Land Transport Exports and MRN Problems - What You Need to Know

Exports of goods outside the EU do not happen exclusively by sea. A significant proportion of cargo leaves the European Union by road or rail - through land border crossings. The export procedure and the MRN apply on identical terms, but in practice land transport exports generate their own set of problems. Our speciality is seaports, but we regularly help clients whose cases involve land borders - particularly when the routing of the goods has changed.

How Does Land Export Work?

The mechanism is the same as for maritime export. The customs agent files an export declaration in the AES system, receives an MRN, and the goods set off towards the point where they will leave the EU customs territory. The difference is that instead of a seaport, the point of exit is a land border crossing.

At the border crossing, the customs office of exit should confirm the physical departure of the goods from the EU. After confirmation, the customs system closes the export procedure, and the exporter receives the the export confirmation message - the document required for the VAT zero rate.

Key stages of land export:

1. Export declaration - filed in the AES system, with the customs office of exit code corresponding to the border crossing (not a seaport).
2. Transport to the border - the driver or rail operator transports the goods to the designated border crossing.
3. Presenting goods at the border - the driver presents the export documents (EAD printout with MRN) to customs officers.
4. Procedure closure - the customs office at the border confirms the departure of the goods, and the MRN is closed.

Typical Border Crossings for Land Export

Goods leaving the EU by land pass through one of many border crossings. Here are the most commonly encountered directions:

EU-Ukraine and EU-Belarus Borders

Crossings such as Dorohusk, Hrebenne, or Terespol (on the Polish-Ukrainian and Polish-Belarusian borders) handle exports to Ukraine and CIS countries. This is one of the main land export directions from Central Europe. Clearance times can be long due to queues and limited crossing capacity. Note: the situation at the Polish-Belarusian border is subject to change - before planning transport through Terespol, check the current status at the relevant border authority website.

EU-Turkey Border (Bulgarian-Turkish)

The Kapitan Andreevo / Kapikule crossing is the most important land export point from the EU to Turkey. Road transport from Central Europe to Turkey typically takes 3-5 days, running through the Czech Republic, Slovakia or Hungary, then Bulgaria.

Dover / Folkestone (UK After Brexit)

Since Brexit, exporting to the United Kingdom via the English Channel (Dover-Calais ferries or the Eurotunnel) is effectively a land export from the perspective of the customs procedure on the EU side. More on this topic: Exporting to the UK After Brexit.

EU-Switzerland and EU-Norway Borders

Crossings at the borders with EFTA countries (e.g., Basel on the German-Swiss border, Chiasso on the Italian-Swiss border, Norwegian-Swedish crossings). Although Switzerland and Norway have agreements with the EU facilitating trade, they are formally third countries - exports require an export declaration and MRN.

Internal EU Borders (e.g., Poland-Germany) - Caution!

Crossings within the EU, such as the Polish-German border, are not points of exit from the EU customs territory. Transport across such borders is internal EU movement. The MRN is closed only at the external EU border - e.g., at a seaport in Hamburg or at the Bulgarian-Turkish border.

Common MRN Problems with Land Transport Exports

In our practice we see several recurring problems that prevent MRN closure in land transport exports:

1. Driver Did Not Present Documents at the Border

This is the simplest yet most common problem. The driver passes through the border crossing but does not present the export documents (EAD printout with MRN code) to customs officers. The goods physically leave the EU, but the customs office has no information about the export declaration - the MRN remains open.

Causes: lack of communication between the forwarder and driver, lost documents, oversight of the procedure (especially when the driver is not accustomed to handling customs formalities).

2. Wrong Customs Office of Exit Code in the Declaration

The customs agent enters a seaport code (e.g., Rotterdam) in the export declaration, but the goods actually travel through a land crossing (e.g., Dorohusk). Or the reverse - a land crossing was declared but the goods end up going through a seaport. The discrepancy between the declared and actual customs office of exit blocks automatic MRN closure.

3. Goods Crossed Through a Different Border Point Than Planned

The declaration specifies one border crossing, but the driver - due to traffic, breakdown, or route change by the forwarder - crossed through a different one. The customs system expects closure at office A, but the goods passed through office B. Even if both offices are on the EU external border, the discrepancy creates a problem.

4. No Automatic MRN Reading at the Crossing

Some border crossings have automatic code reading systems (scanners). If the system fails to read the MRN code from the driver's document or from the vehicle registration linked to the declaration, the procedure will not be automatically closed. This requires manual intervention, which does not always happen.

5. Delays on the Third-Country Customs Side

At some crossings (particularly on the borders with Ukraine, Belarus, or Turkey), clearance takes many hours, sometimes days. During this time, the MRN status in the EU system may get "stuck" - the customs office of exit on the EU side does not update the information, and the exporter waits for an export confirmation that never arrives.

Land vs Maritime Export - Key Differences

From a customs law perspective, the export procedure is identical. The differences emerge in operational practice:

In summary: in maritime exports, MRN problems typically arise from data discrepancies in port systems. In land exports, the main source of problems is the human factor - errors by the driver, forwarder, or customs agent.

When a "Land" Export Becomes "Maritime" - and Vice Versa

This is a scenario we encounter frequently. It looks like this:

1. The exporter plans to ship goods through a seaport (e.g., Hamburg). The customs agent files the export declaration with the customs office of exit code corresponding to the seaport.
2. During transport, a decision change occurs - the forwarder reroutes the cargo to a land route (e.g., through Bulgaria to Turkey), because it is faster or cheaper.
3. The goods leave the EU through a land border crossing, but in the customs system the MRN is waiting to be closed at the seaport, which will never happen.

It also works the other way around - goods were intended to go by land but ended up at a seaport. In both cases, a discrepancy between the declared and actual customs office of exit arises.

How to Avoid This Problem

• Inform the customs agent about route changes - if you know the routing has changed, the agent can submit a correction to the export declaration with the correct customs office of exit (provided the goods have not yet left the EU).
• Establish a fixed procedure with the carrier - the driver should know that at every border crossing they must present export documents, regardless of what is written in the declaration.
• Monitor MRN status - if the MRN is still open several days after the planned exit, this is a signal that something went wrong. The sooner you react, the easier the problem is to resolve.

FAQ - Land Transport Export and MRN

Legal basis: Regulation (EU) No 952/2013 (Union Customs Code), Articles 269-274 (export procedure). Commission Implementing Regulation (EU) 2015/2447, Articles 329-336 (customs office of exit, enquiry procedure). VAT Directive 2006/112/EC. This article is for informational purposes and does not constitute legal or tax advice.