Amendment after goods are released for the export procedure
If Customs has already released the goods for the export procedure, errors cannot be corrected by the declarant, instead an amendment has to be made by Customs.
A request for amendment or invalidation can be submitted to Customs electronically or in writing by
- the exporter in whose name the declaration was made or
- an agent, who as a representative, lodged the declaration on the declarant’s behalf.
If the export declaration that needs to be corrected has been submitted by an agent acting as an indirect representative, only this agent can request for a correction. If the request for amendment is submitted by an exporter who has not submitted the original export declaration, the request for amendment can only concern such declared goods that have already exited the territory of the EU.
The exporter and any representative used by the exporter has to ensure that the export declaration is correct as it is submitted, so that a possible amendment process does not delay the goods transport. The declarant also has to make sure that no more than one export declaration is made for the goods in question.
When should I present the request for amendment?
A request for amendment has to be presented as soon as the error is detected. The goods cannot exit the customs territory of the EU until the amendment decision has been made and Customs has sent the decision (pdf) as well as the new accompanying document, EAD or ESS, to the declarant or these documents have been printed for the customer at Customs.
A request for amendment can also be presented after the goods have exited the customs territory of the EU, but under certain restrictions, which mainly concern re-export notifications. A request for amendment has to be presented within one year, at the latest, from the date when Customs accepted the export declaration that needs to be amended as received.
Finnish Customs only amends Finnish export declarations, that is, export declarations for goods placed under the export procedure in Finland.
The location of the goods must also be entered in the amendment request; that is, the place in Finland where the goods can be inspected. If the goods are not in Finland, the location information provided in the original declaration is provided in the request.
Filing an appeal with an administrative court
You can lodge an appeal with Helsinki Administrative Court against a decision issued by Customs on your claim for a revised decision. The appeal is subject to a charge.
Address the petition of appeal to Helsinki Administrative Court. Send the petition of appeal to Helsinki Administrative Court, PO Box 120, 00521 Helsinki.
Points to consider
- The export customer's address details
Customs does not usually amend the exporter’s address information retrospectively. Customs’ export system ELEX retrieves the information on the customer primarily from the customer register of Customs, using the Business ID and its extension. In their export declarations, the export customers of Customs have to use the extensions they have been issued.
If Customs cannot find the customer's name and address information in the customer register of Customs, it will be retrieved from the European Commission’s EORI register.
If a registered export customer’s extension (e.g. T0001, T0002) has not been provided in the information on the exporter, then the information of the principal place of business, retrieved from the EORI system, is shown as the exporter’s address information in the decisions.
- Customs procedure
Customs does not usually amend export procedure codes retrospectively. For example, it is not possible to amend the code for permanent export (beginning with 10) to codes for temporary export (beginning with 22 or 23) or to special procedures codes for outward or inward processing (beginning with 21 or 31).
If the exporter has had a valid authorisation for a special procedure at the time of export, for example, for inward or outward processing, a written report on the wrong procedure code can be presented together with the bill of discharge to the supervising customs office. In each individual case, the supervising customs office can consider whether the procedure code can be amended. A penalty fee for providing an incorrect procedure code is then imposed in connection with the amendment. In other cases, the request for amendment of the procedure code is rejected.
Re-exportation from a customs warehouse (3171) can only be corrected to re-exportation (procedure code beginning with 31). If a code for re-exportation, beginning with 31, has not been used in the original export declaration, it cannot be corrected to a code beginning with 31, if the exit of the goods has already been confirmed.
It is possible to correct a procedure code in cases of temporary export where the goods are not returned to the Union, but are e.g. sold after the export has taken place. As such a request for amendment (change of procedure) is submitted, documents that clearly and unequivocally show that this is the case have to be presented as proof.
- Information on a special procedure in export declarations with exit confirmation
This information is
- EU procedure
- national procedure
- code and number of authorisation document
- special mentions concerning customs procedures with economic impact.
- All information in export declarations for excise goods
If the original export declaration contains excise goods and accompanying administrative documents (AAD) are used as the previous document for the goods item, it is not allowed to amend the exporter’s Business ID, commodity codes or net weights of goods items, unless the AADs have also been amended. Furthermore, consignments cannot be removed in these cases.
- Information on the place of exit
The place of exit, shown in the Customs systems and in the decision on release with exit confirmation sent to the customer, is the one where the goods were presented.
The written request for amendment or invalidation must be made with customs form no. 701s (in Finnish) on Customs’ website. The form is sent to Customs by e-mail or by post. The amendment or invalidation request has to contain the MRN or the transaction identifier of the export transaction as well as the reasons for the amendment or invalidation.
In a request for amendment, the customer must provide all the new information affected by the amendment. The status of the export declaration is entered in the form (waiting for release/has been released). The required documents and reports shall be attached to the request.
The one-hour processing time is not applied to the processing of the amendment request. If the export goods have already exited the Union, the amendment is not considered urgent, and Customs will process the request as non-urgent.
Amendment and invalidation request, customs form 701s (in Finnish)
The electronic request for amendment or invalidation can be made either in message format or via the online service. An amendment or invalidation of an export declaration submitted using message exchange can be requested using the online transaction services.
- Online transaction service
An electronic request for amendment or invalidation can be submitted via the Customs Export Declaration Service. The declarant must be an identified user in order to use search criteria to retrieve the declaration that needs to be amended or invalidated.
Via the online Export Declaration Service, it is possible to request an amendment or invalidation of message exchange declarations. To do this, the user selects the search “Export declarations submitted via other channels”.
After retrieving the declaration, the declarant chooses whether to make a request for amendment or invalidation. For guidance, there are published filled-in models of requests for amendment and invalidation in the online export instructions.
The unidentified online declarant must make a written request for amendment and invalidation with attachments, and deliver them to the customs office of export.
- Message exchange
To be able to submit a request for amendment using message exchange, the sender of the request
- must have the EDI sender status for exports
- must use messages according to version 2.1 or newer of the message implementing guidelines
- must have tested the amendment and invalidation messages with Customs.
In message exchange, the customer’s amendment request message is the same as an export declaration message where the code (7) for amendment is given in the field “message function”.
When a correct request for amendment arrives to the customs system, the system sends a message of receipt as a reply and after that either an amendment message or a message of rejection of the request for amendment, as well as a decision in PDF format (a decision on amendment or rejection). If, in the checks on receipt, the request for amendment is found to have the wrong format, the message declarant will only receive a rejection message, no decision on rejection.
The message requesting an amendment is a separate message described in the ‘ELEX Message Implementing Guidelines’ (version 2.1 or newer).
When a correct request for invalidation is received by the system of Customs, the system sends a message of receipt as reply and after that either an invalidation message or a message of rejection of the request for invalidation, as well as a decision in PDF format (either a decision on invalidation or a decision on rejection of the request for invalidation). If, in the checks on receipt, the request for invalidation is found to have the wrong format, the message declarant will only receive a message of rejection of the request for invalidation (see 6.2).
In an electronic request for amendment, the same fields are to be filled in as in the export declaration to be be amended, but with corrected information. In addition, the following information must be provided:
Additional statement code FIXFN concerning the whole declaration (i.e. the consignment to be cleared)
- One of the following reason codes (code explanation in parentheses) describing the information to be corrected is entered as the value of FIXFN in the text field following the code:
12 (data concerning the whole declaration)
13 (trader details)
14 (document details)
15 (transport details)
16 (goods item details)
17 (correction on Customs’ initiative).
- The value 17, correction on Customs’ initiative) is used when Customs asks the customer to correct information in the export declaration. This can happen e.g. after a goods control or when Customs requests a correction of statistical information on foreign trade.
- Even if the declaration contains several requests for amendments to different particulars in the export declaration, FIXFN and its value will be entered here only once, and the code that best describes what needs to be changed will be chosen as the value.
Additional statement code FIXFO concerning the whole declaration (i.e. the consignment to be cleared)
- In the text field following the code FIXFO, the reasons leading to the request for amendment are entered as free-form text.
- The FIXFO code and the free-form explanation relating to it can be used several times in the declaration, if needed.
If a consignment is to be removed, the additional statement code FIXFS is used for the consignment
- All details have to be provided even on a consignment that will be removed as well as the additional statement code FIXFS for removal
- Removing an individual consignment always affects the data concerning the whole declaration (e.g. total gross mass, total number of packages and total number of consignments). These details have to be changed accordingly. Even if removing an individual consignment was the only change, one also has to remember to provide the additional statement codes FIXFN and FIXFO.
If the exporter’s or representative's Business ID or its extension needs to be corrected, the correct trader detail is entered in the text field after the code FIXFO.
- In the request for amendment, the trader details on the exporter or the representative have to be the same as in the original export declaration.
- the FIXFN reason code will then be 13.
When using the Export Declaration Service, the additional statement codes FIXFN, FIXFO or FIXFS are not used. The reason codes are in the drop down list, and the freeform explanation relating to the request for amendment is entered in the appropriate field. As for removal of a consignment, it is enough to remove the consignment, so no code is used.
Examples of situations where an electronic request for amendment is rejected
- the request for amendment is submitted after more than one year from the date when the export declaration to be amended was accepted as received by Customs.
- the original declaration has been submitted by an agent acting as an indirect representative, and the request for amendment is submitted by someone else.
- The declaration code (code list 2) has been changed (example: the original declaration had the code A for a complete declaration and the request for amendment, submitted as a message, has the code C for an incomplete declaration).
- the export declaration is already being amended.
- The original export declaration has been split, and the splitting has not yet been completed.
- The goods included in the export declaration have been placed under a transit procedure that has not yet been discharged.
- the reference number or the additional reference provided in the request for amendment is different from the corresponding reference number in the original export declaration.
- In the request for amendment, there are more consignments than in the original declaration, or in the request for amendment, all consignments have been requested to be removed.
- The request for amendment concerns information that is not to be changed.
- In the request for amendment, none of the details in the original export declaration have been requested to be changed.
An amendment request message sent by a message declarant can also be rejected, if
- the message has been sent using a schema version older than 2.1 or if other schema errors are detected in the message
- the original export declaration's transaction identifier provided in the amendment request message is not valid
- there are inaccurate trader details in the amendment request message
- in the amendment request message, there are formal errors detected in controls of correctness and content.
In these cases, the message declarant will not receive a decision on rejection, only a rejection message.
In Customs’ Attachment Upload Service, the applicant can send the attachments in advance regarding an electronic request for amendment and invalidation; this speeds up the processing.
The attachments can also be sent to Customs’ Electronic Service Centre, spake.vienti(at)tulli.fi immediately after sending the request for amendment and invalidation. The message is sent with the standard heading: AVO + MRN, for example AVO 16FI000000123456E1. Only the messages that have standard format headers can be immediately recognised as messages relating to a request for amendment and invalidation and the request can thus be processed without delay. The message must state that the attachments have been sent to the Electronic Service Centre. If the attachments have not been sent or they cannot be linked to the customs clearance transaction in question, the Electronic Service Centre sends the trader a request for additional information.
If the request for amendment only applies to transport data, then there is no need to send attachments.