ATO
Also known as: supplementary declaration, entry in the records
An ATO is the supplementary declaration for entry in the records. You enter the shipment in your own records on arrival, the goods are released on the basis of that entry, and the full declaration follows within the period set by the authorisation.
What is an ATO and what is entry in the records?
Entry in the records is a simplification: you present the goods by entering them in your own records, without filing a full declaration in advance per shipment. Customs releases on the basis of that entry. Afterwards you file the ATO, the supplementary declaration with the full data set, covering the entries of the agreed period. ATO is that supplementary declaration in DMS. It is not a declaration for temporary storage. Temporary storage is a different procedure, with its own time limit after presentation in the port, and it does not run under this name. Mix up ATO and temporary storage and you file the wrong type, or you miss the authorisation that carries the simplification. The ATO is, in EU terms, the supplementary declaration for entry in the records. IMA is the ordinary import declaration with the full set in advance. STO is placement in a warehouse. ATO is the catch-up step after release on the entry. That order is the whole point: first the entry and the release, then the full declaration.
When may you work with an ATO?
Only with an entry-in-the-records authorisation. That authorisation hangs on your EORI number, describes which goods and which locations fall under it, and sets requirements for the records. As a rule you also need AEO status, because customs releases without having seen the shipment in advance. Without that authorisation the ATO does not exist as a working method. You cannot file a supplementary declaration in DMS over entries that customs has not allowed as a simplification. An IMA per shipment then remains the only path into free circulation, or an STO if you place in a warehouse. The authorisation also sets the period. Often that is a calendar month: all March entries go into the ATO you file in April. Sometimes the time limit is shorter, in days after the entry. What the authorisation says is the hard deadline. An ATO that arrives too late is an authorisation condition that has been breached, not only a late declaration.
When does the customs debt arise on entry in the records?
The customs debt arises at the moment of entry in the records, not at the moment you later file the ATO. Duty, VAT and the exchange rate belong to that first moment. Use the rate of the day of the ATO and you calculate with the wrong month, and at an exchange-rate jump on a month boundary that is a structural deviation. That makes the entry the fiscal moment. The ATO is the notification to customs of what was entered then, not the birth of the debt. An entry you make in March and declare in April carries the rate, the tariff and the measures of March. Codes that change on 1 April do not apply to that entry. That is why the records have to capture the entry with date, time, commodity code, value, origin and quantity, at the moment itself. A list you pull from the WMS at the end of the month and only then assign codes to is not an entry. It is a reconstruction, and at a check it does not hold.
How do you file the supplementary declaration and what is the deadline?
You bundle the entries of the period into one or more ATOs in DMS. Every line has to be traceable to an entry: the same code, the same value, the same quantity. The ATO carries the authorisation, the EORI number of the importer and the form of representation. If the authorisation does not match, DMS refuses the declaration. The deadline stands in the authorisation. Filing by the tenth day of the month after the month of entry is common, but that is not a general legal figure you can copy blindly. What your authorisation names is leading. Exceeding it is a finding on the authorisation, and repeated exceeding puts the simplification itself at risk. The ATO can cover several shipments. That is the gain: you do not type a full IMA per container, you catch up the period in one go. The other side is that a fault in the master data repeats across the whole month. A wrong commodity code on an article entered thirty times is thirty times the same fault in one ATO.
How does customs test the alignment afterwards?
Customs tests whether the ATO adds up to what was entered, and whether the entry adds up to what physically came in. Three layers: the physical goods, the records, the supplementary declaration. Each layer has to explain the previous one. A container on site without an entry, or an entry without a line on the ATO, is a gap. At a check customs asks for the entries of a period, the underlying documents (invoice, packing list, transport document) and the ATOs filed over them. If a source document is missing, or the weight on the packing list differs from the entry, that is a finding, even if the ATO has already been accepted. Acceptance of the ATO is therefore not the end of the road. It is the notification. The test happens afterwards, on the records that made the simplification possible. If you do not keep the entries daily and reconstruct them just before the ATO, you only find that out at that test, months later, when the driver and the papers are gone.
What is the difference between ATO, IMA and STO?
IMA is the ordinary import declaration with the full data set before release. Customs sees the shipment on paper before the goods may enter free circulation. STO is placement in a warehouse: no charge, no free circulation, but an inbound in the warehouse stock. ATO is the supplementary declaration after release on entry in the records. All three types run through DMS, and the ATO data set looks like the IMA. The difference is the moment. For IMA and STO the declaration is the condition for the next step. For ATO the next step (release) has already happened, and you catch the data up. Mix them up and a warehouse shipment goes out as IMA, or a shipment without the right authorisation goes out as ATO, and DMS refuses it. Choose the type on the authorisation and the destination, not on what the previous shipment was. A client with a warehouse authorisation gets an STO, a client with entry in the records an ATO, and the rest an IMA. That rule per client stops a declarant guessing per file.