ATO / TSD Customs business scenarios

The information on this page is based on the Dutch Customs scenario document. Are you looking for more details, additional exceptions or elaborated cases? Then consult the full document ATO Business Scenarios Maritime or contact Dutch Customs.

1. Forms of the ATO

Maritime declarants can submit the ATO in two different ways, namely in the form of:

• TSD message with master and house data, or
• TSD message with master data only.

The TSD is the Temporary Storage Declaration: the message that a declarant must use to submit an ATO to Dutch Customs.

2. Business scenarios

2.1 Non-Union goods

There is no requirement to refer to the ENS in the ATO if the goods were loaded in a Member State of the Union, or in Northern Ireland, Switzerland, Norway, Liechtenstein or Andorra.

2.1.1 The Netherlands is the first port in the Union

For all goods on board the vessel, an ENS has been submitted to the Common Repository (CR). European Customs will then assign an MRN to the submitted ENS (example: 26NL9876).

Submission of the ATO

For goods that are discharged in NL, the ATO is submitted by means of a TSD message. In the TSD, at master level, the MRN of the ENS is stated as the previous document.

2.1.2 The Netherlands is not the first port in the Union

2.1.2.1 Goods for the Netherlands remain on board the vessel in the first port

For all goods on board the vessel, an ENS has been submitted to the Common Repository (CR).

• The ENS has been assigned an MRN (example: 26FR9876).
• In the other Member State (example: France), the goods for NL remain on board the vessel that brought the goods into the Union.

Submission of the ATO

• For goods that are discharged in NL, the ATO is submitted by means of a TSD message.
• In the TSD, at master level, the MRN of the ENS is stated as the previous document

2.1.2.2 Goods for NL are brought to NL via another vessel (Transhipment)

For all goods on board the vessel, an ENS has been submitted to the Common Repository (CR).

• The ENS has been assigned an MRN (example: 26FR9876).
• In the other Member State (example: France), goods for NL are Transhipment onto another vessel.
• Goods are brought to NL under the customs transit procedure (T1, or an electronic manifest for transport by sea if a permit has been issued for this), or are released in France with a REN and then with an MFX. For maritime in the Netherlands, a TSD is always mandatory.
• During the journey from the other Member State to the Netherlands, the vessel does not call at a port outside the Union.

Submission of the ATO

For goods that are discharged in NL, the ATO is submitted by means of a TSD message. In the TSD, it is not necessary to refer to the MRN of the ENS (rule C-CARGO-014).

2.1.3 Register of the ATO (ENS obligation DOES apply)

2.1.3.1 ATO is submitted but the ENS is missing

• When presenting non-Union goods, the declarant must refer in the ATO to the MRN of the ENS.
• Dutch Customs reviews whether the ENS being referred to is known in NL. If yes, the ATO is approved. If no, the ATO is approved temporarily.
• An ATO that has been approved temporarily is revalidated at the moment when the goods arrive in NL. It is reviewed whether the ENS being referred to in the ATO exists in the Common Repository.
• If it turns out that the ENS does not exist in the Common Repository, the ATO is definitively rejected.
• Dutch Customs considers the goods to have arrived when the Port Authority reports the visit number (CRN), included in the ATO by the declarant, as arrived (ATA).
• Solution in case of missing ENS: the shipping agent contacts the party who will still submit the ENS so that the ATO can be definitively accepted.

Unavailability of the Common Repository

In the event of unavailability of the Common Repository, Dutch Customs may decide to activate the emergency procedure.

If Dutch Customs receives the ATA notification that the means of transport from the ATO has arrived in NL, then the goods from the ATO in NL will receive the status presented. Dutch Customs will then retrieve the presentation information (the so-called PN – Presentation Notification) from the ATO and the ATA and forward it to the Common Repository.

The Common Repository then still sends the ENS data to Dutch Customs.

If at that moment the ENS is still not known, Dutch Customs receives a notification that the ENS is not known. Dutch Customs receives a rejection message from the Common Repository with error code 90 (“unknown MRN”). The customs system rejects the ATO based on the received error code.

If Dutch Customs does not receive a message from the Common Repository because it is unavailable, the customs system waits for a message from the Common Repository. The ATO is not yet rejected. Also if the Common Repository rejects the PN message (e.g. because the shipment number is unknown), the ATO remains “provisionally accepted”.

2.1.3.2 ATO approved temporarily

• When the ATO has been approved temporarily, Dutch Customs waits until the time of arrival to determine whether the ATO is definitively approved or rejected.
• The arrival is derived from the PN that results in a message to the CR.
• If the ENS is not known in the CR, Dutch Customs receives a message from the CR that the relevant ENS is unknown and the ATO is rejected.
• If the ENS is known, Dutch Customs receives the ENS data and the ATO is approved.

Are goods allowed to leave the terminal

• No, incoming goods may not leave the RTO because they first have to undergo a security selection on the ENS (stop function).
• As long as the goods are not yet there, no declaration for the next procedure may be submitted (exception: pre-lodged declaration).

2.1.3.3 Missing ENS house filing and register of the ATO

If a Temporary Storage Declaration (TSD) is received that refers to an ENS that is not complete, then the Temporary Storage Declaration is (normally) accepted (final status), provided that the MRN of the ENS to which the TSD refers appears in the CR.

Referring to the ENS is only one of the requirements that the TSD must meet.

Dutch Customs may take enforcement measures to ensure that the ENS house filing is still completed (after discharge, goods remain blocked).

Points of attention

• Is the supplementary declarant whose EORI number is mentioned in the master part of the ENS filing indeed the party that will provide the house data? Is the EORI number correct?
• Was the correct F filing used?

2.1.3.4 Additional points of attention regarding the ATO register

How do we deal with ATA carnets with a very large number of HS codes?

As regards the ATA with the large number of HS codes, there is an agreement that customers with ATA Carnets group the goods with the highest value in the trailer/car. The same applies to NATO Forms, for which there is now already an exception possible in Portbase. No examples are available. The question is whether this will continue to be accepted.

How do we deal with express and postal consignments?

For express consignments and postal consignments, all HS codes currently have to be specified. The question is whether an alternative will become available in the future, possibly under the heading (F34). We currently experience a competitive disadvantage on the Calais-Dover route and hope that a solution is in sight.

Stating the inside package unit in ENS and ATO

A skid is a custom-made frame, usually made of metal, on which multiple goods can be placed. Skids are used, among other things, in the process industry for the (prefab) assembly of a complete installation. As an example, this may consist of a pump, a tank, a heat exchanger and a control panel.

ATO

The total number of packages based on the smallest external packaging unit must be reported. For the ATO, it is not sufficient to only state skids. The declarant must state the cardboard boxes (smallest packaging unit).

ENS

In the ENS, a declarant can limit this to stating skids only.

2.2 Union goods

For Union goods that are transported from a port in the EU to another port, without calling at a port outside the territory, no ENS needs to be submitted. This is not a case of bringing goods into the customs territory.

ATO

• For Union goods that are discharged in NL, the ATO is submitted by means of a TSD message.
• In the TSD, no reference is made to the MRN of the ENS.
• In the TSD, at master level, the so-called “supporting documents” are included with which the declarant makes the Union status known.
• For all goods in the consignment, the declarant must provide data enabling Dutch Customs to review the Union status.

Options for indicating Union status

• C552 T2LSM.
• C619 Shipping manifest
• C620 Document T2LF.
• C621 Proof of customs status.
• N380 Commercial invoice.
• N825 Document T2L.

For goods indicated in the ATO as Union goods, no discharge obligation is created. The declarant must, however, include a reference to the relevant POUS document. This also applies to non-Union goods where one of the following codes is used in the “supporting documents” field.

• C624 Form 302.
• N820 Transit declaration (T).
• N821 External Community transit (T1).
• N822 Internal Community transit (T2).
• N925 TIR Carnet.

2.2.1 Change non-Union status after arrival of goods

• Goods have been discharged in the Netherlands and an ATO has been submitted for these goods.
• The ATO shows that the goods have the status of “non-Union goods”.
• The declarant wishes to adjust the status of the goods in the ATO to “Union goods”.

Change of the ATO

• To adjust the status of the goods, the declarant submits an amended ATO.
• In the amended ATO, at master level, the declarant includes the so-called “supporting documents” by which the declarant makes the Union status known.
• In the amended ATO, no reference is made to the MRN of the ENS, since no ENS is required for Union goods. If the vessel calls at a non-Union port (e.g. the UK), then an ENS obligation applies for all goods on board the vessel.
• For goods loaded in Northern Ireland, no ENS obligation applies. For these goods, the place of loading must be indicated with the place name and the country code (XI) and not with a UN/LOCODE. If the UN/LOCODE is stated, the MRN of the ENS must also be stated in the ATO.
• For all goods in the consignment, the declarant must provide data enabling Dutch Customs to review the Union status.
• The created discharge obligation is reversed by the change of the ATO.
• The declarant can change the ATO themselves, even after arrival of the goods. Unlike the old situation, the declarant no longer has to request the change via the BU department of Dutch Customs.

2.3 Specials

2.3.1 Empty containers and trailers

2.3.1.1 Non-shippers owned

• Empty containers of the inland operator/shipping line.
• No contract of carriage has been concluded for this.
• No ENS needs to be submitted, but an ATO does.

Submitting an ATO for empty non-shippers owned containers

• In the TSD, there is no obligation to refer to the MRN of the ENS.
• In the TSD, the master document is mandatory. The type and number must meet the requirements from the MIG Dutch Customs.
• Based on the TSD, no discharge obligation is created, provided that in the TSD, in the “fullness” field, code A is entered to indicate that the container is empty. This condition applies in the TSD for all levels where empty containers are stated (master, master item, house, house item).
• Declaration of the goods code and weight is mandatory:
  • 86 09 00 90 00 Containers and similar load boxes.
  • Weight of the empty container is not zero. The declarant determines the exact weight.

2.3.1.2 Shippers owned

• Empty containers of someone other than the inland operator/shipping line.
• A contract of carriage has been concluded for this.
• Both an ENS and an ATO must be submitted.
• Whether empty containers must be included in the ENS depends on whether there is a transport order for the relevant empty container. If there is a transport order for an empty container, this is a so-called ‘shippers owned’ container. In that case, the empty container must be declared in the ENS

Submitting an ATO for empty shippers owned containers:

This is done in the same way as for non-shippers owned containers. In the ATO, there are no differences between the two types of empty containers.

2.3.1 Military goods

ENS

• Upon entry of military container consignments into the Union, no ENS needs to be submitted for these military goods on the basis of Article 104(1)(h) GVo.DWU.
• A ‘Master NATO Form 302’ is used, which is submitted for handling to the customs office Rotterdam Maasvlakte, department Bringing In and Taking Out (BU).
• See Dutch Customs chapter 10.00.00 (Bringing in by sea), section 3.5.10 and chapter 12.80.00 Submitting a declaration with Form 302.

ATO

• In TSD: no reference to the MRN of the ENS.
• Has an ENS nevertheless been submitted? Then the reference to the MRN of the ENS in the TSD is optional.
• In the TSD, code C624 (Form 302) must be used. The code is stated under the “supporting documents”. Code C624 can be stated at 2 levels: at consignment level or at house consignment level.
• The TSD must contain the reference number of Form 302. Each Form 302 has a unique reference number that must be stated in the TSD.

2.3.2 Cut & Run

• The unplanned departure of a vessel from the Dutch port before all goods have been discharged for which a Temporary Storage Declaration has been made.
• The vessel then returns to the Dutch port to discharge the remaining goods.
• No new ENS needs to be submitted, as the vessel does not call at non-Union ports.
• If after the unplanned departure the vessel calls at a port outside the Union, then upon return to the NL port to discharge the remaining goods, all formalities must be met (ENS and/or ATO).
• To determine whether the goods have arrived, the visit number of the 1st visit (ATA) is leading.

ATO requirements

• At the first visit, the declarant submits an ATO for the goods that will be discharged in the Netherlands.
• After returning to the Dutch port, for goods not yet discharged during the first visit for which an ATO was already submitted at the first visit, no new ATO needs to be submitted. However, the declarant must ask Dutch Customs for permission to apply this arrangement.
• If goods have been loaded in another port and are discharged in a Dutch port, then an ATO must be submitted for these goods.
• If goods originally destined for NL have been discharged in another EU port, then the ATO for these goods must be annulled.

2.3.3 Second Call (re-entry)

• A vessel that entered earlier leaves the Dutch port after partial discharge and calls at a non-Union port. This concerns a planned departure from the Dutch port.
• At a later time, the vessel returns to the Dutch port it previously left to discharge the rest of the cargo.
• In the previously submitted ENS, a re-entry indicator is required. This must have been indicated by the declarant when submitting the ENS.

Submitting an ATO

• The outstanding goods on the first ATO are annulled (by the declarant of the ATO).
• The declarant of the ATO must submit a new ATO for the second call.
• The new ATO is the same as the first ATO:
  • minus the cargo already discharged during the first visit in the first port of call;
  • minus cargo discharged in the intermediate port of call provided it would have been discharged during the first visit in the first port of call;
  • plus the cargo loaded in the intermediate port of call that will be discharged during the second visit after return to the first port of call.
• There must be a link between the Call Reference Number and the B/L number.

2.3.4 Discharge differences

• Art 145(3) UCC: The latest time at which an ATO must be submitted is at the time the goods are presented.
• Presenting is informing Dutch Customs that the goods have arrived and are available for a customs review.
• In the current situation, declarants do not have to submit a separate presentation message (Presentation Notification - PN). In the Netherlands, this notification does not have to be submitted, except for postal consignments when they arrive at the postal sorting centre.
• Dutch Customs derives the presentation from the data of the Notification of Actual Time of Arrival (ATA) and the Temporary Storage Declaration (ATO).
• This paragraph deals with situations in which no ATO has been submitted for the goods to be discharged and situations with differences between the ATO and the goods actually discharged (“discharge differences”). The situations relate to goods and also to empty containers.
• Note Art 129 UCC (Change and invalidation of an entry summary declaration) and Art 146 UCC (Change and invalidation of a Temporary Storage Declaration).
• For more information, see Dutch Customs, chapter 10.00.00, section 3.7.2 Change in the ATO and invalidation, 3.9 Differences (LINK) and 4 Presenting (LINK).

2.3.4.1 Adding overlanded units to an already submitted and accepted ATO after arrival

• The declarant submitted an ATO, which has been accepted by Dutch Customs.
• After discharge in the Netherlands, it turns out that more goods were discharged than were stated in the ATO.

How should the ATO be changed?

Situation 1: Overlanded units were already included in the ENS

• Declarant submits an adjusted ATO in which the overlanded units have been added (within 24 hours after ATD).

Situation 2: Overlanded units were not yet included in the ENS

• Declarant submits a new ENS for the overlanded units to the Common Repository. The existing ENS cannot be changed, because the goods of that ENS have already been presented (ATO + ATA have been done).
• Declarant submits an ATO for overlanded units with reference to the MRN of the new ENS.

2.3.4.2 Full annulment/invalidation of an ATO after arrival

• The declarant submitted an ATO, which has been accepted by Dutch Customs.
• The vessel with the goods has arrived in NL.
• The goods stated in the ATO are not discharged in the Netherlands at all (e.g. due to diversion).

How should the ATO be changed?

Invalidation of the ATO

• If part of the goods stated on the ATO are not discharged in NL, then the declarant must change the ATO. If none of the goods stated on the ATO are discharged in NL, then the declarant must withdraw the ATO.
• The invalidation of the ATO leads to the withdrawal of the discharge obligation in the customs system.
• The invalidation of the ATO leads to the withdrawal of the presentation information in the Common Repository if NL previously sent a PN message to the Common Repository.
• Dutch Customs does not automatically cancel any review of the shortlanded goods in the Netherlands. The declarant receives a review notification. The declarant must contact Dutch Customs to have the review cancelled manually.

2.3.4.3 Removal of shortlanded units after arrival from a submitted and accepted ATO

• The declarant submitted an ATO, which has been accepted by Dutch Customs.
• The vessel with the goods has arrived in NL.
• Part of the goods stated in the ATO is not discharged in the Netherlands (shortlanded).

How should the ATO be changed?

• Declarant changes the previously submitted ATO. The ENS referred to in the ATO remains intact. Since goods have already been presented, the ENS can no longer be changed.
• Dutch Customs sends the changed presentation information to the Common Repository.
• If shortlanded goods are discharged in another Member State, the declarant must submit an ATO there.
• Any review of shortlanded goods is automatically shifted to the other Member State in case of diversion.
• The ATO can be changed up to a maximum of 90 days after submission.
• The created discharge obligation is adjusted by the change of the ATO.

2.3.5 TSD/REN Transhipment service

• The REN cannot/may not be submitted before the ATO has been submitted. However, the REN can be submitted simultaneously with the ATO, which in practice happens frequently.
• The REN message is triggered at the moment when the ATO is definitively accepted and after ATA of the visit.

Explanation

Confirmation of Exit is not sent following the REN. The ATO is only acquitted once the goods declared in the REN have left the Union. The re-export notification is submitted using electronic data interchange techniques and Customs provides the declarant with a Master Reference Number (MRN). A re-export notification must therefore not be submitted before the actual time of arrival (ATA). For all goods that are loaded on board a vessel to leave the customs territory of the Union, an exit declaration must be submitted. The exit declaration must be submitted by the inland operator by electronically sending the customs manifest at exit (also referred to as “Cargo message” - Customs Manifest at Exit – MFX). The customs manifest at exit must in any case state the MRN of the REN. The customs office of exit confirms, no later than the next working day after the day on which the goods have left the customs territory of the Union, the exit to the customs office of export with the message “results at exit”

2.3.6 Holders of scheduled service authorisation

Holders of scheduled service authorisations (RSS) no longer need to submit an ATO for Union goods after the transition to the new ATO (no later than 16 November 2026, 12:00).

3. Verifications and error handling

The MIG indicates which data must be included in a TSD and whether that data is mandatory, optional or conditional. In addition, the MIG contains so-called Rules & Conditions (R&C). The R&C describe which checks and verifications are carried out. If the data in an ATO does not meet the requirements of the R&C, this may result in rejection of the ATO. If an ATO is rejected, Customs will send a message about this.

The Rules & Conditions listed below are explained in the sections that follow. For each R&C it is also described which action a declarant must take to submit a correct ATO.

3.1 Master B/L number that appears in multiple ATOs

• In the TSD, only 1 master consignment can be referenced.
• If it first references visit A and then visit B, the end result is that the consignment is linked to visit B.

3.2 Warehouse

• For goods on board a passing-through vessel, ATO is submitted by means of a TSD message.
• An incoming passing-through vessel is understood to mean:
  • a vessel arriving from sea (often a coaster) with non-Union goods destined for a port in the hinterland (e.g. Nijmegen or a port in Germany);
  • a vessel that has arrived from sea with non-Union goods which, in the port of first entry, has completed all formalities upon entry and has discharged part of the non-Union goods there, and then proceeds with the remaining non-Union goods to a port in the hinterland.
• The “Warehouse” field (permit number of the RTO storage operator) is mandatory in the TSD. If the permit number is not known, a berth code from the N24 table of the Customs codebook will suffice.
• Passing-through vessels: The declarant must enter an alternative value for the permit number of the RTO storage operator, namely “Passing Through Without Unloading” (rule R-CARGO-033).
• For transport to the hinterland, a T1 document must have been submitted. This must refer to the master B/L number in the TSD.
• Are goods imported into the Netherlands? Then submit an import declaration.
• Are goods stored in the Netherlands? Then submit a storage declaration.
• Are Union goods “brought in”? Then demonstrate Union status by means of ‘supporting documents’ in the ATO.

3.3 Party to be informed

At master level, the following applies in the ATO:

• If the consignee is known, it is not mandatory (optional) to complete the party to be informed.
• If the consignee is unknown, the party to be informed must be completed. This obligation applies only to a TSD with house and master data. For a TSD with only master data, the party to be informed is optional. The consignee must always be completed.
• Code10600 (CL701) means Consignee unknown.

At house level, no party to be informed can be reported and code 10600 does not apply. Here, consignor and consignee are always mandatory.