Re-export declaration
Also known as: re-export, re-exportation
A re-export declaration is the declaration with which non-Union goods leave the customs territory of the EU without ever having been placed in free circulation. You use it from a warehouse or from the terminal, not for Union goods.
When is it re-export and when is it export?
Export concerns Union goods: goods produced in the Union or goods on which the import duties have already been paid. Re-export concerns non-Union goods that have never been placed in free circulation. The difference decides the type of declaration, the charge and the fiscal proof you are left with. On re-export, duty and import VAT have never been paid, so there is also no zero rate to substantiate. What does have to line up is the chain: the lot that goes out has to match the lot that was once entered or presented, with the same commodity code, the same weight and the same quantities. At an authorisation check that is the point where it fails. A distribution centre that supplies both inside and outside the Union from one warehouse stock does both. The shipment to a customer in Germany becomes an IMA. The shipment to a customer in the United Kingdom becomes re-export. The same racking, two types of declaration, and the stock has to be able to show both flows.
When do you also need a T1?
If the goods sit at the terminal of exit, the re-export declaration is enough. They leave the customs territory from the place where they lie under supervision, with no further domestic leg under suspension. The clean variant: one declaration, one MRN, departure from the quay. If they sit in a warehouse inland, for example in Amsterdam while the ship leaves Rotterdam, the shipment first has to move under suspension to the terminal. You open a T1 for that. The re-export declaration alone does not cover that domestic leg. Without a T1, non-Union goods travel the road as if they were free, and they are not. The chain is then STO (or earlier presentation), T1 to the port, re-export at exit. Each link points to the previous one. A T1 that does not refer to the inbound, or a re-export that does not refer to the T1, makes a gap. Discharge the T1 only once the re-export is accepted, not earlier, otherwise the movement stays open while the container is already on the ship.
What has to line up in the warehouse records?
Re-export is an outbound. In the stock that outbound has to write off the inbound: the same code, the same weight, the same quantities, or an explained partial outbound. A lot of a hundred chairs of which fifty go to the United Kingdom leaves fifty chairs on stock. Those fifty stay non-Union goods until they later get a destination of their own. At a check customs lays the re-export declarations next to the inbounds. An outbound without an inbound is goods that never arrived in the records. An inbound without a later outbound or IMA is stock that should still be there. Both are findings, and an unexplained shortage produces a customs debt over the missing pieces. Keep the warehouse lot and the declaration linked, down to the line. A re-export that carries a different commodity code from the STO with which the lot was entered also breaks the chain, even if they are physically the same boxes. Customs reads the codes, not the boxes.
What proof comes back and what does that mean for VAT?
A re-export also has an office of exit and a confirmation that the goods have left the customs territory. That message closes the declaration administratively. It is just not proof for the zero VAT rate, because Union goods were never exported and import VAT was never paid that you would reclaim. Put the exit confirmation of a re-export into a VAT file and you substantiate the wrong thing. The zero rate applies to export of Union goods. Re-export is, in customs terms, non-Union goods leaving the territory, and on the VAT return nothing happens with that shipment as export. What you do watch is whether the confirmation comes back. If it stays out, the re-export stays open and the outbound from the warehouse is not closed. The stock is physically gone, administratively not yet. That gap is harder to explain at a warehouse check than an open export declaration, because the suspension was still running.
What has to happen in advance with the safety and security data?
A re-export also has to be pre-lodged before the goods leave the customs territory. The safety and security data (the exit summary declaration) have a deadline of their own, depending on the mode of transport. For sea freight that sits earlier than for road. File the re-export after the carrier's cut-off and the ship leaves without the declaration being linked. The terminal wants an MRN before the container may go onto the quay. Without that number the shipment stays put, even if the warehouse outbound has already been booked internally. Plan the declaration on the terminal cut-off, not on the moment the WMS writes the stock off. Those two moments rarely coincide. For air freight the window is shorter. The AWB is there, the flight goes, and the re-export has to be in before loading. Open the T1 from the warehouse only when the truck is already rolling and you miss the airline cut-off. Open the T1 and the re-export on the booking, not on the truck's departure.
What goes wrong when the chain from inbound to re-export breaks?
The first gap is a re-export without an inbound. The goods leave the territory, but the warehouse records never held them. Customs then sees a declaration that points nowhere, and the preceding T1 or the summary declaration at entry was never discharged. You get questions on two sides of the same shipment. The second gap is a T1 that was opened for the domestic leg, but whose re-export was never filed. The container sits on the ship, the T1 keeps running, and in time the enquiry starts. Alternative proof of exit can help, but you should simply have filed the re-export before the container went onto the quay. The third is a mix-up with export. Union goods declared as re-export, or non-Union goods leaving as export, set the status wrong. In the first case you claim a zero rate that does not exist. In the second case non-Union goods disappear as if the duties had already been paid. Both surface at a check.