Discharge
Also known as: T1 discharge
Discharge is the administrative closing of a T1. Customs confirms that the goods have been placed under a follow-up declaration or presented at the office of destination.
What is discharge of a T1?
Discharge is the moment a live T1 is closed administratively. The holder of the procedure has presented the goods at the office of destination or placed them under a follow-up declaration, and customs confirms that the chain is in order. Until then the goods stay under suspension and the guarantee stays committed. In practice this is called T1 discharge, or T1 afmelden in Dutch. The document closes, the MRN leaves the list of open movements, and the potential customs debt on that shipment falls away. As long as that closing is missing, the T1 is an open file for customs. Discharge is not release of the goods themselves. The goods may already have been unloaded or stored. What closes is the transport document they travelled on. T1 status of the goods can continue after that, for example in a customs warehouse, until an import declaration puts them into free circulation.
How does a follow-up declaration discharge the T1?
In the Netherlands discharge usually happens automatically once the follow-up declaration is accepted. That is an import declaration (IMA) if the goods enter free circulation, or a storage declaration (STO) if they go into a customs warehouse. Both refer to the MRN of the T1. That reference is the link DVA uses to close the T1. DVA is the Dutch system for T1 and T2 documents, the successor of what used to be called NCTS. On arrival you first request permission to unload (DVA arrival). Then the follow-up declaration follows in DMS. Only once that is accepted does the T1 close. The order is therefore: arrival, permission to unload, follow-up declaration, discharge. If you do not refer in the IMA or STO, or you refer to the wrong MRN, the T1 stays open while the goods are already cleared. Customs then sees two files that do not join up. That is the most common reason a T1 remains stuck administratively.
What happens if a T1 is not discharged?
If discharge does not follow, customs starts an enquiry procedure. The holder of the procedure must show where the goods went, for example with an accepted MRN of the follow-up declaration or with alternative proof of presentation. If that fails within the set period, a customs debt arises. That debt is calculated as if the goods had been released into free circulation without a declaration. The guarantee given when the T1 was opened is called on. For a high-value container that quickly runs into tens of thousands of euros, even if the goods were in fact cleared long ago and only the reference is missing. An open T1 also blocks guarantee headroom. A comprehensive guarantee covers a maximum amount for all live shipments together. If T1s stay open, that ceiling fills up and DVA refuses new declarations. That is the practical reason to watch discharge daily, not weekly.
Which time limits apply to discharge?
The office of departure sets a time limit when the T1 is opened, within which the goods must be at the office of destination. In Dutch practice that is often fourteen days, but customs can set it shorter or longer, depending on the route and the risk. Exceeding that limit starts an enquiry, even if the goods arrive later. On the warehouse route a second clock then runs. After arrival you request permission to unload. That request must arrive within the validity of the T1. After it is granted you have, in Dutch practice, three days (seventy-two hours) to close the T1 with an IMA or an STO. If you miss those three days, the T1 stays open and the enquiry starts. A common reason is that the data for the import declaration are not yet complete: missing invoice, missing power of attorney, or an inspection result that has not come in. The T1 does not wait for those papers. File an STO then and clear the goods later, instead of leaving the T1 open.
Who is responsible for discharge?
The holder of the procedure is responsible, not the carrier and not the consignee, unless that party is itself the holder. The holder is the party that opened the T1 and gave the guarantee. In practice that is often the forwarder. That party remains the contact until the T1 is discharged, even if the goods are already with the consignee. If another party filed the follow-up declaration, that party must report back the MRN of the IMA or STO so the holder can discharge the T1. Without that report the holder only sees an open document. That is a classic breaking point in chains where one party runs the T1 and another runs the import. With an authorised consignee authorisation the consignee may report arrival without presenting the goods at a customs office. That speeds up the arrival notice, but it does not lift the holder's duty to discharge. Responsibility does not travel with the goods.
How do you monitor open T1s in practice?
Keep a daily list of T1s whose time limit is running, or for which permission to unload is already in but the follow-up declaration is still missing. Filter on MRN, office of destination and remaining days. A T1 that expires tomorrow comes before a T1 that expires in a week. Check per line whether the follow-up declaration already has an MRN. If it does, and the T1 is still open, the reference is missing or the discharge message was not sent. If there is no follow-up declaration, the question is whether the data are complete or whether an STO should close the T1. Those two situations need a different action and must not land in the same bin. Link the list to the guarantee position. A rising balance of open T1s is an early signal that discharge is stalling, before DVA refuses new declarations. Watch T1 and T2 in the same monitor. The distinction between the two matters for the declaration, not for the monitoring process after it.