4624

Authorization procedure and Trade Register aspects for CAEN 4624

For registering with the Trade Register (ONRC) the activity of wholesale trade of furs, raw hides and tanned or dressed skins (CAEN code 4624), it is necessary to submit a typical incorporation or amendment file of the activity object. In the case of an SRL, the application is accompanied by the articles of incorporation, the affidavit under Law 359/2004 regarding the absence of legal contraindications and, mandatorily, the explicit mention of CAEN code 4624 as the main or secondary activity object. No special prior approvals from ONRC are required for this code, but the correct mention of CAEN classes, according to the Official Nomenclature, is necessary. ONRC fees are standard, and the legal resolution term is 3-5 business days for registration. Any error in the activity name or correspondence with real products may lead to suspension of the authorization or refusal of registration.

From the point of view of the registered office, there are no special restrictions other than those imposed by sanitary-veterinary legislation, given the nature of the products (raw hides). It is advisable that the office be distinct from storage spaces for perishable goods, to avoid confusion with production or processing activities. Any subsequent change of address or secondary objects must be notified to ONRC through the procedure of amending the articles of incorporation.

Regulatory framework, specific approvals and control institutions

Although CAEN 4624 is not subject to direct authorization by the National Sanitary Veterinary and Food Safety Authority (ANSVSA) for wholesale trade activities, the transport or storage of raw hides may require sanitary-veterinary registration in accordance with EC Regulation no. 853/2004 and national legislation (ANSVSA Order no. 69/2010). Practically, any handling of products of animal origin imposes compliance with hygiene, traceability and veterinary control conditions. It is recommended to obtain a sanitary-veterinary registration certificate for storage units, issued by the county DSVSA, if the space is properly equipped. Also, registration in the Register of Operators in the Food Sector (ROSA) is necessary only if the activity exceeds mere intermediation.

Additionally, products (furs, raw hides) may be subject to CITES legislation (Convention on International Trade in Endangered Species), if they come from protected species. The operator must verify the origin of goods and hold supporting documents (certificates of origin, invoices with specifications). Relevant control institutions are: the Tax Authority (ANAF - for VAT and taxes), ITM (for working conditions), Environmental Guard (for specific waste management) and, in case of irregularities, the border police upon entry of goods into the country.

Fiscal management, ANAF audit risk and specific accounting

Operations of wholesale trade of raw hides qualify as supplies of goods, subject to the standard VAT regime (19%), with the possibility of applying reverse charge if the partners are VAT registered and the transactions are intra-Community. Invoicing must comply with the requirements of the RO e-Factura system (ANAF Order no. 33/2024), with the mandatory transmission of invoices via SPV for all B2B transactions, under penalty of fines and suspension of the VAT code. Also, informative declarations (D301, D390) must be correctly filed, paying attention to CN tariff codes (e.g. 4101 for raw hides).

The risk of ANAF audit is high in this sector due to the specific nature of goods (high values, cross-border flows). Accounting must separately and in detail record batches of goods, based on receipt documents (delivery notes, certificates of origin). It is recommended to set up inventory with analytical management by categories (furs, processed hides) and periodic revaluation at the lower of cost and net realizable value. Fiscal obligations include payment of corporate income tax (16% or 1% for micro-enterprises, if conditions are met) and personal income tax (single declaration). For micro-enterprises, income from wholesale trade is included in the EUR 500,000 threshold, without specific restrictions. Finally, any fiscally uncertain transaction must be documented with contracts, invoices and affidavits to avoid the risk of reclassification.