Missing IE599 - What to Do When You Don't Have Proof of Export?

Your goods have reached the buyer, but the export confirmation never arrived? This is one of the most common problems in indirect export -- when the export declaration was filed in one EU member state but the goods left the EU through a port in another. A missing export confirmation does not mean the goods stayed in the EU. It usually means something went wrong or was delayed in the chain of customs messages.

Why Is the Export Confirmation Essential?

The export confirmation message is the official proof of export generated by the AES system once the export procedure is closed. It matters for two reasons:

1. Customs confirmation -- it proves the goods have left the EU customs territory, closing the export operation in the customs system.
2. Tax confirmation -- it is the primary document entitling the exporter to apply the 0% VAT rate on export supplies (Art. 146(1)(a) of the EU VAT Directive; Art. 41(6) of the Polish VAT Act).

Without the export confirmation (or another admissible document -- more on that below), the exporter must charge the domestic VAT rate (23% in Poland) on the export supply.

Who Is Responsible for Closing the MRN and Generating the Export Confirmation?

MRN closure happens automatically -- no application from the exporter is required. Responsibility is distributed across several parties:

• Carrier / port terminal -- responsible for submitting IE507 (presentation of goods) and IE590 (exit notification) to the customs office of exit.
• Customs office of exit (e.g., Rotterdam, Hamburg) -- processes IE507/IE590 and sends IE518 to the customs office of export.
• Customs office of export (e.g., in Poland) -- based on IE518, generates the export confirmation (CC599C in Poland) and delivers it to the declarant.

Most commonly, the problem lies at the first link -- the carrier or terminal did not submit IE590, so the entire chain never started.

Step by Step -- What to Do When the Export Confirmation Is Missing

Step 1: Check MRN Status (days 1-7 after loading)

Before taking action, make sure enough time has passed. The typical time from loading to export confirmation is 2-5 business days. Check the status:

• In the PUESC system (if you have access)
• With your customs agent / representative
• In the port system (Portbase Track & Trace Export for the Netherlands, DAKOSY EMP/ZAPP for Hamburg)

More: How to Check MRN Status

Step 2: Contact the Forwarder (days 7-14)

If the export confirmation has not arrived after 7-10 business days, contact the forwarder or customs agent at the port of exit. Ask:

• Was the container loaded onto the planned vessel?
• Were IE507 and IE590 submitted to the customs system?
• Did the export pre-notification (e.g., in Portbase) contain the correct MRN?

Step 3: Gather Proof of Exit (days 14-30)

Prepare documents confirming the physical export:

• Bill of Lading (B/L) or other transport document (CMR, AWB)
• Delivery confirmation from the buyer in the third country
• Carrier Track & Trace with delivery confirmation
• Vessel manifest with container number
• Third-country customs documents (e.g., import SAD)

Step 4: File an Enquiry Procedure

If the export confirmation still has not arrived, initiate the enquiry procedure at the customs office of export under Article 335 of Commission Implementing Regulation (EU) 2015/2447. Under Art. 335(1) IA, the customs office of export may, on its own initiative, request information from the declarant where, after 90 days from the release of goods (IE529), it has not been informed of the exit of the goods. The declarant may, however, file a request with the customs office at any time after release under Art. 335(2) and (3) IA.

The application should include:

• MRN
• Date and place of loading
• Identification of the customs office of exit (port)
• Collected proof of exit

Step 5: Await the Customs Decision (2-8 weeks)

The customs office of export verifies the evidence, contacts the customs office of exit, and makes a decision:

• MRN closure -- the export confirmation is generated
• Further investigation -- additional evidence required
• Invalidation of declaration -- if the goods did not leave the EU (Art. 248(2) UCC-DA 2015/2446)

Key Deadlines to Remember

• 90 days from IE529 -- threshold after which the customs office of export may initiate an enquiry procedure ex officio (Art. 335(1) IA 2015/2447). The declarant may file a request with the customs office at any time after release (Art. 335(2)-(3) IA).
• 150 days from IE529 -- deadline for invalidation of the declaration if goods did not exit (Art. 248(2) DA 2015/2446)
• VAT return deadline -- the export confirmation must be obtained before the deadline for the return covering the delivery period or the following period (Art. 41(6)-(7) Polish VAT Act)
• 5 years -- statute of limitations for VAT corrections (Art. 70 Polish Tax Ordinance)

More on VAT deadlines: Export Confirmation and VAT Zero-Rating

What If the VAT 0% Deadline Has Passed?

If the export confirmation was not received before the deadline for the return covering the delivery period NOR the following period:

1. You must apply the domestic 23% VAT rate in the return for the delivery period (Art. 41(8) Polish VAT Act).
2. After subsequently obtaining the export confirmation, you can file a VAT correction and recover the overpaid VAT (Art. 41(9) Polish VAT Act).
3. The correction is available for up to 5 years from the end of the year in which the tax payment was due (Art. 70 Polish Tax Ordinance).

How Can We Help?

We specialize in closing MRNs that were not automatically closed -- particularly in indirect export through Rotterdam, Hamburg, Antwerp, and Bremerhaven.

Our services:

• Diagnosing the cause of the missing export confirmation
• Communication with port systems (Portbase, DAKOSY, C-Point, BHT)
• Communication with foreign customs authorities
• Collecting and preparing proof of exit
• Coordinating the enquiry procedure with the Polish customs office
• Obtaining the export confirmation

Frequently Asked Questions (FAQ)

Legal basis: Art. 335-336 UCC Implementing Regulation (EU) 2015/2447; Art. 41(6)-(9) of the Polish Act on Goods and Services Tax of 11 March 2004; Art. 70 Polish Tax Ordinance. Article updated: March 2026.