Union status of goods

Sea transport

Union status must be proved, when Union goods are transported on a vessel by sea between different locations in the customs territory using a route, which is not subject to an authorisation for regular shipping traffic as referred to in customs legislation. For example, if a vessel carries goods from Hamburg via the port of Saint Petersburg to Kotka, proof of Union status must be provided when the vessel arrives in Kotka. 

A document that indicates Union status can only be used once, i.e. when it is presented for the first time to Customs in the destination country. If not all goods in the document proving the Union status of the goods are presented at the same time, the goods that were not presented must have their own separate document of registration or proof of Union status. 

If Union goods from the same vessel are unloaded in different ports of destination, the goods presented in each port must have their own proof of Union status.

Air transport

The Union status must be proved when the goods have been transported via a non-EU airport back to the EU. For example, when a flight from Paris travels via an airport in London to Helsinki, the Union status must be proved when the flight arrives in Helsinki. 

Road transport

The Union status must be proved, when goods are transported part of the way outside the EU and arrives back to the EU territory. For example, when goods manufactured in Finland are transported via Switzerland to Italy, the Union status of the goods must be proved upon arrival in Italy. 

• The T2L proof registered in the EU:s Proof of Union Status (PoUS) system, also ones confirmed by the authorised issuer
• T2LF proof registered in the EU’s Proof of Union Status (PoUS) system for goods, which are transported to a special fiscal territory of the EU, from such territories or between such territories.
  
  Areas that are part of the EU customs territory but not the EU fiscal territory are the Åland Islands, Mount Athos, Guadeloupe, Martinique, Mayotte, French Guiana and Réunion, the Channel Islands and the Canary Islands. 

An approved registration request receives an MRN and a proof document that can be printed out from the Proof of Union Status (PoUS) system. You can send the proof (SRD = Status Registration Document) for example to the consignee of the goods. The proof is valid for 90 days from its registration. At the destination, the operator presenting the goods needs the MRN and the proof document to prove the Union status of the goods.

Check the instructions on how to use the Proof of Union Status (PoUS) system.

Documents other than those registered in the Proof of Union Status (PoUS) system proving the Union status are: 

• Details in a transit declaration for goods place under a T2 transit (for example, between two countries of the Union, e.g. from Finland to Switzerland to Italy and the goods have not been placed under the export procedure)
• For goods arriving by sea, the shipping company’s cargo manifest confirmed by the authorised issuer (with a “C” indicating the Union status of the goods). Read the instructions for the authorised issuer on the page Instructions for holders of authorisations.
• When the value of the goods is no more than 15 000 euros, you can use an invoice or a transport document that only contains Union goods and at least the following details:
  • code “T2L” or “T2LF”
  • full name and address as well as signature of the consignor, or if there is no consignor, the same details of the person concerned
  • competent customs office (FI002000)
  • number of packages, their type, marks and numbers, goods description, gross mass of the goods in kilograms, value of the goods
  • container numbers, if the goods were loaded into containers

However, it pays to request endorsement/registration of the Union status in the Proof of Union Status (PoUS) system, because it can make the customs clearances easier at the destination. 

Note: For Union goods with a value over 15 000 euros, a registration of the Union status must be requested in the Proof of Union Status (PoUS) system. This also applies to the authorised issuer.

• The fishing logbook, landing declaration, transhipment declaration or the data from the vessel monitoring system (this is not required for vessels under 10 m in length).
• TIR Carnet or ATA Carnet, NATO 302 document or EU 302 document, when the document is indicated with “T2L” or “T2LF”. The Union goods must be clearly separated from other goods, so that the marking “T2L” or “T2LF” can be seen to concern only union goods. An endorsement of the marking must be requested from the customs office of departure.
• Registration plates and registration documents for a motor vehicle registered in a Member State of the Union.
• Administrative document (e-AD or e-SAD) from the EMCS system to be used when moving excise products, when the goods have not been placed under the export procedure or the outward processing procedure.

Other than written proof can be:

• packaging, pallet or similar equipment (not a container), which can be identified as belonging to a person established in the customs territory of the Union
• oral declaration for goods transported by a traveller, when the goods are not transported for commercial purposes
• a traveller, who is not an authorised issuer, can request to receive the registration document 1165e for proof of customs status of the Union goods

Validity of the T2L or T2LF proof

• The proof indicating the Union status is valid for 90 days. In the Proof of Union Status (PoUS) system, a longer validity can be requested for justified reasons in the request for endorsement/registration.
• The document proving Union status, for example the authorised issuer’s shipping company’s cargo manifest or a fallback procedure document, is valid for 90 days from the date of endorsement. 
• If the validity of the declaration ends before the goods are presented at the destination, a new request is made in place of the old one. The validity of the proof cannot be extended.

Amendment and invalidation of the T2L and T2LF proof

• The proof of Union status cannot be amended. If the details change, a new request must be made in the Proof of Union Status (PoUS) system. 
  • If a new request is made after the departure of the goods, the MRN of the original declaration and the detail “replacement declaration” can be added to the description of the additional information code “99210 - Issued retrospectively”.
• Invalidation of the proof of Union status of the goods cannot be requested.
• The proof of Union status is invalidated automatically once it is no longer valid.

Information from the Proof of Union Status (PoUS) system regarding the request can be received by email, for example, when an endorsement is received or additional information is requested. The user’s email address must be added to the user information. 

• Always enter the goods item number in the section “goods reference” under the tab “Container details”. This should be done also when there are goods from the same goods item in several containers, and there is only one goods item in the request. 
• Several different packaging methods can be declared in one goods item. The packaging methods are added to the goods item with the + button. 
• The number of packages are not entered for bulk goods and adding the shipping marks is optional. Packaging methods for bulk goods: VQ, VG, VL, VY, VR, VS and VO.
• The goods are entered in the request by goods item, with the commodity codes at the level of six digits. 

Additional documents

The additional document must be such that it helps to confirm the Union status of the goods either directly or via the company’s records. The additional document can be e.g. an invoice, a pro forma invoice, a manifest or a consignment note. 

• The additional document is mandatory in the registration request
• The number of the additional document or the attached document can only be added to the declaration subsequently if Customs requests it. 

• The attachment to the request can contain the details of several buyers/consignees if the consignment in question has several operators.
• However, providing an attachment in the presentation notification is optional.

Check the instructions on how to use the Proof of Union Status (PoUS) system.

• Providing an attachment in the presentation notification is optional.
• If the penultimate character of an MRN proving the Union status of goods endorsed or registered in Spain is ‘M’, the goods are presented in the EU’s Proof on Union Status (PoUS) system.
• The submission of the presentation notification has the same time limit as the presentation of goods for temporary storage: Presentation notification (FI332), arrival notification and presentation IE347)
• The goods can be presented to Customs when they have arrived and are available for inspection by Customs. Goods that are on their way cannot be presented.
• You do not need to submit a separate declaration for temporary storage or an entry summary declaration, when the Union goods have proof of Union status and an MRN obtained from the Proof of Union Status (PoUS) system. In this case, the goods are presented with the MRN obtained in the Proof of Union Status (PoUS) upon arrival in Finland.

If the container is commercial goods, and the Union status must be proved at the destination and the value is over 15 000 euros, endorsement/registration of the Union status must be requested from the Proof of Union Status (PoUS) system. 

• Basic principles for Union goods (Article 5(23)(24) of the Union Customs Code) 
• Presumption of customs status of Union goods (Article153 of the Union Customs Code)
• Presumption of customs status of goods (Article 119 of the Commission Delegated Regulation) 
• Means of proof of the customs status of Union goods (Article 119 of the Commission Implementing Regulation) 

Customs legislation