All economic operators carrying out business activities subject to EU customs legislation and registered in the EORI system must take immediate steps to comply with these new requirements. This includes any person or company involved in trade, transport or logistics activities requiring interaction with customs authorities, so also importers and exporters.

This issue is particularly acute in countries where a larger number of Economic Operators from other nations are registered (e.g., the Netherlands, Sweden) or where postcodes adhere to a unique national system (such as Ireland).

We now urge you to:

1) Verify the accuracy and completeness of their EORI records immediately.

2) Update their registration to include a valid postcode where necessary.

3) Ensure that all new registrations are complete. (Please note that the postcode field will only become mandatory from Q4 2024 in the EOS system as a centrally developed element).

It is important to know that EORI records can only be updated in the Member State of establishment. This means that from February 2024, if your shipment is held up at the border due to a missing zip code, your shipment will be detained until the national authority of the member state where your company is registered has updated the missing information.

If you have any questions or need support with updating your EORI registration, please do not hesitate to contact us. Our team of Gerlach customs experts is ready to help you to ensure that your trading operations continue without interruption.

Version AES 3.0 was developed to adapt the AES procedure to the requirements of the UCC. It contains a number of innovations that are important for everyday work in customs and export processing.

What changes for participants?

Due to the changeover from AES 2.4 and AES 3.0, there are some changes that are important for exporters.

1. country of origin of the goods

Previously, there was only a subdivision into the corresponding shipping region at the federal state level Germany and countries other than Germany.

From now on it is mandatory to indicate the correct country of origin of the goods. The previously possible indication of the country code QU (unknown origin) is no longer applicable.

If the country of origin is not known when the export declaration is submitted, the presumed country of origin or, alternatively, the country of origin/dispatch can be indicated.

Example: If one has a German federal state as the region of origin (01 - 16), then the country of origin DE must also be indicated.

If you specify a foreign country (99) as the region of origin, then you must also specify a country of origin (e.g. CN for China). For European goods, you can also specify "EU".

This has the consequence that, if necessary, several individual items must be declared in the Export Accompanying Document (ABD) in the future in the case of different origins.

The country of origin of the goods must be stated in your shipment documents. Please provide us with this information in the order in the future.

2. carrier

The carrier is a new legally obligatory information and must therefore be indicated in the export declaration in the future. The carrier is also considered to be the forwarding agent.

If the carrier is not known at the time of submission of the export declaration, the presumed carrier can be indicated.

If you do not provide us with a carrier on your behalf, the declarant (declarant = exporter) is considered the carrier.

The complete address and either the EORI or TCUI (Third Country Unique Identification) number of the carrier must be provided.

Please inform yourself in advance with which forwarding agent or freight company you are shipping the goods and obtain the corresponding addresses as well as the EORI or TCUI numbers.

Please provide us with this information in the order in the future. If you do not provide us with a carrier in your order, we will register you as a carrier accordingly.

3. domestic mode of transport and registration number of the outgoing means of transport.

The registration number of the outgoing means of transport is obligatory information in the export declaration and must always be indicated, among other things, if "road transport" is declared as the domestic mode of transport. If the registration number is known at the time the export declaration is filed, it must be indicated.

If it is not known at the time of submission of the export declaration, the presumed registration number can be indicated.

Please contact your forwarding agent or freight company in advance to find out which registration number must be indicated for the domestic shipment of goods.

In the future, please provide us with this information in the order.

4. mode of transport at the border and registration number of the active means of transport crossing the border.

The registration number of the active means of transport crossing the border is mandatory information in the export declaration and must be declared accordingly.

The same requirements apply as for the registration number of the outgoing means of transport.

Please contact your forwarding agent or freight company in advance to find out which registration number must be given for the cross-border shipment of goods.

In the future, please provide us with this information in the order.

5. indication of registration numbers for chemical substances and preparations within the European Customs Inventory of Chemical Products (ECICS).

In the future, the Chemical Abstract Service number (CAS) and the Customs Union and Statistics number (CUS) must be indicated in the export declaration for certain dangerous goods.

The CAS number (also CAS Registry Number, CAS = Chemical Abstracts Service) is an international designation standard for chemical substances. For each chemical substance (including biosequences, alloys, polymers) registered in the CAS database, there is a unique CAS number.

there is a unique CAS number.

The CUS number is an identifier assigned to chemical substances and preparations within the European Customs Inventory of Chemical Products (ECICS).

ECICS - European Customs Inventory of Chemical Products (europa.eu)

Please provide us with the CAS and CUS number in the order in the future.

6. recording info ECCN number

In the context of U.S. export control, ECCN is the abbreviation for "Export Control Classification Number." The ECCN is an alphanumeric designation used in the U.S. dual-use Commerce Control List (CCL) to classify dual-use items.

An ECCN categorizes goods based on their nature and technical parameters. The Export Control Classification Number serves as an important criterion in U.S. export control for reviewing licensing requirements for export and re-export.

The contents listed in the ECCNs are predominantly identical to those of the goods descriptions in Annex I of the EU Dual-Use Regulation. Both the EU Dual-Use Goods List and the US Dual-Use Goods List are based on decisions of the international export control regimes (e.g. Wassenaar Agreement, etc.).

Please provide us with the EECN number in the order in the future.

7 LRN - Local Reference Number

The LRN represents a reference number (Local Reference Number; LRN) defined and assigned by the participant (and, if applicable, agreed with the competent customs authorities), which is used for the unique identification of the created declaration.

It replaces the previous reference number and is used for the provisional identification of an export transaction between receipt and acceptance.

8. ensuring a smooth processing of your shipment.

If you prepare the export declaration yourself, we need the export accompanying document (ABD) together with your order as a PDF file.

Based on the export accompanying document, all necessary shipping and freight documents will be created promptly, including the transit declaration (T1 or T2) according to the new Europe-wide customs regulations. This includes the mandatory entry of all HS codes, product descriptions and weight in the T1/T2.

Alternatively, if the shipping declaration is created via EDI, please ensure that you send us the electronic copies of the above documents. Our integration team can assist you in setting up API-based automatic document transmission.

To ensure proper customs clearance, the exact trade description of your products is mandatory. General descriptions such as "parts", "machinery" or "electronic components" are not accepted by the authorities and may lead to possible delays due to rejections from the authorities and necessary clarifications from our side.

Please send us the export accompanying documents created on your side in PDF form in the order in the future.

The list is not subsequent. Basic information can be found in ATLAS-Info 0306/2022.

Background: Due to e-commerce, the import of so-called small consignments has been increasing massively for years. In some cases, foreign exporters deliberately declare fictitious low values. Due to the mass of consignments, this led to a disadvantage for domestic suppliers, for whom there was no VAT exemption. In addition, the treasury lost considerable revenue. For this reason, the EU VAT digital package stipulated that the 22 euro threshold should be abolished on 1 July 2021 and import VAT should be due from the first euro.

Now German customs has introduced the new ATLAS module IMPOST (import clearance of postal and courier consignments). This web application is intended to help manage the increase in customs declarations for small consignments under 150 euros. According to German customs, the advantage of ATLAS-IMPOST is that the clearance processes are largely automated, which is particularly beneficial for e-commerce.

Compared to a standard customs declaration, less data has to be declared and the data exchange between the application participant and customs takes place exclusively via the web application. Incidentally, consignments of goods with a value of more than 150 euro as well as goods subject to excise duty or goods subject to prohibitions and restrictions will continue to be cleared via the specialised application “ATLAS customs handling” (standard customs declaration with full data ring).

Requirements for the use of ATLAS-IMPOST

Unlike the previous ATLAS declaration procedure, IMPOST is a web-based tool. In order to use it, companies must first apply for an “Import One-Stop-Shop” identification number (IOSS-ID). The import application is linked to the IOSS registration. Prerequisite: They must be private end customers. VAT is then calculated directly to the EU buyer at the time of sale and declared to the competent tax authority of the respective member state.

In order to be able to take advantage of ATLAS-IMPOST, companies should contact their local Gerlach advisor for information and to discuss any necessary preparations regarding the correct process flow. Contact us now.