Fallback procedure

The EU has published a so-called business continuity plan (BCP) for situations where system unavailability affects entry summary declarations. You can read about the plan on the EU’s CIRCABC page “EU Advance Cargo Information System (ICS2)”.

If entry summary declarations cannot be processed in the ICS2 system, the EU will make the unavailability known

• with an unavailability notification to operators that have subscribed to the notification
• on the start page of the ICS2 Declaration Service for Safety and Security Data (STI-STP) (Please note: you need the Suomi.fi mandate “Customs clearance” to use the service)
• to the EU member states.

If the unavailability lasts for more than 30 minutes, the EU will confirm with a new unavailability notification that the operators are authorised to commence BCP measures. This means the following:

• The goods can be loaded at the start point of the movement, and they can be transported to the EU territory and unloaded although no safety and security declaration has been lodged.
• However, no arrival notification can be submitted for the means of transport, and no presentation notification for the goods.
• The goods can be presented and cleared only once the ICS2 system is available again and the entry declarations have been submitted for the goods. If the case is urgent, the declarant can contact Customs’ message exchange support.
• No fallback procedure documents are used. The entry summary declarations and arrival declarations are submitted as soon as the systems are available.

Subscribe to unavailability notifications

You can subscribe to the EU’s unavailability notifications via the ICS2 Declaration Service for Safety and Security Data (STI-STP). You can find guidance on how to subscribe to the notifications on CIRCABC, in the public group ”EU Advance Cargo Information System (ICS2)”, in the folder ”ICS2 Business Continuity”. The guidance is titled “How to receive BCP notifications”.

What does the subject line of the notification mean?

The subject line of the unavailability notification describes the type of unavailability and what component is affected. The subject line can read, for example, “Production unscheduled unavailability of ICS2 Common and or ICS2 National component on 21122024 0025 CET”.

The subject line of the notification can provide details such as:

• The type of unavailability can be either scheduled or unscheduled unavailability.
• If the unavailability is scheduled, the notification will also state the estimated end date/time of the unavailability expressed in Central European Time (CET).
• In the case of an update to a notification of unscheduled unavailability, this is stated in the subject using the word “update”.
• In the case of a confirmation message that the operators can activate the BCP, the subject starts with “Production activation of the ICS2 BCP”.
• The subject can specify a certain country if the unavailability only affects the operations of declarants in that country.
• In addition, the time of registration of the unavailability is given in Central European Time (CET).

The subject also states which component of the system is unavailable, for example:

• TAPAS (the EU’s AS4 interface service for direct message exchange, TAXUD Access Point for AS4)
• UUMDS Central (the EU’s Uniform User Management & Digital Signatures system)
• UUMDS Local (Suomi.fi e-identification system for FI-EORI operators)
• ICS2 Common and/or National component (the core of the ICS2 declaration system, i.e. CR system, or the related national system, i.e. the Customs Clearance System UTU in Finland)
• STI (the EU’s Shared Trader Interface).

What to do if the unavailability is in the message declarant’s declaration system

If the unavailability is in the message declarant’s own declaration system, do as follows:

• Submit the entry summary declaration in some other way, for example by using a representative.
• Notify the EU of the start of the unavailability and later of the end of it.
• Activate the BCP when you get the authorisation to do so.
• After the unavailability, submit the declarations that were not submitted during the unavailability.

Provide the declaration in some other way

If the unavailability is in the message declarant’s own system, the declarant is not exempted from the obligation to submit the entry summary declaration.

You can, for example, use a representative or submit the declaration online in the ICS2 Declaration Service for Safety and Security Data (STI-STP). In the service, you can request amendment or invalidation of declarations submitted in the ICS2 Declaration Service for Safety and Security Data (STI-STP), but not of declarations previously submitted via message exchange.

Notify the EU of the unavailability

Message declarants must submit separate notifications on the start and end of unavailability in their own systems via the EU Customs Trader Portal (EUCTP). The notification must be submitted within 30 minutes of the discovery of the unavailability and immediately after the end of the unavailability. The information is also transmitted via the portal to the customs authorities of the other EU countries.

If you are using an IT service provider to transmit messages, you can arrange for the IT service provider to submit the unavailability notification.

If you cannot save the information yourself, you should notify Customs by email of the unavailability on hd@tulli.fi.

Read the guidance on what information about the start and end of the unavailability must be provided in chapters 3.6.1 and 3.6.2 of the BCP on the CIRCABC page “EU Advance Cargo Information System (ICS2)”.

Activate the BCP

The EU sends the information on the activation of the operator-specific fallback procedure to all customs authorities of the member states within 30 minutes of registering the unavailability. At this point, the declarant can activate the BCP, that is, the goods can be loaded onto the means of transport at the departure point and transported to the EU territory and unloaded there.

During the unavailability, you may receive a request for additional information for an ENS you have submitted, or a “Do not load” notification, via alternative communication channels (e.g. by email or phone). The notifications can also be received via the ICS2 Declaration Service for Safety and Security Data (STI-STP) if you have selected them on the tab “Manage Preferences”. You can also reply to a request for additional information for example by email or phone. However, you cannot receive a notification that the processing of the declaration is concluded (“assessment complete”) through these alternative channels.

Submit the declarations after the end of the unavailability

When the unavailability is over, you must submit all declarations that were not sent during the downtime. However, you can only submit a maximum of 400 messages per second.

Things to note in case of TAPAS system unavailability

If the EU’s interface service for direct message exchange, TAPAS, is unavailable, it is forbidden to send messages. During TAPAS unavailability, you cannot obtain even a technical confirmation of receipt for messages.

Message declarants can choose to submit their declarations in the ICS2 Declaration Service for Safety and Security Data (STI-STP). In that case, arrival declarations can also be submitted in the service, if an entry summary declaration has been successfully submitted for the goods in the form of a message to the ICS2 system. A presentation notification can also be submitted for such goods.

Things to note in case of UUMDS system unavailability

If the central component of EU’s Uniform User Management & Digital Signatures system (UUMDS) is unavailable, the messages sent by message declarants will not be processed. The sender of the message receives the error message R04, and the message is rejected. In such a case, the declarant cannot send messages.

The unavailability does not necessarily affect message declarations if no more than 24 hours have passed since the registration of the declarant’s previous message. The declarant’s details will be cached in the TAPAS system for 24 hours. This means that the declarant can continue submitting new entry summary declarations and arrival notifications, as well amendment and invalidation messages, for 24 hours.

During this unavailability, all message declarants will receive response messages to the messages they have sent previously. The response messages can also be sent to the message declarants via alternative communication channels, such as by email or phone. In such a case, the message declarant must reply to them in the same manner, for example by email.

During this unavailability, no one will be able to log in to the ICS2 Declaration Service for Safety and Security Data (STI-STP)

• to submit new declarations
• to view responses to previously submitted declarations
• to request amendment or invalidation of a previously submitted message.

Users of the ICS2 Declaration Service for Safety and Security Data will not see the response notifications to the declarations they have submitted until the unavailability is over. An exception to this is the “Do not load” notification, which is sent to the user of the e-service in an alternative manner, such as by email or phone.

Users of the e-service can also be notified of goods control during the unavailability. The notification about goods control concerning a previously submitted arrival notification will arrive via the system of Finnish Customs when the goods have been presented in the Customs Clearance System (UTU) after their arrival.

Things to note in case of STI or ICS2 common or national system unavailability

If the STI or the ICS2 common or national system is unavailable, you can send declaration messages and related amendment and invalidation requests.

However, the declarations are not processed in the CR system; instead, they remain in queue awaiting registration. In such a case, it is important that you don not send the message again, even though you do not receive a registration message or MRN for, for example, an ENS message.

The response messages generated in the EU’s ICS2 system will also remain in queue and will only be sent to you once the unavailability is over. However, you may receive, for example, a request for additional information or a “Do not load” notification for a previously lodged ENS in an alternative manner, such as by email or phone.

When the STI system is unavailable, you do not have the alternative of submitting declarations in the ICS2 Declaration Service for Safety and Security Data (STI-STP).

A temporary storage declaration for goods arriving directly from another EU country (FI337 or FI335) is submitted only after the service interruption is over. The goods may be unloaded in a port area or at an airport without any separate notification.

If the goods need to be released during the service interruption, the data should be submitted to the customs office of entry using fallback procedure documents in the manner specified in the instructions regarding the entry summary declaration. However, the time limits specified for the entry summary declaration don’t apply to temporary storage declarations submitted under the fallback procedure.

If goods arriving by road are presented to the customs office at the border together with the reference number MRN for the entry summary declaration during a service interruption in the system of Finnish Customs, Customs makes the necessary presentation entries into the system when the service interruption is over.

If the service interruption occurs during the arrival of a means of transport by sea or air and the operator isn’t able to submit an arrival notification (IE3N06) for the means of transport, the notification should be submitted electronically as soon as the service interruption is over. For unloaded goods, an entry summary declaration (FI332) can exceptionally be submitted directly, and the arrival notification will be submitted to the ICS2 Declaration System for Safety and Security Data when the interruption is over.

If goods arriving by sea, air and rail are to be declared during a service interruption in a situation where the entry summary declaration has been submitted electronically but the arrival notification and presentation cannot be submitted, the transport company provides the customs office of entry with the following information:

• for goods arriving by air: flight number and time of arrival
• for goods arriving by sea: name of the vessel, IMO number, Portnet number and time of arrival
• for goods arriving by rail: train list.

In the customs declaration, the MRN and goods item number of goods as well as the transport document number are provided in the previous document details, but the fallback procedure code is provided as the document code. 

If the warehouse keeper can’t submit an unloading report (FI364) to Customs due to a service interruption, it will be submitted to Customs when the service interruption is over.

Delays in the warehouse keeper’s notifications caused by a service interruption will not prevent other customs clearance of the goods.