Kernrechtsfrage
Whether customs origin and tariff information under Art. 20 ZG must be issued in a form that is appealable as a decision.
Extrahierter Entscheid
Yes. A written customs origin ruling is, in principle, to be issued as a decision under Art. 5 VwVG and may be challenged before the Federal Administrative Court.
Extrahierte Begründung
Art. 20 ZG creates a legally binding, prospective and standardized information relationship; legal certainty and Art. 29a BV require judicial review, and the structure of the customs rules follows the model of binding rulings in comparable tax areas.