On 6 February 2024, Portbase and Dutch Customs held an information session regarding upcoming changes concerning T2L(F) cargo, better known as PoUS. Below, we share the questions and answers that were asked there, both in NID and in MLI. We have divided the questions into three topics:
Changes in declaration of T2L(F) cargo
From when does PoUS (Proof of Union Status) take effect?
PoUS is the new European information system through which Customs issues and reviews Union status certificates T2L(F) automatically, and will take effect from 1 March 2024. From that date, the new registration rules apply. T2L(F) Union status certificates are valid for 90 days.
The MRN (Master Reference Number) you receive upon registration must be stated in the ATO (Declaration for Temporary Storage). From this date, you can no longer email/send T2L(F) forms in PDF to the Inward and Outward Department of the Rotterdam Maasvlakte customs office (hereafter abbreviated as BU) of Customs. BU will manually report the arrival in PoUS of the T2L(F) goods and Customs will later review the validity of the T2L(F) certificate. The latter is done by the customer management department of Customs.
From Q3 2025, the customs manifest will also be registered in PoUS. At that point, the TC 12 Permit (Permit for drawing up a shipping manifest after departure) will expire and can no longer be used.
Does this apply to incoming and outgoing cargo of Union goods to and from NL?
Yes, for incoming cargo you receive a T2L(F) MRN from your overseas partner. For outgoing cargo, you provide a T2L(F) MRN to your overseas partner.
Has the Netherlands made any adjustments to the European regulations?
No, all Union countries apply the same rules and policy.
Do I also need to register the T2L(F) in the ATO from 1 March 2024 if this certificate was issued on paper before 1 March?
The current method of registration in the ATO for Union status certificates issued on paper before 1 March 2024 remains unchanged. You register these as C-status and keep a paper copy.
How should I handle T2L(F) Union status certificates issued on or before 29 February?
Due to the 90-day validity, the current arrangement for these T2L(F) Union status certificates is sufficient. After 29 May 2024, the old procedure no longer applies.
Is there a known European emergency procedure if the PoUS system is unavailable?
No, at this time there is no known emergency procedure. Dutch Customs is currently collecting all feedback and sharing it with TAXUD (Taxation and Customs Union Directorate-General).
What needs to be registered for outgoing Union goods to receive an MRN?
TAXUD has not yet provided work instructions; these will follow after 1 March 2024. Dutch Customs is currently working on drafting work instructions, aiming to release these in week 7 of 2024 via douane.nl.
No information is yet known about this from other EU countries, but the deadline is the same. Why was this not announced earlier?
This will differ per EU country. The Netherlands also noticed this late. However, work is now underway with Portbase to implement it. Dutch Customs has drawn up a FAQ list and published it on douane.nl, and together with input from Portbase, this will be maintained.
What can I do with my current TC12 permit up to Q3 2025?
The TC12 Permit (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 are considering applying for this permit, you will need to decide for yourself whether it is still worthwhile.
We have jointly developed the Maritime Single Window, but now Dutch Customs is opting for a separate system for registering Union status certificates. Soon we will also have to deal with ICS 2.0, why is this not being aligned?
The use of PoUS for Union status certificates T2L(F) and soon the customs manifest is a European requirement. The use of ICS 2.0 is also a requirement. The European Union has set out new policy lines for electronic procedures in the Multi-Annual Strategic Plan for Electronic Customs (MASP). Dutch Customs has no influence on the timelines set for this.
Does this process have any effect on Union goods that concern NL-NL?
Correct. No Union status certificate is required for this transport.
In the ATO, no C-status is shown for Union goods. I am not a carrier/agent and therefore cannot state ICT and the MRN of the Union status certificate in the NID. How do I get the Union goods out of the RTO?
The procedure for this situation before 1 March 2024 does not change. There is one difference: you do not have a paper Union status certificate. You only have an MRN. You contact the Inward and Outward Department of the Rotterdam Maasvlakte customs office. They will, based on the MRN, record the arrival of the Union status certificate in PoUS. The CWP (Central Customs Work Point) will unblock the Union goods. With a removal authorisation, you can remove the Union goods from the RTO.
Changes in review of handling T2L(F) cargo
In the ATO, the B/L must be registered as C-status with the T2L(F) MRN, is that for review of whether the MRN is valid?
No, Customs manually reports the arrival of the T2L(F) goods in PoUS. This is not for review of its validity, but for the correct closing of the ATO.
MRN verification (checking validity) is not possible at the moment, the registration of the MRN in the ATO is not valid evidence. How can we manage and review this now? Would it not be better to register as non-Union goods (T1) or Union goods and provide evidence afterwards?
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 for review of the validity of the MRN. However, with the MRN you can search in the PoUS system. If desired, you can make arrangements with the permit holders of the Authorised Issuer Permit - ACP, such as providing a printout of the Union status certificate from PoUS for your administrative records.
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/certificate of the customs status of Union goods/notification is submitted (country code in two letters) (a2);
- Field 3: Unique identification code for message per year and country (an..12);
- Maximum first 6 characters representing the reference number of the customs office;
- Maximum next 6 characters to complete the unique identification by using one specific character that identifies centrally generated MRNs. This specific character must 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 enable detection of an error when entering the entire MRN (an1).
- Example: 23NL000702C00004P0
With the introduction of MRN registration for Union status certificates T2L(F), the process becomes compliant with MRN as we know it from other customs declarations, which is a positive development.
Correct.
Who is responsible in the event of an error in the registration process? For example, a typing error in the MRN number or an unlawfully issued Union status certificate?
The declarant remains responsible for correct administration.
What if the Union status certificate is not reported in PoUS for arrival within 90 days? And is registered as C-status in the ATO?
An agent is responsible for their ATO and Customs will request evidence.
How does Customs review the validity of the Union status certificate? Is a paper administration still required?
This is done digitally from the PoUS system. No paper file is required for certificates registered in PoUS. You are free to make separate arrangements with the permit holders of the Authorised Issuer Permit - ACP for a paper version (printout from PoUS) for your own administration if desired.
Automation options
How do we register a T2L(F) Union status certificate?
In the EU Customs Trader Portal with eHerkenning level 3, which can be registered in both Dutch and English. There is currently no automation possible from your own systems and the EU Customs Trader Portal. You can make printouts from this portal to share with third parties.
This will be manual work. Creating a T2L(F) is an automated process for many parties before 1 March 2024. The data from a declaration for release for free circulation (import - IM4) is used for the automated creation of a T2L(F) Union status certificate. Can Portbase help us digitise this process?
Yes, but this is not foreseen and is impossible within the current timeline. TAXUD has not yet provided clarity on any further development of optimisation/automation. Dutch Customs does hope to bring this feedback as soon as possible.
Can I also work with codes in my ATO, such as code 27 for Transhipment? And then (have) messages processed automatically?
No, not at this time. The operation of REN (Re-Export Notification) with the service Transhipment is outside the scope of this.
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