How an export declaration works step by step

An export declaration is the electronic customs declaration that you (or your customs broker) file before goods leave the EU. Without a valid export declaration with confirmed exit, you risk additional VAT assessment, rejection of your 0% rate and fines for incomplete administration. In the Netherlands this runs via the AGS Export system and the European ECS (Export Control System). Below the complete procedure in eight concrete steps.

What is an export declaration?

An export declaration is a formal notification to Customs that goods are about to leave the EU customs territory. The legal basis lies in article 158 of the Union Customs Code (UCC). The declaration has three functions simultaneously:

• Customs-technical: proof that goods actually leave the EU.
• Fiscal: substantiation of the 0% VAT rate on export (article 9 paragraph 2 under b Wet OB).
• Statistical: data for CBS and Eurostat on Dutch trade flows.

In the Netherlands you work with:

• AGS Export: the Dutch declaration system.
• ECS: the European control system that handles the exit confirmation.
• Single Window: the portal that links AGS to other authorities (NVWA, Tax Administration, COKZ).
• Sagitta: the old system, replaced by AGS.

Since the introduction of the UCC in 2016 (and the ongoing migration to the Multi-Annual Strategic Plan, MASP-C), data requirements have been considerably expanded. A modern export declaration has between 40 and 60 mandatory fields.

When must you declare exports?

• For definitive export of goods from the EU to a third country.
• For re-export of non-Union goods that were stored here.
• For temporary export (for example for repair, fairs) under outward processing or ATA carnet.
• For export samples above the de minimis threshold (typically above €1,000 or for excise and restriction goods regardless of value).

Generally not subject to declaration are shipments up to €1,000 and 1,000 kg for postal shipments and courier services — but in practice courier companies (DHL, UPS, FedEx) file a simplified declaration anyway.

The 8 steps of an export declaration

Step 1: Preparation and data collection

Collect in advance:

• EORI number of the exporter (NL + 9 digits, usually linked to VAT number).
• HS codes (8 digits for export, in line with the Combined Nomenclature).
• Goods description in understandable trade terms.
• Value in EUR (with foreign currency at the official monthly rate of Customs).
• Weight net and gross.
• Destination country and end user.
• Transport details (flight number, B/L, license plate).
• Any licenses (dual-use, sanctions, excise).
• Proofs of origin (EUR.1, statement of origin, REX statement).

Step 2: Sanctions lists and export control

Before declaration: check whether the goods or the customer fall under a sanctions regime. Specifically:

• EU sanctions lists: against Russia, Belarus, Iran, North Korea, Syria and others.
• Dual-use goods: civilian goods with military application (Regulation (EU) 2021/821), license via the CDIU (Central Import and Export Service).
• Strategic goods / military goods: separate license via Ministry of Foreign Affairs.
• Cultural goods, artworks: separate rules.

Since 2022 the Russia sanctions have been particularly extensive. An innocuous-looking shipment of machine parts can fall under a sanction. Check the EU Sanctions Map and use screening software.

Step 3: Submit declaration in AGS Export

The customs broker (or the exporter themselves with a connection) submits electronically. Mandatory data is split into:

• Main segment: declarant, exporter, consignee, departure/destination, total value.
• Goods segment per article: HS code, description, quantity, value, origin, any licenses.
• Transport segment: modality, carrier, route.

AGS checks immediately for consistency. Incorrect fields lead to a rejection with error codes. In practice, 5–10% of declarations are initially rejected — with good agents that’s below 1%.

Step 4: MRN and release

On acceptance AGS assigns an MRN (Movement Reference Number). This is an 18-digit identifier that recurs throughout the export process. Customs gives, immediately or after physical inspection, a release for exit (release for export). The shipment may then be transported to the office of exit — usually Schiphol Cargo, Rotterdam Maasvlakte or a border office.

Step 5: Presentation at the office of exit

The goods must physically arrive at the office of exit before the latest date of presentation, usually 90 days after release. At Schiphol this happens electronically via Cargonaut (since 2023 part of Portbase): the Ground Handler scans the air waybill and links it to the MRN.

Step 6: Inspection and exit confirmation

The office of exit checks (on a sample or risk-driven basis) and electronically confirms in ECS that the shipment leaves the EU. This is called the exit confirmation (Confirmation of Exit).

Step 7: Proof for VAT administration

The exporter receives via AGS a PDF with the exit confirmation and the MRN. This is your fiscal substantiation for the 0% VAT rate. Keep this for at least 7 years in your administration. Without exit confirmation, the Tax Administration can recover the 21% VAT at audit — sometimes years later.

Step 8: Periodic aftercare

Open export declarations not confirmed within 90 days receive an investigation request from Customs. Always respond within the set period with additional proof (CMR with proof of receipt, waybill, carrier declaration). No response = automatic rejection and possible recovery.

Special situations

Excise goods (alcohol, tobacco, mineral oils)

For excise goods under suspension you work with EMCS (Excise Movement and Control System) alongside AGS. The e-AD (electronic Administrative Document) handles the excise part.

Simplified declaration / EIDR

Companies with a simplified declaration license (VVR) or Entry in Declarant’s Records (EIDR) may supplement afterwards. This is only profitable at high volumes and requires solid administration.

Pre-departure declaration

Since UCC the export declaration (which also serves as pre-departure ENS) must be submitted at the latest 1 hour before loading for air and 24 hours for sea. Late declaration leads to a Hold by the airport or port.

Common mistakes

1. Wrong EORI of the customer

For some destinations (especially the UK after Brexit) the EORI or registration number of the foreign customer is relevant. A wrong number leads to rejection on the import side.

2. Incorrect value

The statistical value must be the actual transaction value, not the purchase price or an agreed amount. For intercompany transactions the arm’s-length price must be used.

3. Incorrect HS code

A deviation of just one digit can switch a license requirement on or off. If in doubt: apply for a Binding Tariff Information (BTI), valid 3 years across the EU.

4. Forgotten dual-use check

Many exporters don’t realize their product falls under the dual-use list. Categories like telecom equipment, encryption software, machinery, sensors — always check Annex I of Regulation 2021/821.

5. No exit confirmation archived

During VAT audits, exit confirmations are systematically requested. Companies relying only on the MRN face revision of the 0% rate.

Get started

An export declaration looks like routine, but one wrong field can cost hundreds or thousands of euros — in recovery, delay or license fines. Especially with the extensive sanctions rules of 2024–2026, good screening is crucial.

DouaneDoc handles export declarations daily from Aalsmeer. See our export declaration service or request a quote. Also want to know when you use a EUR.1 or statement of origin? That article fits nicely with this one.

Direct contact: 088 088 2407 or sales@aircargo.nl.