28 In that regard, it should be noted that, in accordance with the Court’s case-law, the concept of unlawful removal from customs supervision, as referred to in Article 203(1) of the Customs Code, must be understood as encompassing any act or omission the result of which is to prevent, if only for a short time, the competent customs authority from gaining access to goods under customs supervision and from monitoring them as provided for in Article 37(1) of the Customs Code (Cases C‐66/99 D.
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