ATO / TSD Customs Business Scenarios

The information on this page is based on the Customs scenario document. Looking for more details, additional exceptions or elaborated cases? Then consult the full document ATO Business Scenarios Maritime or contact 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 a declarant must use to submit an ATO to Customs.

2. Business scenarios

2.1 Non-Union goods

There is no obligation 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).

Submitting 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 NL remain on board the vessel at 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.

Submitting 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 transhipped onto another vessel.
• Goods are brought to NL under the customs transit procedure (T1, or electronic manifest for transport by sea if a permit has been issued for that) or exit 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.

Submitting the ATO

For goods that are discharged in NL, the ATO is submitted by means of a TSD message. In the TSD, there is no need to refer to the MRN of the ENS (rule C-CARGO-014).

2.1.3 Register of the ATO (ENS required)

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.
• Customs reviews whether the ENS being referred to is known in NL. If yes, the ATO is approved. If no, the ATO is provisionally approved.
• A provisionally approved ATO is revalidated at the moment the goods arrive in NL. It is checked whether the ENS referred to in the ATO exists in the Common Repository.
• If it appears that the ENS does not exist in the Common Repository, the ATO is definitively rejected.
• Customs considers the goods to have arrived when the Port Authority reports the visit number (CRN) included by the declarant in the ATO as arrived (ATA).
• Solution in the absence of an ENS: the shipping agent contacts the inland operator, who still submits the ENS so the ATO can be accepted definitively.

Unavailability of the Common Repository

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

If 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 are given the status presented. Customs then retrieves the presentation information (the so-called PN – Presentation Notification) from the ATO and the ATA and forwards it to the Common Repository.

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

If the ENS is still not known at that time, Customs receives a notification that the ENS is not known. 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 Customs does not receive a message from the Common Repository because it is unavailable, then 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 provisionally approved

• When the ATO has been provisionally approved, 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, Customs receives a message from the CR that the relevant ENS is unknown and the ATO is rejected.
• If the ENS is known, Customs receives the ENS data and the ATO is approved.

May goods leave the terminal

• No, incoming goods may not leave the RTO because they must first 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: advance 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 referred to by the TSD appears in the CR.

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

Customs can take enforcement measures to ensure that the ENS house filing is still done (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 supply the house data? Is the EORI number correct?
• Was the correct F filing used?

2.1.3.4 Additional points of attention for ATO registration

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

With regard to 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, where currently an exception is only 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 shipments?

For express shipments and postal shipments, currently all HS codes must 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.

Including 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. For 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 mention skids. You must mention the cardboard boxes (smallest packaging unit).

ENS

A declarant may, in the ENS, suffice by mentioning only skids.

2.2 Union goods

For Union goods that are transported from one 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 in.

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, the so-called “supporting documents” are included at master level, with which the declarant indicates Union status.
• For all goods in the consignment, the declarant must provide data enabling Customs to review the Union status.

Options to indicate Union status

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

For goods declared in the ATO as Union goods, no discharge obligation is created. However, the declarant must include a reference to the relevant POUS document. This also applies to non-Union goods where one of the following codings is used in the ‘supporting documents’ field.

Options to indicate non-Union status for cargo with special circumstances

• 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 “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” with which the declarant indicates Union status.
• In the amended ATO, no reference is made to the MRN of the ENS, since for Union goods no ENS is required. If the vessel calls at a non-Union port (e.g. the UK), then an ENS obligation applies to 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, then the MRN of the ENS must also be mentioned in the ATO.
• For all goods in the consignment, the declarant must provide data enabling 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. In contrast to the old situation, the declarant no longer needs to request the change via Customs’ BU department.

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 Customs MIG.
• 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 listed (master, master item, house, house item).
• Declaration of goods code and weight is mandatory:
  • 86 09 00 90 00 Containers and similar load boxes.
  • The weight of the empty container is not zero. The declarant determines the exact weight.

2.3.1.2 Shippers owned

• Empty containers of a party 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 concerns 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 both types of empty containers,

2.3.1 Military goods

ENS

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

ATO

• In TSD: no reference to the MRN of the ENS.
• Has an ENS been submitted anyway? Then 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 specified 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, since 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 complied with (ENS and/or ATO).
• For determining 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 to be discharged in the Netherlands.
• After returning to the Dutch port, for goods not yet discharged at 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 request permission from Customs to be allowed to apply this arrangement.
• If goods have been loaded additionally in another port and will be discharged in an NL port, then an ATO must be made for those goods.
• If goods originally destined for NL were discharged in another EU port, then the ATO for those goods must be cancelled.

2.3.3 Second Call (re-entry)

• A vessel that arrived 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 remainder of the cargo.
• A re-entry indicator is required in the previously submitted ENS. This must have been indicated by the declarant when submitting the ENS.

Submitting an ATO

• The outstanding goods on the first ATO are cancelled (by the declarant of the ATO).
• For the second call, the declarant of the ATO must submit a new ATO.
• The new ATO is the same as the first ATO:
  • minus the cargo already discharged during the first visit in the first port called;
  • minus cargo discharged in the port called in between, provided it would have been discharged during the first visit in the first port called;
  • plus cargo loaded additionally in the port called in between that will be discharged during the second visit after return to the first port called.
• 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 moment at which an ATO must be submitted is at the moment of presentation of the goods.
• Presentation is notifying Customs that the goods have arrived and are available for a customs review.
• In the current situation, declarants do not need to submit a separate presentation message (Presentation Notification - PN). This notification does not need to be submitted in the Netherlands, except for postal consignments when they arrive at the postal sorting centre.
• Customs Netherlands 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 Customs, chapter 10.00.00, section 3.7.2 Change in the ATO and invalidation, 3.9 Differences (LINK) and in 4 Presentation (LINK).

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

• The declarant has submitted an ATO, which has been accepted by Customs.
• After discharge in the Netherlands, it appears that more goods have been 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 amended ATO in which the overlanded units are 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 from 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 cancellation/invalidation of an ATO after arrival

• The declarant has submitted an ATO, which has been accepted by 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 is not discharged in NL, the declarant must change the ATO. If none of the goods stated on the ATO have been discharged in NL, the declarant must withdraw the ATO.
• Invalidation of the ATO leads to withdrawing the discharge obligation in the customs system.
• Invalidation of the ATO leads to withdrawing the presentation information in the Common Repository if NL previously sent a PN message to the Common Repository.
• Customs does not automatically cancel any review of the shortlanded goods in the Netherlands. The declarant receives a review notice. The declarant must contact 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 has submitted an ATO, which has been accepted by 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.
• Customs sends amended 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 done. However, the REN can be submitted simultaneously with the ATO, which happens frequently in practice.
• The REN message is triggered at the moment the ATO is definitively accepted and after ATA of the visit.

Explanation

Confirmation of Exit is not sent following the REN. Cleansing of the ATO only takes place 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 loaded on board a vessel to leave the customs territory of the Union, an export declaration must be made. The export declaration must be made by the inland operator by submitting the customs manifest at exit electronically (also referred to as the ‘Cargo message’ - Customs Manifest at Exit – MFX). The customs manifest at exit must, in any case, include the MRN of the REN. The customs office of exit confirms, no later than the next working day following 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 permits

Holders of scheduled service permits (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 of an ATO does not meet the requirements of the R&C, this may lead to a rejection of the ATO. If an ATO is rejected, Customs will send a message about this.

Below are the Rules & Conditions that are explained further on. 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 occurs in multiple ATOs

• Only 1 master consignment can be referenced in the TSD.
• If first reference is made to visit A and then to 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 arriving from sea with non-Union goods that has completed all formalities upon entry at the port of first entry and has discharged part of the non-Union goods there, and sails onwards with the remaining non-Union goods to a port in the hinterland.
• The “Warehouse” field (permit number of the RTO storage keeper) is mandatory in the TSD. If the permit number is not known, a berth code from the N24 table of the Customs codebook may be used instead.
• Passing-through vessels: When entering the permit number of the RTO storage keeper, the declarant must enter an alternative value, 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 only applies 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.

Related articles

• Information about New Temporary Storage Declaration
• Frequently asked questions about the new Temporary Storage Declaration (ATO) / TSD
• New IFTMCS specifications (5.8.9)
• Web screens Cargo Declaration Import, after transition to TSD