Declaration chain
Also known as: chain of declarations
The declaration chain is the series of customs declarations that refer to each other, from T1 to import or re-export. Each link points back to the previous one, so customs can follow the goods.
What is a declaration chain?
A declaration chain is the series of declarations that belongs to one shipment, where each next declaration refers to the previous one. Customs wants to know at every moment under which procedure the goods stand. A gap in that chain means the goods stand nowhere for a moment, and that is exactly what the supervision does not allow. A simple chain is T1 to IMA. The container arrives, travels under T1 to the warehouse, and is cleared there. The IMA refers to the MRN of the T1. The T1 is discharged. The chain is closed. A warehouse chain adds an STO: T1 to STO, later IMA or re-export on exit. The chain is watertight or it is not. A missing reference, a wrong MRN or a follow-up declaration that was never filed, produces questions from customs and possibly an additional assessment. The goods can physically already stand in the right place. Administratively they are missing.
Which links occur most often?
On arrival in a Dutch port the consignment first stands under temporary storage, the shipping line's ATO, for up to ninety days. Then a T1 inland follows, or an IMA straight at the terminal. If the consignee chooses the warehouse, the next link is an STO. If he chooses to clear, it is an IMA. From the warehouse the chain continues. Exit into free circulation is an IMA. Exit to another member state is a new T1. Exit to a third country is re-export, and if the goods do not sit on the terminal a further T1 for the stretch to the port. Each movement is a new link, not a free act. A simplified declaration adds an extra step: first a reduced data set, later the supplementary declaration (ATO in DMS terminology, not to be confused with the shipping line's temporary storage). That supplement has a hard time limit. If you let that run, the chain is open at the back.
How do declarations refer to each other?
The reference runs via the MRN. The IMA or STO names the MRN of the T1 as previous document. In DVA the T1 can also point forward to the follow-up declaration, so discharge follows automatically. That two-way reference is what closes the chain. One side is not enough if customs wants to see both sides. The MRN identifies the declaration, not the container. A T1 with twenty containers has one MRN. A shipment with a T1 and a separate IMA has two. The wrong number in the previous-document field is a silent error: the declaration is accepted, the T1 stays open, and weeks later the enquiry arrives. On re-export from the inland warehouse you have two documents one after the other: the re-export declaration and the T1 to the port. That T1 refers to the re-export, or the other way around, depending on how the chain is built. Without that link the trailer may not go on the road, however green the re-export is.
What happens if there is a gap in the chain?
Customs sees a T1 that is not discharged, or warehouse stock that does not match an exit declaration, or a re-export without proof of exit. The result is a question, then an enquiry, and if the proof is missing a customs debt. That debt is calculated as if the goods had been released into free circulation. The gap is often small. A forgotten reference. An STO filed under a different file number. A T1 opened for the wrong office of destination. Physically nothing is wrong. Administratively there is a consignment without a follow-up, and for customs that is the same as a consignment that has disappeared. Repair is possible as long as you have the proof: the MRN of the follow-up declaration, the stock movement, the exit message. The longer you wait, the more the enquiry takes its own course. A chain you close the same day costs a correction. A chain that stays open for six weeks costs a procedure.
How do you monitor the declaration chain?
Watch per shipment the status of each link, not only the last declaration. An IMA with release says nothing about the T1 if the reference is missing. An STO in the warehouse says nothing about the earlier T1 if that is still open. The list is only green when every document in the chain has a closing step. Link the monitoring to time limits. A T1 has a transit period. A lossingsvergunning starts three days. A supplementary declaration has a hard filing period. A confirmation of exit belongs within ninety days. Those clocks run independently. One green link does not stop the other clocks. Make the chain visible to both sides if T1 and import sit with different parties. The holder of the T1 needs the MRN of the IMA. The declarant of the IMA needs the MRN of the T1. Without that exchange the chain is green in two systems and red at customs.
Where does the chain break in practice?
At the hand-over. The terminal has the T1, the warehouse files the IMA, and nobody passes the MRN on. Or the shipping line has the ATO, the forwarder opens a T1, and the reference to temporary storage is missing. Each extra party is an extra chance of a missing link. On inspections. A pre-notification in CLIENT PD produces a release code that must go into the IMA. Without that code the import declaration is incomplete, and the T1 keeps waiting. The inspection chain is a side track of the declaration chain, but it does block it. On inland re-export. The re-export declaration alone is enough if you sit on the terminal. Inland you need a T1 behind it. That extra link is forgotten because the re-export has already been accepted. The trailer may not go on the road, or the T1 is opened too late and the chain gets a one-day gap.