of goods across the customs border	- type of transport (water (sea/river or vessels of mixed (river-sea) navigation), air, automobile, railway, pipeline, along power transmission lines, etc.); - direction of movement (import/export); - type of place of movement (sea, river (lake), mixed checkpoint, other place that is the place of movement of goods); - the region of activity of the customs authority in which the place of movement is located; - type of customs procedure (customs transit, special, free customs zone, re-export, etc.); - the legal grounds for the transfer (within the framework of the implementation of production sharing agreements, in accordance with the Agreement between the Russian Federation and the Republic of Abkhazia on cooperation and mutual assistance in customs matters, within the framework of intergovernmental agreements on industrial, scientific and technical cooperation of defense industry enterprises, etc.); - other features (movement in the same consignment with goods declared with the submission of licenses (lists) of the Federal Customs Service of Russia, movement of goods across the border of the SEZ, equivalent territories of advanced socio-economic development or the free port of Vladivostok or free warehouses, etc.)

Source: compiled by the author.

It is worth noting that the regulations establishing the competence of customs authorities to register customs declarations do not deprive customs posts that are not CED of such powers, but these powers are significantly limited (for example, by the condition of placing goods under the customs procedure of customs transit, declaring goods using a paper customs declaration, etc.).

The changing geopolitical situation and then the logistics of the Russian Federation's foreign trade led to a redistribution and a significant increase in the burden on officials of individual economic centers, especially those located in the Far Eastern Federal District. In some CED, a critical shortage of staff has occurred or is predicted. At the same time, the competence of the CED on registration of electronic customs declarations, fixed by the current regulatory legal acts, currently limits the possibility of redirecting the declaration array to less busy CEDs.

These conditions and factors led to the problem of ensuring operational regulation (redistribution) of the declarative array entering the CED, optimizing the burden on officials, and shortening the release period of goods. In order to solve this problem, the Federal Customs Service of Russia proposed to ensure the alignment of the powers of the CED for the registration of electronic customs declarations by defining such CEDs with an information system of customs authorities that meets the tasks of full-scale digitalization and automation of customs authorities in accordance with the Development Strategy of the Customs service of the Russian Federation until 2030. At the same time, there was a problem of legal justification and consolidation of this mechanism.

An analysis of scientific papers devoted to dispatching customs declarations ^[1-18] allows us to conclude that in the scientific community the legal aspect of dispatching customs declarations, related to solving issues of its legal justification and regulatory consolidation, remains without any attention. Absolute priority in the areas of scientific research is given to highlighting and substantiating the positive economic effects and functional and technological advantages for the control and supervisory activities of customs authorities and their customs operations. Under these circumstances, dispatching is not considered as a special independent legal institution in the system of customs law norms, which is at the initial stage of formation, but only as a simple technical and technological solution that does not provide for special regulation, does not affect the basic customs rights and legitimate interests of participants in foreign economic activity, and does not significantly affect the functions performed by customs authorities.. Such an approach does not meet the long-term and other goals and objectives of the customs service development, including those established by strategic planning documents, the role of informatization in this process, as well as the needs of the business community for the availability and effective functioning of a legally protected mechanism for the protection and implementation of the rights of declarants and other interested parties.

In order to normalize the principle of equality of powers to register electronic customs declarations for all CEDs included in the unified network of electronic customs offices and CEDs, as well as dispatching electronic customs declarations, a draft order of the Ministry of Finance of the Russian Federation "On the powers of Customs authorities to register Customs declarations" (hereinafter referred to as the draft order) was developed, providing for the automatic distribution of electronic customs declarations of goods between authorized persons to register them by the CED through the information system of customs authorities (hereinafter – ISTO).

The dispatching of electronic customs declarations is characterized by the following features, suggesting:

- centralization of control (distribution of electronic customs declarations in the CED in accordance with their competence and loading is controlled by the Federal Customs Service of Russia);

- Remote control;

- efficiency (the distribution of electronic customs declarations in the CED occurs automatically within the time limits prescribed for customs operations related to registration or refusal to register an electronic customs declaration, that is, no later than 1 hour of the customs authority's working time from the date of filing the electronic customs declaration);

- automation (distribution of electronic customs declarations in the CED in accordance with the established criteria is carried out automatically through the ISTO without the direct participation of a customs official);

- a combination of the principles of the CED's competence and optimization of its loading (dispatching of electronic customs declarations is carried out not only on the basis of the availability of appropriate legal powers to register them with the CED, but also depending on the actual loading of its officials with the incoming declaration array).

Meanwhile, the provisions of the current customs legislation (paragraph 1 of Article 109 of the EAEU Customs Code and Part 1 of Article 98 of Federal Law No. 289-FZ dated 08/03/2018 "On Customs Regulation in the Russian Federation and on Amendments to Certain Legislative Acts of the Russian Federation" (hereinafter referred to as the Law on Customs Regulation)) It is stipulated that "the customs declaration is submitted to the customs authority authorized to register customs declarations." Taking into account that the customs declaration is carried out by the declarant or a customs representative (on behalf of the declarant), and the filing of customs declarations, including operations related to the filing of customs declarations, are an integral stage of customs declaration and represent the duty and exclusive authority of the declarant, the choice of a specific customs authority among those authorized to register customs declarations for filing customs The declaration is an unconditional right of the declarant, guaranteed by customs legislation. At the same time, determining the competence of customs authorities to register customs declarations is the exclusive competence of the federal executive authority responsible for developing state policy and regulatory regulation in the field of customs affairs, represented by the Ministry of Finance of the Russian Federation (Part 2 of Article 98 of Federal Law No. 289-FZ dated 08/03/2018 "On Customs Regulation in the Russian Federation and on amendments to Certain Legislative Acts of the Russian Federation", clause 5.2.8 (14) of the Regulations on the Ministry of Finance of the Russian Federation (approved by Decree of the Government of the Russian Federation dated 30.06.2004 No. 329)).

An analysis of the current customs legislation allows us to identify the following main stages of the customs declaration of goods using an electronic customs declaration (see Table No. 3).

Table No. 3.

The main stages of the customs declaration of goods

using an electronic customs declaration

and their characteristics

customs declaration – application to the customs authority using the customs declaration of information on goods, about the chosen customs procedure and (or) other information necessary for the release of goods
Stage	Features	The subject
I. Filing a customs declaration	- submitted to the customs authority authorized to register customs declarations; - the customs declaration is submitted before the expiration of the period of temporary storage of goods (in respect of imported goods), before their departure from the customs territory of the EAEU (in respect of exported goods); - the goods must be located on the territory of the State to which the customs declaration in respect of such goods is submitted.	declarant or customs representative
II. Acceptance, verification and registration of the Customs declaration	- fixing the date and time of filing the customs declaration; - verification of the customs declaration in order to establish the absence of grounds for refusal of its registration; - registration or refusal to register a customs declaration no later than 1 hour of the customs authority's working time from the date of filing the customs declaration; - registration of a refusal to register a customs declaration (in case of refusal to register a customs declaration); - from the moment of registration, the customs declaration becomes a document attesting to facts of legal significance.	customs authority

Thus, the provisions of the EAEU Customs Code currently do not provide for the distribution of customs declarations between customs authorities authorized to register customs declarations. At the same time, in accordance with the EAEU Customs Code, customs relations that are not regulated by EAEU law, before they are regulated by EAEU law, are regulated by the legislation of the EAEU member States on customs regulation (paragraphs 2, 5 of Article 1 of the EAEU Customs Code).

However, taking into account the fact that the right of the declarant (customs representative) to file a customs declaration with any customs authority authorized to register customs declarations is separately provided for by the Law on Customs Regulation, as well as the fact that unified customs regulation is carried out in the EAEU, including the establishment of the procedure for customs operations related to the customs declaration of goods (Article 1 TC The introduction of dispatching customs declarations as a customs operation related to the filing of customs declarations in the structure of the "Filing of a customs declaration" stage of customs declaration carried out by the declarant or customs representative on behalf of the declarant appears to be a violation of the right of the declarant (customs representative) to submit a customs declaration to any customs authority guaranteed by the EAEU Labor Code and the Law on Customs Regulation. the body authorized to register customs declarations.

In addition, in accordance with the dispatching mechanism established by the draft order, it is actually assumed that an electronic customs declaration is submitted through the Unified Automated Information System of Customs Authorities (hereinafter referred to as the EAEU TO) directly to the Federal Customs Service of Russia (the Main Directorate of Information Technology Operating the EAEU TO) (paragraph 90 of the regulation on the Main Directorate of Information Technology (approved by the order Federal Customs Service of Russia dated 30.06.2021 No. 550), redirecting after the initial reception (fixing the date and time of filing) the electronic customs declaration to the CED for registration. However, the regulation on the Federal Customs Service (approved by Decree of the Government of the Russian Federation dated 04/23/2021 No. 636) does not give the FCS of Russia, as well as its structural divisions, the authority to receive customs declarations.

Finally, the dispatch of customs declarations does not take into account the special simplifications provided by customs legislation to authorized economic operators who have received certificates of the second or third types (Article 437 of the EAEU Customs Code). Thus, authorized economic operators have the right to perform customs operations related to the customs declaration of goods at a customs authority other than the customs authority in whose region the goods are located (subparagraph 5 of paragraph 3 of Article 437 of the EAEU Customs Code).

Meanwhile, the Republic of Belarus has experience in dispatching customs declarations among other EAEU member states. The Law on Customs Regulation of the Republic of Belarus (paragraph 2 of Article 93 of the Law of the President of the Republic of Belarus dated 10.01.2014 No. 129-Z "On Customs Regulation in the Republic of Belarus") defines that the customs authority authorized to register a filed customs declaration is the customs authority in whose region the goods are located, unless otherwise established by the State Customs Committee Republic of Belarus. In accordance with the Resolution of the State Customs Committee of the Republic of Belarus dated 08/02/2022 No. 74 "On the customs authority authorized to register declarations for goods", the customs authority authorized to register declarations for goods submitted in the form of an electronic document is the customs authority designated by the information system of customs authorities when submitting such declarations for goods. However, this mechanism applies only to cases where goods are placed under the customs procedure of release for domestic consumption, and also provides for other exemptions (for goods sent in international mail, transported by pipeline or power transmission lines, etc.).

A special feature of this regulatory act of the Republic of Belarus is that dispatching (determination of the customs authority authorized to register declarations of goods by the customs information system) is considered as an essential condition for determining the competence of the customs authority to register customs declarations, while the draft order developed in the Russian Federation considers dispatching only as a mechanism designed to optimize the load to the CED related to the registration of the declaration array, by redistributing it between less busy CEDs, and not affecting in any way the competence of the CED for the registration of customs declarations. Taking into account the above, the Belarusian experience of legally consolidating the dispatch of customs declarations in the national legislation on customs regulation, which provides for its legal condition for determining the competence of the customs authority for the registration of customs declarations, is in full compliance with the law of the EAEU.

Thus, dispatching of customs declarations is an integral manifestation and condition for full-scale digitalization and automation of the activities of customs authorities, established as a target for the development of the customs service of the Russian Federation until 2030, designed to ensure operational regulation and redistribution of the declaration array entering the CED, optimize the burden on officials, shorten the release period of goods, simplify and Speeding up customs operations, ensuring uninterrupted registration of electronic customs declarations, and eliminating the possibility of declarants interacting with customs officials are aimed at reducing the likelihood of corruption offenses.

References

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2. Argatov, M.A., & Desyatnichenko, O.Yu. (2023). Dispatching customs declarations: new opportunities and challenges for participants in foreign economic activity and the Federal Customs Service of Russia. Management Consulting, 8(176), 74-85.
3. Baldanova, A.D., & Zhigzhitova B.N. (2022). Dispatching of customs declarations. Young researchers on modern problems of theory and practice of customs affairs, pp. 8-9.
4. Lisina, D.A., & Ibragimova, D.M. (2021). The concept and features of dispatching customs declarations in Russia. Current problems of tax policy, pp. 249-253.
5. Polukhin, I.V. (2021). Some problems of dispatching customs declarations. Actual problems of modern economy, pp. 276-282.
6. Pigasina, P.S., & Baranova, A.F. (2022). Dispatching of customs declarations: problem statement. Customs business Founders, 1, 17-19. Lawyer Publishing Group, LLC.
7. Khudzhatov, M.B., & Nartova, E.P. (2020). Improving customs operations by introducing the principles of automatic distribution of declarations for goods. Marketing and Logistics, 6, 72-82.
8. Aliev, R.T. (2022). The practice of dispatching customs declarations. International Scientific Student Journal, 14, 12-15.
9. Baklan, I.S. (2019). Dispatching as an innovative process in the activities of customs authorities. Modern Science, 5-1, 72-75.
10. Nachkin, A.I. (2021). The state and prospects of using information resources for automatic dispatching of customs declarations. Scientific papers of the Northwestern Institute of Management of the RANEPA Founders: Russian Presidential Academy of National Economy and Public Administration, 12(4), 216-221.
11. Gorokhov, A.D. (2021). Problems and consequences of dispatching customs authorities. Actual issues of state regulation of foreign economic activity: domestic and foreign experience, pp. 37-42.
12. Skripka, V.S. (2021). Improving the application of dispatching customs declarations. International scientific student journal, 12, 370-373.
13. Meshechkina, R.P., & Vorona, A.A. (2021). Digital landmarks of the Federal Customs Service -the stage of automatic dispatching. Bulletin of the Belgorod University of Cooperation, Economics and Law, 2, 9-18.
14. Filchakova, V.A. (2021). The use of automatic dispatching of declarations for goods in the customs authorities of the Russian Federation. Youth science on current problems and prospects for the development of sectors of the national economy, pp. 604-607.
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REVIEW of an article on the topic "Dispatching of customs declarations in the Russian Federation: problems of legal justification". The subject of the study. The article proposed for review is devoted to topical issues of dispatching customs declarations in the Russian Federation from the perspective of legal regulation of relevant relations. The author of the article studies various issues of dispatching customs declarations in the Russian Federation, including the stages of establishing electronic declaration centers in the Russian Federation, theoretical and understandable issues (signs depending on which the competence of the customs authority for registration of customs declarations is determined), procedural aspects (the main stages of customs declaration of goods using electronic customs declaration and their characteristics), the legal basis of this issue, and other problematic aspects. The specific subject of the study was, first of all, the provisions of legislation, practice materials and opinions of scientists. However, unfortunately, the analysis of scientific literature is not actually given in the article. Research methodology. The purpose of the study is not stated explicitly in the article. At the same time, it can be clearly understood from the title and content of the work. The purpose can be designated as the consideration and resolution of certain problematic aspects of the issue of dispatching customs declarations in the Russian Federation from the perspective of legal regulation of the relevant relations. Based on the set goals and objectives, the author has chosen the methodological basis of the research. In particular, the author uses a set of general scientific methods of cognition: analysis, synthesis, analogy, deduction, induction, and others. In particular, the methods of analysis and synthesis made it possible to summarize and separate empirical data. The most important role was played by special legal methods. In particular, the author actively applied the formal legal method, which made it possible to analyze and interpret the norms of existing legal acts. For example, the author's conclusion is as follows: "the provisions of the current customs legislation (paragraph 1 of Article 109 of the EAEU Labor Code and Part 1 of Article 98 of Federal Law No. 289-FZ dated 08/03/2018 "On Customs Regulation in the Russian Federation and on Amendments to Certain Legislative Acts of the Russian Federation" (hereinafter referred to as the Law on Customs Regulation)) It is stipulated that "the customs declaration is submitted to the customs authority authorized to register customs declarations." Taking into account the fact that customs declaration is carried out by the declarant or a customs representative (on behalf of the declarant), and the filing of customs declarations, including operations related to the filing of a customs declaration, are an integral stage of customs declaration and represent the duty and exclusive authority of the declarant, the choice of a specific customs authority among those authorized to register customs declarations for filing customs The declaration is an unconditional right of the declarant, guaranteed by customs legislation. At the same time, determining the competence of customs authorities to register customs declarations is the exclusive competence of the federal executive authority responsible for developing state policy and regulatory regulation in the field of customs affairs, represented by the Ministry of Finance of the Russian Federation (Part 2 of Article 98 of Federal Law No. 289-FZ dated 08/03/2018 "On Customs Regulation in the Russian Federation and on amendments to Certain Legislative Acts of the Russian Federation", clause 5.2.8 (14) of the Regulations on the Ministry of Finance of the Russian Federation (approved by Decree of the Government of the Russian Federation dated 30.06.2004 No. 329))". Thus, the methodology chosen by the author is fully adequate to the purpose of the study, allows us to study all aspects of the topic in its entirety. Relevance. The relevance of the stated issues is beyond doubt. There are both theoretical and practical aspects of the significance of the proposed topic. From the point of view of theory, the topic of dispatching customs declarations in the Russian Federation is complex and ambiguous from the point of view of the legal regulation of the relevant relations. It is difficult to argue with the author that "In 2020, the creation of a unified network of electronic customs offices and electronic declaration centers (hereinafter referred to as CED) was completed, which ensures the processing of more than 95% of all declarations for goods submitted in electronic form. The reduction of declaration sites (from over 670 active declaration sites in 2018 to 16 CED in 2020 (see Table 1) required the refinement of the software tools of the Unified Automated Information System of Customs Authorities (hereinafter referred to as the EAEU), which provides for the introduction of dispatching of customs declarations submitted in electronic form (hereinafter referred to as electronic customs declarations). between customs authorities (Order of the Federal Customs Service of Russia dated 26.06.2018 No. 988 "On the Decision of the Board of the Federal Customs Service of Russia dated May 29, 2018 "On the creation of a unified network of electronic customs offices and electronic declaration centers. Problems and ways to solve them"). This mechanism has been used by the customs authorities of the Russian Federation since 2021." Thus, scientific research in the proposed field should only be welcomed. Scientific novelty. The scientific novelty of the proposed article is beyond doubt. Firstly, it is expressed in the author's specific conclusions. Among them, for example, the following conclusion: "dispatching of customs declarations is an integral manifestation and condition for the full-scale digitalization and automation of the activities of customs authorities, established as a target for the development of the customs service of the Russian Federation until 2030, designed to ensure the operational regulation and redistribution of the declarative array entering the CED, optimize the burden on officials, shorten the time to ensure the simplification and acceleration of customs operations, the uninterrupted registration of electronic customs declarations, and the exclusion of the possibility of declarants interacting with customs officials are aimed at reducing the likelihood of corruption offenses." These and other theoretical conclusions can be used in further scientific research. Secondly, the author suggests ideas for improving current law enforcement and practice based on the generalization of empirical data. The above conclusions may be relevant and useful for specialists in the field under consideration. Thus, the materials of the article may be of particular interest to the scientific community in terms of contributing to the development of science. Style, structure, and content. The subject of the article corresponds to the specialization of the journal "Administrative and Municipal Law", as it is devoted to legal issues related to the activities of customs authorities. The content of the article fully corresponds to the title, as the author considered the stated problems and generally achieved the set research goal. The quality of the presentation of the study and its results should be fully recognized as positive. The subject, objectives, methodology and main results of the research follow directly from the text of the article. The design of the work generally meets the requirements for this kind of work. No significant violations of these requirements were found. Bibliography. The quality of the literature used should be highly appreciated. The author actively uses the literature presented by authors from Russia (Zhukov D.B., Boyarsky G.A., Meshechkina R.P., Vorona A.A. and others). Many of the cited scientists are recognized scientists in the field of customs law. At the same time, the author of the reviewed article does not provide a review of scientific literature with reference to the opinions of specific authors. The article limited itself to a formal study of the bibliography: "An analysis of scientific papers on dispatching customs declarations [1-18] allows us to conclude that in the scientific community the legal aspect of dispatching customs declarations, related to the issues of its legal justification and regulatory consolidation, remains without the necessary attention." It is impossible to find out from the text of the article who and what exactly the scientists believe.
Thus, the works of these authors correspond to the research topic, have a sign of sufficiency, and contribute to the disclosure of various aspects of the topic. At the same time, there is no actual analysis of the literature. Appeal to the opponents. The author has not analyzed the current state of the problem under study. There are no quotes from scientists and author's comments on them. Conclusions, the interest of the readership. The conclusions are fully logical, as they are obtained using a generally accepted methodology. The article may be of interest to the readership in terms of the systematic positions of the author in relation to the stated issues only after reviewing the scientific literature and the positions of other authors. Based on the above, summarizing all the positive and negative sides of the article, "I recommend sending it for revision"

Second Peer Review

The subject of the research in the article submitted for review is, as its name implies, the dispatching of customs declarations in the Russian Federation. The author focuses on the analysis of the relevant problems of legal justification. The declared boundaries of the research have been observed by the scientist. The research methodology is not disclosed in the text of the article. The relevance of the research topic chosen by the author is undeniable and is justified by him as follows: "In 2020, the creation of a unified network of electronic customs offices and electronic declaration centers (hereinafter referred to as CED) was completed, which ensures the processing of more than 95% of all declarations for goods submitted in electronic form. The reduction of declaration sites (from over 670 active declaration sites in 2018 to 16 CED in 2020 (see Table 1) required the refinement of the software tools of the Unified Automated Information System of Customs Authorities (hereinafter referred to as the EAEU), which provides for the introduction of dispatching of customs declarations submitted in electronic form (hereinafter referred to as electronic customs declarations). between customs authorities (Order of the Federal Customs Service of Russia dated 26.06.2018 No. 988 "On the Decision of the Board of the Federal Customs Service of Russia dated May 29, 2018 "On the creation of a unified network of electronic customs offices and electronic declaration centers. Problems and ways to solve them"). This mechanism has been used by the customs authorities of the Russian Federation since 2021." Additionally, the scientist needs to list the names of the leading experts involved in the research of the issues raised in the article, as well as disclose the degree of their study. This is partially done in the main part of the work: "An analysis of scientific papers on dispatching customs declarations [1-18] allows us to conclude that in the scientific community the legal aspect of dispatching customs declarations, related to solving issues of its legal justification and regulatory consolidation, remains without any attention." The scientific novelty of the work is reflected in a number of the author's conclusions: "The changing geopolitical situation and then the logistics of the Russian Federation's foreign trade led to a redistribution and a significant increase in the burden on officials of individual economic centers, especially those located in the Far Eastern Federal District. In some CED, a critical shortage of staff has occurred or is predicted. At the same time, the competence of the CED on registration of electronic customs declarations, fixed by the current regulatory legal acts, currently limits the possibility of redirecting the declaration array to less busy CEDs. These conditions and factors led to the problem of ensuring operational regulation (redistribution) of the declarative array entering the CED, optimizing the burden on officials, and shortening the release period of goods. In order to solve this problem, the Federal Customs Service of Russia proposed to ensure the alignment of the powers of the CED for the registration of electronic customs declarations by defining such CEDs with an information system of customs authorities that meets the tasks of full-scale digitalization and automation of customs authorities in accordance with the Development Strategy of the Customs service of the Russian Federation until 2030. At the same time, the problem of the legal justification and consolidation of this mechanism has arisen"; "The analysis of scientific papers on dispatching customs declarations [1-18] allows us to conclude that in the scientific community the legal aspect of dispatching customs declarations, related to the solution of issues of its legal justification and regulatory consolidation, remains without any attention. Absolute priority in the areas of scientific research is given to highlighting and substantiating the positive economic effects and functional and technological advantages for the control and supervisory activities of customs authorities and their customs operations. Under these circumstances, dispatching is not considered as a special independent legal institution in the system of customs law norms, which is at the initial stage of formation, but only as a simple technical and technological solution that does not provide for special regulation, does not affect the basic customs rights and legitimate interests of participants in foreign economic activity, and does not significantly affect the functions performed by customs authorities.. Such an approach does not meet the long-term and other goals and objectives of the customs service development, including those established by strategic planning documents, the role of informatization in this process, as well as the needs of the business community for the availability and effective functioning of a legally protected mechanism for the protection and implementation of the rights of declarants and other interested parties," etc. Thus, the article makes a definite contribution to the development of Russian legal science and certainly deserves the attention of potential readers. The scientific style of the research is fully supported by the author. The structure of the work is logical. In the introductory part of the article, the scientist substantiates the relevance of his chosen research topic. In the main part of the work, the author identifies the problems of legal justification for dispatching customs declarations in the Russian Federation and suggests ways to solve them. The final part of the article contains conclusions based on the results of the study. The content of the article corresponds to its title, but it is not without its formal drawbacks. Thus, the author writes: "The mechanism for dispatching electronic declarations for goods provides for their automatic (in accordance with established criteria) distribution between the CED, as well as within the CED between CED officials "depending on their workload and competence" - "dispatching", "for goods" (typos). The scientist notes: "The change in the geopolitical situation and then the logistics of foreign trade of the Russian Federation led to a redistribution and a significant increase in the burden on officials of individual economic centers, especially those located in the Far Eastern Federal District" – "The change in the geopolitical situation and, as a result, the logistics of foreign trade of the Russian Federation led to a redistribution and a significant increase in the burden on employees some CED, especially located in the Far Eastern Federal District" (stylistic errors). Thus, the article needs additional proofreading - it contains typos and stylistic errors (the list of typos and errors given in the review is not exhaustive!). The bibliography of the study is represented by 18 sources (scientific articles). From a formal and factual point of view, this is enough. The author managed to reveal the research topic with the necessary completeness and depth. There is an appeal to the opponents, but it is general in nature due to the focus of the research. The author states that "The analysis of scientific papers devoted to dispatching customs declarations [1-18] allows us to conclude that in the scientific community the legal aspect of dispatching customs declarations, related to solving issues of its legal justification and regulatory consolidation, remains without any attention." The scientific discussion is conducted correctly by the scientist. The provisions of the work are properly reasoned and illustrated with tables.
There are conclusions based on the results of the study ("Thus, dispatching of customs declarations is an integral manifestation and condition for full-scale digitalization and automation of the activities of customs authorities, established as a target for the development of the customs service of the Russian Federation until 2030, designed to ensure operational regulation and redistribution of the declaration array entering the CED, optimize the burden on officials, shorten the release period of goods, simplify and speeding up customs operations, uninterrupted registration of electronic customs declarations, and excluding the possibility of declarants interacting with customs officials are aimed at reducing the likelihood of corruption offenses"), have the properties of reliability, validity, and undoubtedly deserve the attention of the scientific community. The interest of the readership in the article submitted for review can be shown primarily by experts in the field of administrative law and customs law, provided that it is slightly improved: disclosure of the research methodology, additional justification of the relevance of its topic (within the framework of the remark made), elimination of violations in the design of the work.

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Dispatching of customs declarations in the Russian Federation: problems of legal justification