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Invalidation of a declaration

The purpose of an invalidation request is not to replace corrections or amendments. Primarily, the export declaration that already has been submitted should be amended, if amending the incorrect detail is permitted.

The invalidation request is submitted via the Customs Clearance Service or via message exchange. In special situations, invalidation can be requested in writing via the Customs Registry Office.

When is invalidation permitted?

Invalidation of an export declaration at the exporter’s or their representative’s request after release for the export procedure is permitted if the customer can prove that the goods in the export consignment will not be exported from the EU territory at all (e.g. if a sale is cancelled).

To cancel pre-lodged export declaration before it has been accepted as received, a written notification is to be submitted to Customs. In that case, Customs sends the customer a rejection message (without a decision in PDF format) with the message “The received export declaration has been cancelled at the customer’s request”.

Invalidation is permitted if it’s no longer appropriate to hold the goods declared for the export procedure under the procedure. For example, invalidation can be requested if a code for a customs procedure with economic impact (3151) has, by mistake, been provided for the export goods, although it is a question of normal export (1000). In that case, in addition to the invalidation, a new export declaration (procedure code 1000) will have to be submitted for the goods.

If Customs has already decided to inspect the goods that have been declared for export, the invalidation request is not accepted until the inspection has been completed.

If invalidation is requested for a declaration for re-export from customs warehouse (3171), the party making the invalidation request will have to present proof that the goods have been returned to the same customs warehouse. The proof can be a customs declaration for placing the goods under the customs warehousing procedure and a verification that the goods have been entered in the records.

Customs can also, case by case, consider allowing an invalidation if discrepancies are detected afterwards in the export declaration or if the details have to be corrected several times.

Customs can also invalidate an export declaration on its own initiative, if the exporter or their representative hasn’t presented an acceptable account of the exit of the goods.

Other things to note

An invalidation request is usually not accepted if the export goods have already exited the EU territory.

There are, however, situations where the consignee, and even the destination country, are detected to be incorrect, with the goods already on the way to the destination and the exit of the goods already confirmed. These changes are normally processed with an amendment request, if the changed country of destination is outside the EU.

If the actual country of destination is an EU country, the whole export declaration is unnecessary. If the case is detected in time, it should be processed as normal invalidation of a declaration, but when the exit of the goods has already been confirmed in the system, invalidating the declaration is no longer unproblematic. In these cases, one must contact the customs office of export (Electronic Service Centre) and ask for case specific instructions. 

Contact information

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).

The invalidation request (FI514) must contain the following:

  • the MRN of the export declaration to be invalidated
  • the date of the invalidation request
  • the reason for the invalidation request, provided using one of the following reason codes:
    • A – Goods placed under another customs procedure
    • D – Duplicate declaration
    • M – Other errors observed by declarant
    • N – The goods did not arrive
    • V – Erroneous declaration data
    • Y – Export cancelled
  • a free-form description of the reason for the invalidation request
  • if a replacement declaration has been submitted, the MRN of the export declaration that will remain valid 
  • the party making the request, that is, the declarant in the original declaration.

Examples of situations where the invalidation request is rejected

  • The export declaration that the request for invalidation concerns has not been accepted as received in Customs’ export system.
  • The export declaration is being processed by Customs (e.g. goods inspection or amendment is under way) when the invalidation request arrives.
  • The goods covered by the export declaration have been placed under the transit procedure that is yet to be discharged. 
  • The invalidation request is made by a party that wasn’t included in the original export declaration.
  • The invalidation request concerns excise goods or re-export goods taken out of the customs territory of the EU.
  • One year has passed since the goods covered by the export declaration to be invalidated were released for the export procedure (date of export).
  • It is a case of export that was initiated in Finland, but the goods were declared for exit via another EU Member State (indirect export) and the export system of this Member State rejects the cancellation notification sent by Finnish Customs.

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.