Document codes in the customs declaration: Know what you're declaring.

Authored by: Lilian Retel for 'Weg en Wagen'

Document codes explained

Document codes are specific number or letter combinations used in a customs declaration to clarify which documents, licences or certificates are linked to a consignment. For example, a code starting with an L refers to an import licence, a U to declarations of origin and code X to an export licence. They act as a digital declaration to customs, indicating that certain obligations have been met. For example, the code can confirm that a product has been approved for import or conversely declare that the product is not covered by a particular regulation.

Document codes are especially important in import and export declarations. They can be used to prove that the correct licences and documents are present for the shipment, or to confirm that products meet certain environmental requirements. An incorrect code can lead not only to delays at customs, but also to fines or extra checks.

Document codes can apply to all customs procedures, but they are most commonly used for import and export declarations.

For imports, document codes are often used to show that the correct certificates, exemptions or licences are present. Examples include:

• Certificates of origin, such as a EUR.1 certificate (for preferential import tariffs).
• Veterinary or phytosanitary certificates, for example when importing food or plants.
• Environmental declarations, such as for goods containing regulated chemicals or gases. For example, certain commodity codes require declarations on whether the products contain ozone-depleting substances or fluorinated greenhouse gases.

When exporting, document codes are often needed to declare whether goods are subject to export restrictions.

• A commonly used document code is the one for goods covered by the dual-use regulation. These are items that can be used for both civilian and military applications and sometimes require a special licence.
• Exports of cultural goods, strategic goods or certain technologies may also require specific document codes to prove compliance with regulations.

The importance of using the correct code

Each document code is linked to a specific situation and directly affects the handling of the declaration by customs. Customs uses these codes to quickly check whether the correct documents are attached and whether the declaration complies with the applicable legislation. A mistake when filling in a document code can lead to delays, extra checks or even fines.

Whether or not a document code has to be filled in depends on the commodity codes used. Customs software and databases, such as TARIC (the EU Customs Tariff), indicate per commodity code whether an additional document code is required. If a mandatory document code is missing, the declaration is not processed, and an error message follows. This can cause shipments to remain stuck until the declaration is submitted correctly.

Using the correct document code is crucial in the customs process. Thus, filling in the correct document code is more than an administrative formality; it is a statement of fact and a confirmation of the situation surrounding the goods being imported or exported. This makes the use of the correct code essential to ensure the process runs correctly and to avoid legal and financial risks.

Example 1: Dual use

When an importer or exporter enters a document code, he or she is declaring something about the goods or transaction. For example, when exporting goods covered by the dual-use regulation (goods that may have both civilian and military applications), the appropriate document code must be entered to indicate whether a licence is required. This code is a declaration that the goods are or are not under the strict control of the authorities. Failure to enter the correct code correctly may result in the goods being wrongly released without the necessary authorisation, or in the opposite case, they may be detained because customs requires an unjustified authorisation.

Therefore, to determine whether goods are covered by a particular regulation or not, that regulation will also have to be consulted. Working with assumptions is not possible if it is not clear what such a regulation exactly entails and its scope. In the case of the dual-use regulation (Regulation (EU) 2021/821), merely consulting it may not be enough. When looking at this regulation, it will immediately become clear that it contains a lot of information and describes products in a very technical way. Thus, an expert with a technical background or in-depth product knowledge may also need to be consulted.

If it is stated in an export declaration that a product is not covered by this regulation, it will also be necessary to demonstrate how this has been checked and verified. Simply stating that it does not fall under the Regulation is not enough. It must be specified, why a certain qualification has been chosen for a product. The qualification determines whether the good has a civil or military application.

Example 2: Import of goods containing wood

At the end of 2025, the new Deforestation Legislation (EUDR) comes into force. This legislation is controlled via the customs declaration, namely by entering a document code and a release code on import and/or export.

Suppose an importer in the Netherlands receives a shipment of furniture containing wood from South America. The importer is aware that wood is a product potentially subject to EUDR regulations, as the EU has set up strict rules to prevent products that contribute to deforestation from reaching the European market.

When importing this furniture, the importer must enter the correct document code in the customs declaration to indicate that the shipment complies with EUDR requirements. In this case, the correct document code may indicate that the wood used has been verified and certified as coming from a sustainable source and that the deforestation risk of the shipment has been assessed.

Suppose the importer enters the wrong document code and chooses a code that does not indicate that the wood meets EUDR requirements. Instead of the code confirming that the product complies with EU legislation against deforestation, the importer inadvertently chooses a code that indicates that the sustainability requirements do not apply.

The customs authorities will check this declaration and, if they discover that the consignment of furniture does not comply with EUDR regulations, this may lead to the following consequences:

1. Delays in processing the shipment: The furniture will be detained at customs until proper proof of EUDR compliance is provided.
2. Penalties for the importer because the wrong document code has been entered and the required documentation is missing.
3. Convening of additional controls: Customs may decide to inspect the consignment and demand more information on the origin of the wood and whether this information indeed meets the sustainability requirements.
4. Loss of access to the European market: If the consignment cannot be approved, the importer may have to send the furniture back to the exporting country or destroy the furniture (or have it destroyed), incurring significant costs and possibly damaging the relationship with the supplier.

In this case, the document code has a very specific function: it confirms that the importer complies with EU regulations and that the timber used comes from a plantation that meets EUDR requirements. If the wrong code is entered, the customs information is not processed correctly, which can lead to legal complications for the importer and possible delays in the overall delivery process.

Know what you're declaring!

Filling in the correct document code is more than a formality. It determines whether your shipment will pass through customs smoothly or get stuck with delays, extra charges or even fines. As the examples show, a document code is a declaration to customs that you are compliant.

Avoid mistakes by understanding the regulations well. A well-chosen document code saves time, money and hassle!