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Traffic Manual

II.4.2.5. Regular maritime service or non-regular maritime service

Non-Union goods, and in certain cases also Union goods, on board a vessel operating on a regular maritime service must be transported under a customs procedure ("truck on ferry") or placed under a Union transit procedure (T1 or T2F) for carriage on the regular maritime service. To this end, a regular maritime service may choose to obtain authorization to use a DTE as a transit declaration for maritime transport or to use the ordinary transit regime (through a declaration in the NCTS based on the SAD and a guarantee) for T1 or T2F goods. If the DTE is used as a transit declaration for maritime transport, regular maritime service manifests can be used for such purposes and no guarantee is required.

When operating short sea shipping services between two or more EU ports and transport mainly non-Union goods, it is advisable for operators to analyze the administrative effort involved. They must assess whether it is worthwhile to comply with the administrative requirements necessary to obtain authorization to use the regular maritime service and the DTE as a transit declaration for maritime transport, and to comply with the operational requirements necessary to use these authorizations. Another option is for operators to consider using a non-scheduled shipping service instead. This way, regular maritime service authorization would not be required, and the operator could provide simple proof of the customs status of EU goods, where applicable.

Unforeseen circumstances during transportation in regular maritime service

Where a vessel registered for a regular maritime service is forced by unforeseen circumstances to transship goods at sea, call at or load/unload goods at a non- EU port, a port not on a regular maritime service or a free zone of an EU port, the shipping company shall immediately inform the customs authorities of all subsequent EU ports of call along the vessel's scheduled route.

The customs status of the goods on board such vessel shall not be altered unless new goods are loaded or unloaded goods are left at such locations.

Example 1
New York/Le Havre/Antwerp route using a non-scheduled maritime service

Upon arrival in Le Havre, all goods are considered non-Union goods.

  • For Union goods (not subject to excise duty) loaded in Le Havre: A T2L document must be completed or, at the request of the shipping company, the shipping company's manifest containing the code "C" must be used.
  • For Union goods subject to excise duty loaded at Le Havre: A paper copy of the electronic administrative document (e-DA) must be used (as provided for in Articles 21 and 34 of Council Directive 2008/118/EC and Commission Regulation No 684/2009).

Example 2
Le Havre/Pointe-à-Pitre (Guadeloupe) route using a non-scheduled maritime service

Upon arrival at Point-à-Pitre, all goods are considered non-Union goods.

  • For Union goods: A T2LF document must be completed or, at the request of the shipping company, a shipping company manifest containing the code "F" must be used.

Example 3
Genoa/Marseille route using a non-scheduled maritime service

Upon arrival in Marseille, all goods are considered non-Union goods.

  • For Union goods (not subject to excise duty) loaded in Genoa: A T2L document must be completed or, at the request of the shipping company, the shipping company's manifest containing the code "C" must be used.
  • For Union goods subject to excise duty loaded in Genoa: A paper copy of the e-DA must be used (as provided for in Articles 21 and 34 of Council Directive 2008/118/EC and Commission Regulation No 684/2009).

Example 4
New York/Le Havre/Antwerp route using a non-scheduled maritime service

Upon arrival of the vessel in Le Havre, all goods will be considered non-Union goods.

Part of the cargo is unloaded in Le Havre and the rest remains on board.

There are two possibilities:

  • The goods are unloaded in Le Havre and transported by road to Antwerp, in which case the T1 transit regime, under which the road transport is carried out, and the provision of a guarantee will be required;
  • The goods are not unloaded in Le Havre and are transported by sea to Antwerp, in which case they do not need to be included in the T1 transit procedure. Upon arrival in Antwerp, all goods will be considered to have non-Union status unless evidence of their customs status as Union goods is presented.

Example 5
Export of goods with a request for restitution
Le Havre/Antwerp/New York route using a non-scheduled maritime service

Export formalities are completed in Le Havre, where the goods are loaded onto a vessel under a single contract for carriage to a third country and transported to Antwerp, where they are loaded onto another vessel bound for a third country.

Since the goods are transported via a non-scheduled service, they will be considered non-Union goods.

Proof of the customs status of Union goods in the case of transshipment

Union goods are transported under a regular transport service (see section II.4.2). If the goods are subsequently transferred to a vessel that is not a regular shipping service in an EU port, the status would be lost and the goods would be placed in temporary storage. This poses a problem at the EU port of end-use (termination). Schematically, the problem is as follows:

DUBLIN
Union goods loaded
.
Ship A (regular service)
.
MARSEILLES
transfer
.
Vessel B (non-scheduled service)
.
Taranto
proof of Union status required

In such cases, the required proof of status at the EU port of end-use (completion) – for example, Taranto – will have to be a T2L, which at the latest must have been issued and authenticated by the competent authorities at the port of transhipment – for example, Marseille.

It is advisable that in these cases proof of status accompanies the goods from the start of the transport operation (ship A).

An alternative is that the required proof is the shipping company's shipping manifest (see section II.4.2).