Italy: Port Efficiency and Documentation Details – An AEO Optimization Path for Hot-Rolled Steel Exports to Italy

As Europe’s third-largest steel consumer, Italy presents exporters with a dual challenge due to its complex port operations and sophisticated customs regulations. Hot-rolled steel, as a commodity, is particularly sensitive to logistical efficiency and costs. Optimizing supply chain visibility and customs clearance efficiency through AEO certification has become a strategic solution for exports to Italy.

Part 1: Efficiency Analysis and Selection Strategies of Major Italian Ports

1. Comparative Analysis of Three Major Steel Hub Ports

Port | Core Advantages | Efficiency Challenges | Applicable Cargo Types

Genoa | • Italy’s largest port

• Direct hinterland access to the northern industrial region
• Specialized steel terminal
• High congestion rate (average shipping delay of 18-36 hours)
• Limited yard space | High value-added plate

Long-term contract bulk cargo

Trieste | • Central European railway hub

• High degree of automation
• Customs territory extends to Austria

Hinterland transport relies on rail

• Impact of severe weather (Brahma) | Inland destination cargo volume | Multimodal transport priority

Taranto | • Southern core steel port

• Specialized bulk cargo berths
• Lower port fees
• Relatively old infrastructure
• Fluctuating customs clearance speed | Large quantities of primary steel | Southern Italy/Mediterranean region cargo

1. Key Time Nodes for Port Operations

Anchorage Waiting Time: Genoa average 24 hours, Trieste average 8 hours

Unloading Efficiency: Bulk hot-rolled steel coils average 800-1200 tons/day (depending on port equipment)

Document Preparation Window: A complete electronic pre-declaration must be submitted 24 hours before arrival.

Demurrage Risk: Free container time at Italian ports is typically 7-10 days; demurrage rates are €50-150/TEU per day.

3. Port Selection Decision Matrix

High Value + Time Sensitive → Trieste (Optimized Rail Intermodal Transport)

Large Volume + Cost Sensitive → Taranto (Bulk Cargo Advantage)

Comprehensive Balance + Long-Term Agreement → Genoa (Comprehensive Service)

Part Two: Refined Management of Export Documents for Hot-Rolled Steel

1. List of Mandatory Documents and Key Details

Commercial Invoice:

Must specify steel grade (e.g., S235JR), specifications (thickness/width/coil weight)

Must be prepared in Italian or bilingually, with clear price terms (CIF Italian port)

Origin information must be accurate to the production plant

Packing List:

Hot-rolled coils must indicate coil number, heat number, weight (gross/net weight), and dimensions.

Packaging method (naked/rust-proof paper/steel strapping) must be described in detail.

Stacking restrictions and handling instructions must be illustrated.

Material Certificate 3.1/3.2:

Must be issued by the manufacturer and comply with EN 10204 standards.

Includes complete chemical analysis (C, Mn, P, S, Si, etc.)

Mechanical property data (yield strength, tensile strength, elongation)

Heat treatment state (hot-rolled, normalized, etc.)

Certificate of Origin:

Generally, Certificate of Origin (CO) is issued by the China Council for the Promotion of International Trade (CCPIT).

If a preferential tariff rate applies, a FORM is required. Certificate A

Italian Customs may require an additional declaration of origin

2. Italian-Specific Document Requirements
   Special Requirements for Transport Documents:

The bill of lading must show the consignee’s tax code (Codice Fiscale)

Dangerous Goods Declaration (Even if hot-rolled steel is not a dangerous good, certain coatings require a declaration)

Port Security Declaration (ISPS Code compliance)

Tax-Related Documents:

The EU internal VAT number must be accurate

Information on the Italian importer’s financial representative

The EORI number must be displayed on all customs documents

3. Electronic Submission Systems

Italian Customs Portal: Pre-declaration via the “Dogana” system

Port Community Systems: Genoa uses “PORTIT,” Trieste uses “TRIESTE SYSTEM”

Submission Timeline:

T-72 hours: Submit a summary declaration of goods
T-24 hours: Submit a complete manifest and documents
T-4 hours: Submit a vessel berthing application
T+0: Immediate customs clearance begins upon arrival
Part Three: Optimized Path and Implementation Value of AEO Certification

1. Italian AEO Certification Type Selection

AEO-C (Customs Simplification):

Suitable for: Long-term stable importers

Core Benefits: Simplified declaration process, reduced physical inspection rate (30-50% reduction)

Suitability for hot-rolled steel: ★★★☆☆ (Basic benefits)

AEO-S (Security):

Suitable for: Companies prioritizing supply chain security

Core Benefits: Priority customs clearance, EU mutual recognition

Suitability for hot-rolled steel: ★★☆☆☆ (High security requirements)

AEO-F (Comprehensive):

Suitable for: Large supply chain management companies

Core Benefits: All C+S benefits + financial guarantee reduction

Suitability for hot-rolled steel: ★★★★★ (Maximum overall benefits)

2. AEO-F Certification Path for Hot-Rolled Steel Exporters

Phase 1: Diagnosis and Assessment (1-2 months)

Analysis of existing process gaps

Selecting an Italian customs consultant

Developing a certification roadmap

Phase 2: System Construction (3-4 months)

Establishing a compliance management system

Implementing the Supply Chain Security Agreement (ISO) 28000 Benchmarking)

Proof of Financial Solvency

Phase Three: Application Submission (2-3 months)

Document Package Preparation (Business Model, Process Manual, Audit Report)

Preliminary Review by Italian Customs

On-site Audit Preparation

Phase Four: Audit and Acquisition (2-4 months)

On-site Audit by Italian Customs

Rectification and Feedback

AEO Certificate Issuance

3. Specific Benefits of AEO Certification for Hot-Rolled Steel Exports
   Benefit Dimensions Quantitative Improvement Operational Impact
   Customs Clearance Speed ​​Clearance time reduced by 40-60% Port demurrage reduced by 2-3 days
   Inspection Rate Physical inspection reduced by 50-70% Significant reduction in cargo damage risk
   Cost Optimization Port fees saved by 15-20% Shortened cash flow cycle
   Supply Chain Visibility Real-time tracking accuracy rate 95%+ Improved customer satisfaction
   Competitive Advantage Enhanced bidding qualifications Improved ability to obtain long-term agreements

Part Four: Comprehensive Operation Plan and Risk Control

1. End-to-End Optimized Operation Process

China Operation:

1. 1. Pre-production stage: Confirm the Italian customer’s AEO status and plan the certification optimization path.
2. Production stage: Generate a material certificate conforming to EN 10204 3.2 and bind the roll number.
3. Pre-shipment: Pre-submit documents through the Italian port system and confirm the AEO code is effective.

Sea transport operations:

4. Vessel selection: Prioritize calls at AEO-friendly ports (Trieste AEO dedicated channel).
5. In-transit management: Share vessel location in real time and update estimated arrival time.

Italian operations:

6. 24 hours before arrival: Complete AEO fast-track electronic customs clearance.
7. Port operations: Prioritize unloading; AEO cargo is stored separately.
8. Inland transport: Apply simplified transit procedures for direct delivery to the end user.
9. Common Risks and Mitigation Measures

Document Discrepancy Risk:

Mitigation: Implement a “dual-person review system” and use a document verification checklist.

Tools: Utilize an intelligent document system to automatically verify key fields.

Port Congestion Risk:

Mitigation: Develop backup port plans (e.g., diverting to Trieste when Genoa is congested).

Monitoring: Subscribe to real-time efficiency data for Italian ports.

Certification Expiration Risk:

Mitigation: Conduct internal compliance audits every six months.

Relationships: Maintain regular communication with Italian customs.

Market Risk:

Monitoring: Track Italian steel safeguard measures and anti-dumping cases.

Diversification: Develop customer bases in both Southern and Northern Italy.

3. Digital Tool Integration Solution

AEO Certification Management Platform: Track certification status, update requirements, and expiration reminders.

Port Efficiency Dashboard: Real-time monitoring of operational indicators at major Italian ports.

Document Automation System: One-click generation of complete sets of documents compliant with Italian requirements.

Carbon Footprint Tracking Module: Addressing Italy’s upcoming green steel procurement policy.

Conclusion: Building a Sustainable Competitive Advantage through AEO Certification
The Italian steel import market is moving towards efficiency-first, compliance-driven, and green-oriented development. Hot-rolled steel exporters should:

1. Strategic Level:

Treat AEO certification as a market access investment, not a compliance cost.

Prioritize efficient ports such as Trieste as strategic hubs.

Establish long-term partnerships with Italian AEO-certified importers.

2. Operational Level:

Implement lean document management to achieve “first-time submission correctness.”

Utilize AEO rights to optimize port and inland logistics costs.

Establish a dedicated Italian supply chain visibility system.

3. Development Level:

Replicate the Italian experience to other EU markets.

Explore the synergistic effects of green steel certification and AEO.

Participate in Italian infrastructure project bidding, leveraging AEO advantages.

Ultimately, the key to success in the Italian market lies in the deep integration of port operational efficiency, refined document management, and the advantages of AEO certification to build a resilient supply chain system that is difficult to replicate. This not only addresses current challenges but also prepares for future EU supply chain digital passports, green tariffs, and other new regulations, establishing a long-term market position.