Portbase and the Dutch Customs had organised a meeting concerning changes that are in effect after 01-03-2024. We hereby share all questions and answers we received that day and divided them by three subjects.
Changes in T2L(F) cargo declaration
Q1: When does PoUS (Proof of Union Status) come into effect?
A1: PoUS is the new European information system with which Customs automatically issues and checks Union status certificates T2L(F) and will come into effect from 1 March 2024. The new registration rules apply from that date. T2L(F) Union status certificates have a validity of 90 days.
The MRN (Master Reference Number) that you receive upon registration must be stated in the ATO (Temporary Storage Declaration). From this date you cannot email/send T2L(F) forms in PDF to the Entry and Exit Department of the Rotterdam Maasvlakte customs office (hereinafter abbreviated as BU) of Customs.
BU manually reports the arrival in PoUS of the T2L(F) goods and Customs later checks the legality of the T2L(F) proof. Customs' customer management department does the latter.
From Q3 2025, the customs manifest will also be registered in PoUS. At that time, Permit TC 12 (Permit for drawing up a shipping manifest after departure) will also expire and can no longer be used.
Q2: Does this apply to incoming and outgoing cargo of Union goods to and from the Netherlands?
A2: Yes, for incoming cargo you will receive a T2L(F) MRN from your overseas partner. For outbound cargo, you supply a T2L(F) MRN to your overseas partner.
Q3: Does the Netherlands have any adjustments to the European regulations?
A3: No, all Union countries apply the same rules and policies.
Q4: Do I also have to register the T2L(F) in the ATO as of March 1, 2024 if this certificate was issued on paper before March 1?
A4: The current method of registration in the ATO for Union status certificates issued on paper before 1 March 2024 remains unchanged. You register this as C status and keep a paper copy.
Q5: How should I handle T2L(F) Union Status Certificates issued on or before February 29?
A5: Due to the validity of 90 days, the current regulations surrounding these T2L(F) Union status certificates are sufficient. After May 29, 2024, the old procedure will no longer apply.
Q6: Is there a European emergency procedure known if the PoUS system is not available?
A6: No, there is no emergency procedure known at this time. Dutch Customs is currently collecting all feedback and sharing it with TAXUD (Taxation and Customs Union Directorate-General).
Q7: What must be registered for outgoing Union goods to receive an MRN?
A7: TAXUD does not yet have work instructions available, which will only be available after March 1, 2024. Dutch Customs is now developing work instructions, with the aim of releasing them in week 7, 2024 via redactie.nl.
Q8: No information is yet available from other EU countries, the deadline is the same. Why wasn't this announced earlier?
A8: This will differ per EU country. The Netherlands also noticed this late. However, we are now working with Portbase on its implementation. Dutch Customs has drawn up a FAQ list and posted it on redactie.nl and this will be maintained together with input from Portbase.
Q9: What can I do with my current TC12 permit until Q3 2025?
A9: The Permit TC12 (Permit for drawing up a shipping manifest after departure) will expire in Q3 2025. Until then, the permit can be used, as long as the goods are registered as C status. If you intend to apply for this permit, you must decide for yourself whether it is still worthwhile.
Q10: We jointly developed the Maritime Single Window, but Dutch Customs has now opted for a separate system for the registration of Union status certificates. We will soon also be dealing with ICS 2.0, why is this not being brought into line?
A10: The use of PoUS for Union status certificates T2L(F) and soon the customs manifest is a European obligation. This is also the case with the use of ICS 2.0. In the European Union, new policies for electronic procedures have been established in the Multi-Annual Strategic Plan for Electronic Customs (MASP). Customs Netherlands has no influence on the timelines set for this.
Q11: This process has no effect on Union goods that concern NL-NL?
A11: Correct. No proof of Union status is required for this transport.
Q12: No C status is stated for Union goods in the ATO. I am not a shipping company/shipbroker and am therefore not allowed to mention ICT and the MRN of the Union status certificate in the MID. How do I get the Union goods from the RTO?
A12: The procedure for this situation before March 1, 2024 will not change. There is one difference, you do not have a paper proof of Union status. You only have one MRN. You contact the Entry and Exit Department of the Rotterdam Maasvlakte customs office. They report the arrival of the Union status certificate in PoUS based on the MRN. The CWP (Central Work Point Customs) unblocks the Union goods. With a fiat removal you can remove the Union goods from the RTO.
Changes in control of T2L(F) cargo handling
Q13: In the ATO, the B/L must be registered as C status with the T2L(F) MRN, is this to check whether the MRN is valid?
A13: No, Customs manually reports the arrival of the T2L(F) goods in PoUS. This is not to check whether it is legal, but to ensure correct debiting of the ATO.
Q14: MRN validation (checking validity) is currently not possible, registration of the MRN in the ATO is not a valid burden of proof. How can we manage and control this? Isn't it better for me to register as non-Union goods (T1) or Union goods and provide evidence afterwards?
A14: In the T2L(F) MRN, the 17th letter is a 'P'. The letter 'P' indicates that it is a Union status certificate registered in PoUS. This is not sufficient to check the validity of the MRN. You can use the MRN to search the PoUS system. If desired, you can make mutual agreements with the permit holders of Authorized Issuer Permit - ACP, such as providing a printout of the Union status certificate from PoUS for your administrative workload.
The MRN has the following structure:
- Field 1: last two digits of the year of formal acceptance of the declaration (YY) (n2);
- Field 2: Identification code of the country where the declaration/proof of the customs status of Union goods/notification is lodged (country code in two letters) (a2);
- Field 3: Unique message identifier by year and country (an..12);
- Maximum the first 6 characters representing the customs office reference number;
- Up to the next 6 characters to complete the unique identification using one specific character that identifies centrally generated MRNs. This specificity may not be used by national PoUS systems when generating MRNs at national level.
- Field 4: Procedure identification “P” (a1);
- Field 5: Check digit for the entire MRN to allow detection of an error when recording the entire MRN (an1).
Example is: 23NL000702C00004P0
Q15: With the arrival of an MRN registration for Union status certificates T2L(F), the process becomes compliant with MRN as we know it for other customs declarations and that is a positive development.
Q16: Who is responsible if there is an error in the registration process? For example, a typographical error in the MRN number or an unlawfully issued Union status certificate?
A16: The submitter remains responsible for correct administration.
Q17: What if the Union Status Certificate is not reported in PoUS within 90 days before arrival? And is it registered as C status on the ATO?
A17: A shipbroker is responsible for his ATO and Customs will ask for proof.
Q18: How does Customs check the legality of the Union status certificate? Is paper administration still required?
Q18: This takes place digitally from the PoUS system. No paper file is required for evidence registered in PoUS. You are free to make separate agreements with the permit holders Authorized issuer permit - ACP for a paper version (print from PoUS) for your own administration if desired.
Q20: How do we register a T2L(F) Union Certificate of Status?
A20: In the EU Customs Trader Portal with eHerkenning level 3, which can be registered in both Dutch and English. No automation is currently possible from your own systems and the EU Customs Trader Portal. You can make prints from this portal to share with third parties.
Q21: This will be manual work. Creating a T2L(F) will be an automated process for many parties before March 1, 2024. The data from a declaration for release for free circulation (import - IM4) is used to automatically draw up a Union certificate of status T2L(F). Can Portbase help us digitize this process?
A21: Yes, but that is not foreseen and impossible in the current timeline. TAXUD has not yet provided clarity on any further development of further optimization/automation. Dutch Customs hopes to provide this feedback as quickly as possible.
Q22: Can I also work with codes in my ATO, such as code 27 for Transhipment? And then automatically process messages?
A22: No, not at the moment. The operation of REN (Re-Export Notification) with the Transhipment service is not covered by this.
If you have any new questions concerning PoUS, please contact our Customer Service.