MRN Enquiry Procedure - 90-Day Rule under Art. 335 IA 2015/2447
The MRN enquiry procedure is a formal customs procedure under Article 335(1) of Commission Implementing Regulation (EU) 2015/2447 to the Union Customs Code. Where, after 90 days from the release of goods for export, the customs office of export has not been informed of the exit of the goods, it may request the declarant to inform it. If your MRN remains open and you are missing the export confirmation, this article explains how the procedure works and what your options are.
What Is an Enquiry Procedure?
The enquiry procedure (German: Nachforschungsersuchen, Polish: postepowanie poszukiwawcze) is a formal customs procedure initiated when the export confirmation message has not been generated automatically following an export shipment.
The legal basis is Article 335 of Commission Implementing Regulation (EU) 2015/2447 to the Union Customs Code (UCC, Regulation 952/2013). The purpose of the procedure is to officially establish whether the goods have in fact left the customs territory of the European Union.
The mechanism is straightforward: the customs office of export (e.g., in Poland, Germany, or another EU Member State) contacts the customs office of exit (typically at the port through which the goods were shipped) and requests confirmation that the goods have departed. If the office of exit confirms the exit - the MRN is closed and the exporter receives their export confirmation.
Without the enquiry procedure, an open MRN remains unresolved - and the exporter has no proof of export for VAT purposes.
Enquiry Period under Art. 335 IA 2015/2447 (90 Days)
Article 335(1) of Commission Implementing Regulation (EU) 2015/2447 provides that where, after 90 days from the release of goods for export, the customs office of export has not been informed of the exit of the goods, it may request the declarant to inform it. This is a discretionary power, not a mandatory action.
| Parameter | Value |
|---|---|
| Enquiry trigger period (ex officio) | 90 days from release of goods (Art. 335(1) IA 2015/2447) |
| Nature of the power | Discretionary (“may”) |
| Office of exit response deadline | 10 days (Art. 335(3) IA 2015/2447) |
| Maximum validity of export declaration | 150 days (Art. 248(2) DA 2015/2446) |
| Declarant's own initiative | Possible at any time (Art. 335(2) and (3) IA 2015/2447) |
Important: The 90-day rule concerns the power of the customs office to initiate an ex-officio enquiry. The declarant does not have to wait 90 days - under Article 335(2) and (3) IA, the declarant may inform the customs office of export of the exit at any time after release of goods, or request a certification of exit. In practice you should act substantially earlier, in parallel with port-system intervention.
When Should You Initiate an Enquiry?
An enquiry procedure is warranted when:
- You know the goods have physically left the EU (the vessel has sailed), but you have not received the export confirmation
- Attempts to resolve the matter through the port system have not produced a result
- The MRN shows as “open” or “not closed” in the customs system
- The 150-day deadline for possible invalidation of the export declaration (Art. 248(2) DA 2015/2446) is approaching
- You need the 0% VAT proof of export and are running out of time within the 150-day window
Important: Do not delay. After 150 days from the release of goods, the customs office may invalidate the export declaration - obtaining a standard export confirmation then becomes considerably more difficult. We recommend taking action well before the 90-day ex-officio trigger threshold.
How the Enquiry Procedure Works
The procedure follows a defined structure. Below we describe what happens at each stage - not how to conduct the procedure yourself (this requires specialist knowledge and access to customs systems).
Request to the customs office of export
The exporter or their authorized representative files a formal enquiry request with the customs office of export (the office that processed the original export declaration). The request must include the MRN, the export declaration, and any available evidence of the goods having left the EU.
Communication with the customs office of exit
The customs office of export contacts the customs office of exit - typically the customs authority at the port through which the goods were shipped (e.g., Hamburg, Rotterdam, Antwerp). It requests information on the status of the goods' departure.
Verification of the facts
The customs office of exit reviews its records and the data available from port-level systems. If it can confirm that the goods have left the port, it registers the exit in the customs system.
Outcome
In the best case, the export confirmation is issued retroactively - the MRN is closed, and the exporter receives their proof of export. If this is not possible, the customs office of export may issue an alternative exit confirmation under Article 335(4) IA or direct the exporter to use alternative documentary evidence.
Alternative Proof of Export
If the enquiry procedure does not result in the issuance of a standard export confirmation, there are two alternative paths:
Alternative exit confirmation
The customs office of export may issue an alternative exit confirmation under Article 335(4) IA 2015/2447 if the exit of goods has been demonstrated through other means. This confirmation carries the same legal weight as the standard export confirmation for VAT purposes, although in practice it may be subject to closer scrutiny by the tax authority.
Alternative documentary evidence
In situations where no customs-issued confirmation is attainable, the tax authority may accept other forms of documentary evidence of export:
- Bill of Lading with an “on board” notation confirming the goods were loaded onto the vessel
- CMR consignment note with confirmation of receipt at the destination outside the EU
- Forwarder certificate attesting that the export took place
- Chamber of Commerce certificate from the country of destination
Recommendation: The standard export confirmation (CC599C in Poland, Ausgangsvermerk in Germany, confirmation of exit in the Netherlands) always provides the highest degree of legal certainty. It is advisable to exhaust all possibilities of obtaining one before resorting to alternative documentary evidence.
Why Use a Specialist?
The enquiry procedure is a technically and legally demanding process that requires specialist expertise:
- Access to port-level systems - identifying the root cause of an unclosed MRN often requires access to port systems at major European seaports. Individual exporters typically do not have this access.
- Contacts with foreign customs offices - direct working relationships with customs authorities at exit ports can accelerate the procedure from weeks to days.
- Documentation expertise - the quality of the request and the supporting documents has a direct impact on the outcome and duration of the procedure.
- Cross-border expertise - when goods are exported through foreign ports (DE, NL, BE), familiarity with each country's national customs procedures is essential.
The cost of engaging a specialist is negligible compared to the potential VAT correction - at a standard rate of 19-23% on the value of the exported goods, the financial exposure on a single declaration can run into tens of thousands of euros.
Frequently Asked Questions
What is an MRN enquiry procedure?
A formal customs procedure under Art. 335 of Commission Implementing Regulation (EU) 2015/2447 to the Union Customs Code. It may be initiated by the customs office of export when the export confirmation has not been issued automatically. The customs office of export contacts the customs office of exit to clarify whether the goods have left the EU customs territory.
When can the customs office initiate an enquiry procedure?
Under Article 335(1) IA 2015/2447, where after 90 days from the release of goods for export the customs office of export has not been informed of the exit of the goods, it may request the declarant to inform it. The 90-day rule has applied since the UCC entered into force and has not been amended. The declarant may inform the customs office on their own initiative at any time under Article 335(2) and (3) IA.
What if my MRN has been open for more than 150 days?
After 150 days, the customs office of export may invalidate the export declaration (Art. 248(2) DA 2015/2446). Obtaining a standard export confirmation becomes considerably more difficult, but not impossible. You may still be able to obtain an alternative exit confirmation (Art. 335(4) IA) or use alternative documentary evidence (e.g., Bill of Lading with “on board” notation, CMR). Contact a specialist as soon as possible - every day of delay reduces the chances of a successful outcome.
Can I file the enquiry request myself?
Formally, yes - the request is filed by the exporter or their authorized representative. In practice, it requires knowledge of customs procedures, access to port-level systems, and contacts with foreign customs offices. A specialist intermediary significantly accelerates the process and improves its success rate.
How long does the enquiry procedure take?
From a few days to several weeks - depending on the complexity of the case, the response time of the customs office of exit, and the quality of the supporting documentation. A specialist with direct contacts at European ports can significantly shorten this timeline.
Related Articles
Z Number - Export Registration in Hamburg | VAT 0% Export - Export Confirmation Explained | What Happens If MRN Stays Open? | MRN Closure Timeline
Need to close your MRN?
We cover 8 European ports. Average filing time 32 minutes, 2h order acceptance guarantee.