Export

Important transition of data that in a provisional period is declared at the shipment level and definitively at the item level, or at the item level and definitively at the declaration level. These different ways of declaring the data are explained in the AES technical guide and also in the PDF of the course taught by the Tax Information Technology Department, which is available in 'Help' on this same page.

On the other hand, to determine whether a declaration should follow the rules of the provisional or final period, the date of admission of the declaration must be compared with the date of entry of the final period (December 15, 2025).

Therefore, if a CC513C message for rectification of the declaration or a CC515 message with additional type X for supplementation of the declaration is submitted, the rectification message and the supplementary declaration will follow the rules of the final period if the declaration to which they refer was submitted after December 15, 2025.

However, in the CC515 message with additional type Y or Z, the rules of the final period will be followed if the date of admission of the recapitulative is after December 15.

It is not allowed from December 10, 2025. Until that time, these messages were accepted so that exports registered by the ECS system could be modified and/or supplemented, but with the entry of the final AES period, this is no longer allowed. Therefore, if it is necessary to modify and/or supplement exports registered with ECS, from December 10, 2025, it must be requested by registration with the corresponding Customs.

If the export remains in RQ status, the operator must send another CC507 message after about 15 minutes. Once sent, the situation may be one of the following:

• The export should move to the DE state, at which point message 507 would be processed with the export data.

• That the export continue in RQ status

• That the export be changed to RZ status

In the last two cases, customs may release the export by manually sealing the DAE.

From September 10, 2025, the export declaration may date a Summary Declaration of Temporary Deposit or G4 in the case that the goods are in a Canary Islands location and it is procedure 10.00 (definitive export).

From December 3, 2025 inclusive, in the registration of export declarations in AES, if the number of packages of a lot (goods item) is 0, then the gross mass of that lot must be 0. This rule is described in the AES guide.

 AES P1 is the electronic system intended to implement the requirements set out in the Union Customs Code relating to the export and exit of goods from the customs territory of the Union. This system replaces ECS - Export control system from the date of effective production start.

The system pursues the following objectives:

• Update existing functionalities to improve them or adapt them to CAU
• Add new features to improve trade facilitation and automation of processes provided for in the legislation
• National and trans-European harmonisation of export declarations

From that date onwards, for declarations registered with the ECS system, rectification (CC513) or invalidation (CC514) messages are not accepted in electronic format, nor are EDIFACT messages. Any request for rectification or invalidation must be made via Registry addressed to the competent administration.

Furthermore, the details of the declaration with the data in ECS format (pre CAU) were no longer available at the AEAT headquarters. The details will continue to be available in CAU (AES) format.

The national coexistence period between the ECS P2 and AES P1 systems began on October 18, 2022 (the date the AES system was put into production in Spain) and ended on May 9, 2023.

The interim period began on May 9, 2023, during which the AES P1 system became operational in the various Member States. This provisional period ended on December 14, 2025, with the definitive period beginning the following day.

The CAU introduces the following new features in the electronic export system AES P1 :

• New configuration of export declaration data
• New data to be declared and disappearance of data included in ECS P2
• Generalized treatment of export pre-declarations
• Possibility of centralized European dispatch for export.
• Disappearance of the paper declaration.
• Specific treatment of simplified and complementary declarations
• Specific treatment of post-clearance declarations
• Possibility of partial lifting of the export declaration

The AES P1 system introduces modifications to the following functionalities already provided in ECS P2 :

• Modifications and invalidations of declarations
• Research procedure
• Formalities for the exit of goods from the customs territory of the Union
• Deviation management
• Scenario export followed by transit

In 2016, the CAU introduced several changes to customs export and exit formalities. It also established as a general rule that all exchanges of information between customs authorities and between economic operators and customs authorities should be carried out using electronic data processing techniques. In addition, it introduced structural changes to the declaration data requirements and their formats and codes to be used in declarations, in line with the EU ## customs data model .

The EU ## Customs Data Model (hereinafter EUCDM) is the model for the trans-European customs systems and for the national customs systems of the Member States.

The adaptation of the declarations to the EUCDM data model implies the disappearance of the different boxes of the export DUA and the appearance of the data groups, data elements and data sub-elements within data groups.

In the Technical Guide of system AES P1 , in the section “Functional description of the CC515CVxEnt XML request message” information of interest is given on the export fields, validations that apply to them, code tables (if any), filling guides and correspondence with the declaration in system ECS P2 .

The technical export guide can be found on the Electronic Office in the export section.

Tax Agency: Technical guides - Presentation of the SAD (Single Administrative Document)

In 2016, the UCC introduced several changes to export and exit customs formalities. It also established as a general rule that all exchanges of information between customs authorities and between economic operators and customs authorities should be carried out using electronic data processing techniques. Furthermore, it introduced structural changes to the data requirements for declarations and their formats and codes that must be used in the declarations, in line with the EU customs data model.

The EU Customs Data Model (hereinafter referred to as EUCDM) is the model for trans-European customs systems and for the national customs systems of the Member States.

Adapting the declarations to the EUCDM data model involves the disappearance of the different boxes in the export DUA and the appearance of data groups, data elements and sub-elements within the data groups.

In the AES P1 system technical guide, in the section "Functional description of the CC515CVxEnt request XML message", information of interest is given about the export fields, validations that apply to them, code tables (if any), filling guides and correspondence with the declaration in the ECS P2 system.

The technical export guide can be found on the Electronic Office website in the export section, at the following link:

AES Export SW (agenciatributaria.gob.es)

The EUCDM is available at the following link: EUCDM 6.2 (softdev.eu.com)

The information regarding the data to be included in the declarations submitted through the AES P1 system, as well as the requirements corresponding to this data, are listed in columns B1 (export and re-export declaration), B2 (special outward processing regime), B4 (declaration of dispatch of goods in the framework of trade with special tax territories), C1 (simplified export declaration) and C2 (presentation of goods to customs in case of registration in the registries or in the case of pre-export declaration) of Annex B of Delegated Regulation (EU) 2015/2446 ^[1] and Implementing Regulation (EU) 2015/2447

In the AES export system, the declaration consists of 3 levels:

• Declaration (or header): which contains the data common to the entire declaration

• Shipping (goods shipment): which contains data for a specific shipment and that data is common to all items that that shipment has

• Items (goods item): which contains data for a specific item of merchandise in the corresponding shipment.

The documents generated by the AES system are as follows:

• Export customs release document adapted to the requirements of the Customs Code of the Union

• Temporarily the export accompanying document (DAE)

• Departure authorization document at the exit customs

• Certificate of effective exit of the goods from the customs territory of the Union

• T2L or T2LF document. When the export declaration is submitted in Spain and the customs office where the goods are presented is also Spanish, the T2LF applies to shipments destined for the Canary Islands and the T2L applies to exports destined for Andorra.

Modifications to the export declaration after the release will result in the generation in the export system AES of a new release document in which the modifications made to the export declaration will be reflected and to which a new CSV will be assigned.

The DAE (Export Declaration) provided for in the case of exports where the customs office of export and exit do not coincide (indirect exit), will continue to be made available to the declarant. This possibility has been foreseen given that the customs authorities of some countries continue to require the DAE (Export Declaration) to confirm the departure of goods.

The following persons may be involved in the export declaration:

• Exporter
• Declarant: may be the exporter.
• Representative: If the declarant is different from the exporter, indirect representation is deduced and it will not be necessary to expressly declare the field of representation. If the representation is direct, in this case the data of the declarant and exporter will coincide and direct representation must be included as the type of representation in this field. In addition, code I1032 will be used if you wish to indicate a type of representation in the ATC other than state representation (that is, in those cases where direct state representation is declared and indirect ATC or vice versa).
• Shipper (Consignor): mandatory data only in case of declaration with security data. The shipper may be the exporter or a third party (depending on the contract with the carrier).
• Addressee (Consignee): mandatory data only in case of declaration with security data.
• Carrier: It is only included in the export declaration if it is different from the declarant.

Both the sender (consignor) como el destinatario (consignee) are optional data in the export declaration. In the event that this declaration requires security data, both become mandatory data.  The SECURITY SHIPPER indication, if filled out in the case of a declaration with security data, will indicate the person who acts as the shipper, this shipper being the third party who, on behalf of the exporter, delivers the goods to the carrier at the place of receipt of the goods.

It may be listed at the level of consigment si es uno solo el que se hace cago de todo el envío, o a nivel de goods item si son distintos o hay varios a nivel de item. 

Therefore, if the export declaration requires security data (EXPORT OPERATION/Security is '2') both the sender and the recipient will become mandatory data.

The export declaration is submitted by the declarant or by the person acting on behalf of the declarant (representative). As a general rule, the person submitting the export declaration must be established in the customs territory of the Union.

In the case of direct representation or self-dispatch, the declarant is the exporter. In the case of indirect representation, the declarant will be the indirect representative.

The declarant must have EORI established and NIF .

In accordance with the provisions of Commission Delegated Regulation EU 2015/2446, the following will be the exporter:

• an individual who carries in his personal luggage goods that are to be transported outside the customs territory of the Union.
• Outside the above circumstances, any person established in the customs territory of the Union who is empowered to decide and has decided that the goods must be transported outside the customs territory may be an exporter.

Where the preceding paragraph does not apply, any person established in the customs territory of the Union who is a party to the contract under which the goods are to be transported outside the customs territory shall be deemed to be an exporter.

In the case of natural persons, their habitual residence must be in the customs territory of the Union. In the case of legal persons or associations of persons, the registered office, headquarters or a permanent commercial establishment must be located in the customs territory of the Union.

As a general rule, export declarations must indicate the following in relation to the exporter:

•  EORI established in the EU
•  NIF since it is an operation of a tax nature or with tax implications with repercussions on VAT .
• The exceptions to this general rule are as follows:
• Individual shipments according to the rules of Appendix IX of Resolution DUA of small shipments.
• Declarations with CO code that do not require EORI although it will be necessary to have NIF .
• Re-exports: In this case the EORI may be associated with a NIF instrumental: requested regime 3171, 3178 and 3153.
• Export country other than Spain.
• Successive deliveries in which the exporter is established in the EU but not in Spain for the purposes of VAT It includes the NIF of the person making the exempt delivery, with code I5007 in "Additional Information". (Appendix XV Resolution of DUA )
• Exports made by a non-established person (although the EORI of an established person agreed by the parties must appear as the exporter) with the NIF of the person making the exempt delivery appearing in "additional information".  (Appendix XV Resolution of DUA )

No. The data group corresponding to the representative will only be included in the declaration if the type of representation is direct. In the event that an exporter other than the declarant is declared, the latter will necessarily be an indirect representative of the exporter.

As a general rule, the export declaration is lodged in the Member State corresponding to the place where the exporter is established or the place where the goods for export are loaded or packed. However, sections 2 and 3 of article 221 RECAU regulate exceptions to the general rule.

 AES P1 is the electronic system enabled for the submission of customs declarations that allow the inclusion of merchandise in the customs regimes of export and passive processing.

Likewise, the system AES P1 must be used to send the following types of declaration and presentation:

• Re-export declaration
• Declaration of shipment of goods in the framework of trade with special tax territories
• Simplified export declaration, and
• Presentation of goods to customs in the event of registration in the records or in the case of pre-export declaration

Yes. The AES P1 system allows the submission of the normal or simplified customs declaration before the presentation of the goods to customs. In such cases, if the goods are not presented within 30 days of the submission of the customs declaration, the declaration shall be deemed not to have been submitted.

Given the current wording of the Protocols of Origin, this is not possible. These Protocols of Origin indicate that, where the certificate of movement of goods issued in paper form is the preferential proof of origin in Article on Procedure for issuing certificates of movement EUR.1, it is:

“7. The customs authority or the competent governmental authority issuing a movement certificate EUR.1 shall make it available to the exporter as soon as the actual export has been effected or secured.”

The expression “as soon as export has been effected or guaranteed” may be understood when the exporter has begun the formalities for the export of the goods in a manner that makes it impossible to give another destination to the goods without informing customs. In practical terms, this means that the exporter must have submitted the corresponding export declaration to the customs authorities and they must have accepted it (the export declaration has legal existence and cannot be cancelled without the consent of the customs authorities).

Yes. Centralized clearance is a customs simplification that occurs when the Customs office where the goods are presented is located in a different country than the Customs office where the declaration is submitted. This simplification of the declaration procedure is subject to the operator being granted prior authorisation by customs. Furthermore, it may only be used in those cases where the Member State in which the goods are presented has adapted the export system to the requirements of the UCC.

The AES P1 Technical Guide is available in the HELP section of this same section.

The differences between v5 and v4 are new elements and the removal of others exclusively in the response messages and the possibility that opens only in v5 to declare as a prior document N337 (DSDT or G4) whose merchandise has not yet been effectively presented to customs. Once the latest DSDT/G4 knowledge involved in the previous EXS documents has been submitted, the declaration will be activated.

In v5, the use of the previous document types XSUM/XSUA will be prevented and replaced by the existing N337, which allows DSDT and G4 references.

Cancellations and modifications will be accepted using v5 of declarations made with v4.

The production launch date for version 5 of the electronic system for summary declaration of exit and notification of re-export is November 3, 2025. The closing date for version 4 is scheduled for May 18, 2026.

The new version of the electronic system allows the submission, modification and cancellation of the following types of declaration and notification: 

• Summary declaration of departure
• Summary declaration of departure for urgent shipments
• Re-export notification
• Reshipment Notification

Yes. The updated version of the electronic system will be allowed for the management of cancellations and modifications of declarations and notifications made using version 4.

Yes. The carrier data group must be completed in the updated version of the electronic system for summary declaration of exit and notification of re-exportation, and it is necessary to include the carrier's EORI number .

The technical guide for submitting EXS declarations, Re-export Notifications and Re-shipment Notifications is available in CUSTOMS, ELECTRONIC CUSTOMS, TECHNICAL GUIDES, Submission of Summary Exit Declarations (EXS, A1/A2), Re-export Notifications (A3) and Re-shipment (NR).

In accordance with the provisions of Annex B of Commission Delegated Regulation EU 2015/2446, the Union code must be recorded in the data element “country of export”. corresponding to the Member State in which the goods are located at the time of their inclusion in the scheme.

Example A. Merchandise produced in Spain (ES) with the Export declaration presented in ES:

• Country of export = ES

However, where it is known that the goods have been introduced from another Member State into the Member State in which the goods are located at the time of their placement for the customs procedure, indicate that other Member State, provided that (i) the goods have been introduced from there solely for the purpose of export, (ii) the exporter is not established in the Member State in which the goods are located at the time of their placement for the customs procedure, and (iii) the entry into the Member State in which the goods are located at the time of their placement for the customs procedure does not constitute an intra-Community acquisition of goods or a transaction equivalent to such within the meaning of Council Directive 2006/112/EC.

Example B. Goods produced in France (FR) and transported to ES (country in which the export declaration is submitted) for shipment outside the EU :

• Country of export = FR

However, where goods are exported following an inward processing procedure, the country of export shall be the Member State in which the last processing activity was carried out.

In accordance with the provisions of Annex B of Commission Delegated Regulation EU 2015/2446, the corresponding Union code must be indicated in the data element “country of origin”. to the non-preferential country of origin, as defined in Title II, Chapter 2, of the Union Customs Code.

• The message of presentation of the goods at the export customs may be presented by the declarant, his representative and any person who has received power of attorney from the declarant.
• As for the means of transport for which this message can be presented, it is valid for all means of transport, whether maritime, land or air."

In accordance with the provisions of Annex B of Commission Delegated Regulation EU 2015/2446, the data element “region of issue” must be indicated using the corresponding code defined by the Member States, the region of dispatch or production within the Member State concerned of the goods in question.

This information will only be completed if the export country is Spain or if it is required by the office presenting the goods in a centralised European export clearance scenario.

Example A. Merchandise produced in Spain (ES) with the Export declaration presented in ES:

• Country of export = ES
• Region of issue: the corresponding Spanish

Example B. Goods produced in France (FR) and transported to ES (country in which the export declaration is filed) for shipment outside the EU .

• Country of export = FR
• Region of issue: the corresponding French one (this data element will only be completed in the case of European centralized clearance, provided that it is required by the office where the goods are presented)

With the introduction of the electronic system for accreditation of proof of customs status of the Union, POUS, proof of T2L/T2LF status must be requested through this computer system from 01/03/2024 (known as POUS 1). However, the CGM/F test must be requested through this system from 15/08/2025 (POUS 2).

However, in exchanges between the Peninsula and the Balearic Islands with the Canary Islands, the T2LF/CGMF will be generated through the national export system. In these cases, POUS will only be used when obtaining these documents through a means other than the usual one is justified.

Furthermore, for exports from the Peninsula and Balearic Islands to Andorra, the T2L will also be generated through the national export system.

The code N825 (to indicate that it is a T2L) or C620 (to indicate that it is a T2LF), or C551 (to indicate that it is a CGMF) must be filled in on the supporting documents (ED 12 03 000 000) of the AES export declaration.

In exchanges other than those mentioned above, the POUS system will be the only one enabled to process requests for registration and/or endorsement of proof of status as Union goods.