19As regards more specifically the concept of unlawful removal from customs supervision under Article 203(1) of the Customs Code, it should be borne in mind that, in accordance with the Court's case-law, that concept must be interpreted as covering 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 carrying out the monitoring required by Article 37(1) of the Customs Code (Case C-222/01 British American Tobacco [2004] ECR I-4683, paragraph 47 and case-law cited therein).
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