Import/Export
MRN Closure at Seaports – Export Confirmation and VAT Zero-Rate via ZAPP, BHT, Portbase and APCS
February 23, 202617 min readPawel Dubel
How to close MRN and obtain CC599C (formerly IE599) at Hamburg, Bremerhaven, Rotterdam and Antwerp ports. Complete guide to ZAPP, BHT, WHT, Portbase and e-Desk systems for export VAT zero-rate.
MRN Closure at Seaports – Export Confirmation and VAT Zero-Rate via ZAPP, BHT, Portbase and APCS
Category: Export / Export Confirmation Procedure Updated: February 2026 Reading time: ~13 min
An exporter dispatching goods through Western European seaports routinely encounters the same problem: a valid export declaration with an MRN number is in hand, yet the port terminal refuses to load the container onto the vessel. The cause is a missing MRN registration in the relevant port telematic system. In another scenario, the vessel has already sailed, but the exporter still has not received the exit confirmation message (CC599C, formerly IE599) — the document required to apply the VAT zero-rate on the export transaction.
This article explains what MRN closure in a port system means, how the process works at each of the major Western European seaports, and which errors most frequently delay or prevent the issuance of proof of export.
What is MRN and why must it be closed at the port?
MRN (Movement Reference Number) is the unique reference number assigned by the customs system to every export declaration upon its acceptance by the customs office of export. The acceptance is confirmed by message CC528C (before 31 October 2024: IE528). Once the goods are released for export (message CC529C), the Export Accompanying Document (EAD) is generated — this document accompanies the consignment until it reaches the customs border of the Union.
The mere existence of an MRN does not, however, mean the export procedure is complete. The procedure remains "open" until the customs office of exit — the customs office responsible for the port through which the goods physically leave the customs territory of the Union — confirms the exit. Only then:
- the exporter receives message CC599C (before 31 October 2024: IE599),
- the VAT zero-rate may be applied to the export transaction,
- the export procedure is formally closed.
Where MRN originates – national AES systems vs port telematic systems
The MRN is generated by each Member State's national export system. In Poland, this is AES/ECS2 PLUS (administered by the National Revenue Administration via the PUESC portal; this designation has been in use since 31 October 2024, previously AES/ECS2). In Germany, the equivalent system is ATLAS-AES. Belgium and the Netherlands operate their respective national customs systems.
Port terminal systems — ZAPP, BHT, WHT, Portbase, APCS — are not customs systems. They are Port Community Systems (PCS): electronic intermediaries between the forwarder or exporter and the container terminal, as well as the customs authority of the country of exit.
The mechanism works as follows: until the MRN is registered in the port system before the gate-in (physical delivery of the container to the terminal), the terminal cannot transmit the required arrival message (known as CODECO) to the customs authorities. Without this message, the customs office will not close the export procedure and will not generate CC599C.
Practical consequence: if goods are customs-cleared in Poland and the exit takes place through Hamburg, the Polish MRN must be registered in the ZAPP system before the container arrives at the port terminal. The same principle applies to export declarations from any other EU Member State — the MRN must always be registered in the port system of the actual point of exit.
Difference between EAD/CC529C and proof of export (CC599C)
This is the most common misunderstanding in export practice — many exporters confuse the moment of release for export with the confirmation of physical exit from the customs territory of the Union.
| Document | What it confirms | Entitles to VAT zero-rate? |
|---|---|---|
| CC528C (formerly IE528) | Acceptance of the export declaration, assignment of MRN | NO |
| EAD + CC529C (formerly IE529) | Release of goods for the export procedure — transport may commence | NO |
| CC599C (formerly IE599) | Physical exit of the goods from the customs territory of the Union | YES |
Note: The message designations CC528C, CC529C and CC599C have been in effect since 31 October 2024, the date of the EU-wide deployment of the upgraded AES systems. Their predecessors (IE528, IE529, IE599) are referenced in this article solely for informational purposes, as these legacy designations remain in documentary circulation. Documents issued before 31 October 2024 retain full validity.
Possessing the EAD and an MRN on transport documents alone does not constitute a sufficient basis for applying the VAT zero-rate on an export transaction. The CC599C message is generated automatically by the customs system only after the customs office at the port of exit receives confirmation from the terminal that the container has been loaded onto the vessel and the vessel has departed.
Ports and their systems – overview
Each major Western European seaport handles export through its own dedicated telematic system. These systems differ in name, operator and procedural detail, but they all serve the same purpose: electronically linking the MRN to the container and transmitting the arrival confirmation to the customs authorities.
Hamburg – ZAPP / EMP
ZAPP (Zoll-Ausfuhrüberwachung im Paperless Port — customs export supervision in a paperless port) is the mandatory customs export handling system at the Port of Hamburg, developed and maintained by DAKOSY Datenkommunikationssystem AG. The system is integrated with the German national customs system ATLAS-AES. ZAPP is being progressively migrated to its successor platform — EMP (Export Management Platform).
How ZAPP works: the forwarder submits a port order (Hafenauftrag — port handling instruction) containing the MRN data to the system. Based on the declaration type and circumstances, the system assigns one of three customs references:
- Z-number – standard export outside the Union based on an AES declaration (ABD with MRN),
- B-number – cases where a Z-number is not applicable, including: MIT (Wiederausfuhrmitteilung — re-export notification for non-Union goods under Article 274 UCC), SBF (Sonstige Befreiungsfälle — other cases exempt from the obligation to lodge an export declaration), EUB (EU-Bestimmung — EU destination; used when cargo will be unloaded at an EU port and does not leave the customs territory of the Union, regardless of whether the goods originate from an EU or non-EU country), and AUS (Ausfallkonzept — fallback procedure when the system is unavailable),
- S-number – for non-Union goods (e.g. from Norway, Switzerland) being taken out of the customs territory of the Union for which neither a Wiederausfuhrmitteilung nor a T1 document with MRN has been lodged; the basis is an exit summary declaration (ASumA, declaration type DUX).
The Z-number status remains "not released" (NRL) until the terminal confirms the gate-in of the container. Upon confirmation, the status changes to "released" and the container may be loaded onto the vessel. After the vessel departs the port, ZAPP transmits the export closure message to ATLAS, and the MRN is automatically closed.
Waiting time for zollfrei (customs release) for Z-numbers: approximately 2 hours from gate-in, provided the customs office has not ordered an inspection (Verladestopp — loading prohibition). S-numbers: approximately 24 hours from the creation of the S-number (not from gate-in) — this timeframe must be factored in when planning against the Ladeschluss (terminal cargo cut-off) and vessel departure.
Bremen / Bremerhaven / Cuxhaven – BHT
BHT (Bremer Hafentelematik — Bremen port telematics) is the equivalent of ZAPP for the ports of Bremen, Bremerhaven and Cuxhaven. The operating principle is analogous: the system, linked to ATLAS-AES, assigns BHT references for each export consignment, and zollfrei is issued electronically following MRN verification.
Customs release timeframes:
- for ABD declarations with MRN: approximately 2 hours,
- for declarations without ABD (e.g. MIT, other B-number cases): up to 12 hours.
Operational note: The BHT reference must reach the terminal before the physical delivery of the container. The terminal will refuse to accept the cargo if the reference is not available in the system at the moment of gate-in.
Wilhelmshaven – WHT
WHT (Wilhelmshaven Hafentelematik — Wilhelmshaven port telematics) operates on principles similar to BHT. A key difference: WHT requires the carrier's booking reference to be provided at the port order registration stage. The WHT reference must be generated and available before the container is delivered to the terminal — advance document preparation is essential.
Rotterdam / Amsterdam / Vlissingen / Terneuzen – Portbase
Portbase is the Dutch Port Community System (PCS), serving the ports of Rotterdam, Amsterdam, Vlissingen and Terneuzen (the latter two as North Sea Port, added to the PCS on 25 June 2024). For export, the core service is Melding Export Documentatie (MED — Notification Export Documentation): electronic submission of customs documents, including MRN, to the container terminals.
How Portbase works: the forwarder or exporter logs in to the PCS and registers the MRN (document type depending on the procedure: AES, ATA, TIR, re-export, etc.) together with the container number and booking number. The terminal verifies the data at gate-in and transmits to the Dutch customs authority (Douane) a CODECO message confirming the arrival of the goods. On this basis, the customs office closes the procedure after the vessel's departure.
Supported terminals (selection): Hutchison Ports ECT Delta, Hutchison Ports ECT Euromax, APM Terminals Maasvlakte II, Rotterdam World Gateway, Rhenus Deep Sea Terminal, Rotterdam Shortsea Terminal, and others.
Tip: Portbase allows enabling e-mail notifications (ECS Notification for Forwarders) on consignment status, including MRN errors and customs blocks. It is advisable to configure these notifications immediately after registration — the absence of an alert may mean a problem is missed before the terminal cargo cut-off.
Antwerp / Zeebrugge – APCS / e-Desk
In the ports of Antwerp and Zeebrugge, the Port Community System role is performed by APCS (Antwerp Port Community System). The dedicated application for registering MRN for containerised and ro-ro exports is e-Desk, accessible through the My Port of Antwerp-Bruges portal (portofantwerpbruges.com). Until 1 October 2024, this portal operated under the name C-point.
How e-Desk works: the declarant (forwarder, exporter or their authorised representative) enters the MRN and container number into the e-Desk application. The terminal, acting in the Belgian procedure as the "trader at exit", verifies the data upon the container's arrival and transmits a CODECO message to the Belgian customs authorities confirming the arrival of the goods. On this basis, Belgian customs generates the exit confirmation, which closes the export procedure.
Key operational rule: MRN registration in e-Desk must take place before the container is delivered to the terminal. Since September 2016, post-gate-in registration is technically impossible at any terminal connected to APCS.
Common problems and how to avoid them
Wrong container number or booking before cut-off
The container number must be identical in three places simultaneously: in the export declaration (EAD/ABD), in the port system registration (ZAPP/BHT/Portbase/e-Desk), and in the booking confirmation from the shipping line. Any discrepancy — even a single digit or letter — will result in the container being blocked at gate-in.
Most common error: copying the container number from a customs agency document that may contain a planned number (from the booking stage), rather than the number of the actually assigned container. The number must always be verified against the pick-up confirmation issued by the road haulier.
If the container has not yet reached the terminal, the MRN and container number can be corrected directly in the Portbase or e-Desk system. After gate-in, changes can only be made by the terminal operator or the competent customs office.
MRN rejected at gate-in
A "blocked" status or refusal to accept the container by the port system may result from several causes: the MRN originates from a different Member State's system and is not recognised by the port system (integration issue), an incorrect item position number in the port order, expiry of the declaration's validity (beyond 150 days from release for export), or a formal error in the export declaration requiring correction.
In each of these cases, direct contact with the customs office of exit in the country of exit or the port system operator is required.
Dangerous goods (DG) – document sequence
Containers with dangerous goods cargo (commodity classes per the IMDG Code) require submission of a Dangerous Goods Declaration to both the shipping line and the terminal operator before the standard MRN registration in the port system. The absence of DG documentation blocks gate-in regardless of the customs release status. DG documents and MRN must be submitted simultaneously, or the DG documentation must be submitted first.
150-day deadline – risk of declaration invalidation
Pursuant to Article 248(2) of Commission Delegated Regulation (EU) 2015/2446, read in conjunction with Article 335 of Commission Implementing Regulation (EU) 2015/2447, if within 150 days from the date of release of the goods for export (message CC529C/formerly IE529) the customs office of export has not received information on the exit of the goods, nor alternative evidence confirming that the goods have left the customs territory of the Union, the customs office of export may invalidate the export declaration.
Once invalidated, the CC599C message cannot be generated. The exporter loses the possibility of applying the VAT zero-rate on the basis of that declaration and must take steps to obtain alternative proof of export or initiate a new procedure.
Recommended action: monitor the status of open MRNs, particularly in cases of logistical delays (holds, vessel changes, embargoes). If there is a risk of exceeding the deadline, contact the customs office of export without delay and submit explanations or an application.
Missing CC599C after vessel departure
It occasionally happens that the port system does not correctly transmit the exit confirmation to the customs system of the country of export — the cause may be an error in the CODECO message or a technical problem with the integration between the terminal system and the customs authority. If several days after the vessel departure date the CC599C has not reached the exporter or customs agency, the first step is to check the MRN status in the national customs system (e.g. PUESC for Polish declarations, ATLAS for German declarations) and obtain from the shipping line or ocean freight forwarder a confirmation of loading and departure (Manifest or Bill of Lading with departure date). Further steps — including potential application for manual generation of exit confirmation or compilation of alternative evidence — require contact with the customs office of exit and case-by-case analysis by a customs agency.
Frequently Asked Questions (FAQ)
Can a Polish MRN be closed through a port in Hamburg or Rotterdam?
Yes. An export declaration opened in Poland (AES/ECS2 PLUS system, with an MRN beginning with "PL") may be closed by any customs office of exit in the Union, including seaports in Germany, the Netherlands or Belgium. The condition is that the Polish MRN is registered in the relevant Port Community System (ZAPP, BHT, Portbase or e-Desk) before the container is delivered to the terminal. The same applies to MRNs from any other EU Member State.
Can MRNs from Germany, Belgium or the Netherlands be handled in the same systems?
Yes. Port systems are not restricted to domestic MRNs. Portbase, ZAPP, BHT and e-Desk handle MRN numbers from all EU Member States, provided the number structure is correct and the declaration is active in the customs system of the country of export.
What is CODECO and what role does it play?
CODECO (Container gate-in/gate-out report message; standard UN/EDIFACT/SMDG) is an electronic message transmitted by the terminal operator to the customs authority of the country of exit, confirming the physical arrival of the container at the terminal. It is on the basis of CODECO that the customs office monitors the consignment and — after the vessel's departure — generates the exit confirmation (CC599C). CODECO is a standard used at ports in the Netherlands, Belgium and elsewhere. Historically, the abbreviation derived from COntainer DEparture COnfirmation, but the current official message name in the UN/EDIFACT standard is Container gate-in/gate-out report message.
What is the difference between IE599 and CC599C?
Since 31 October 2024, EU Member States have been operating under upgraded AES systems with harmonised message designations. The IE599 message has been replaced by CC599C. Both documents serve an identical function: they confirm the physical exit of goods from the customs territory of the Union and constitute the basis for applying the VAT zero-rate on export transactions. Documents issued before 31 October 2024 as IE599 retain full validity.
Does the absence of CC599C always prevent the application of the VAT zero-rate?
As a general principle, CC599C (formerly IE599) is the primary and preferred document confirming export for VAT purposes. In exceptional circumstances, where the CC599C is demonstrably unobtainable, alternative evidence of export may be accepted. However, the specific evidentiary requirements for zero-rating exports vary by Member State; readers should consult their national VAT rules or a tax advisor.
Practitioner's note: If CC599C has not arrived within the expected timeframe, and the exporter holds a Bill of Lading bearing a "shipped on board" notation with the date and the carrier's stamp — this is practically the strongest available non-customs evidence of the physical loading of goods onto a vessel and departure from port. However, a B/L alone does not originate from a customs authority, and national tax authorities may challenge it as insufficient on its own. A significantly stronger position is achieved by combining the B/L with the EAD and — if available — the customs import document from the country of destination or a tracking confirmation from the carrier. Such a document set is difficult to challenge by either a tax authority or an administrative court.
Does centralised clearance (CCI) change how MRN is closed at the port?
No — the process at the port terminal itself is identical to that under standard clearance. Under the centralised clearance model (Article 179 of the Union Customs Code), the export declaration is lodged with a customs office in one Member State (e.g. Poland), even if the goods are physically located at a port in another Member State (e.g. Antwerp or Rotterdam). The result is the same MRN — a number beginning with "PL" — which must be registered in the Belgian e-Desk or Dutch Portbase before the container's gate-in, exactly as under domestic clearance. The customs office in Poland acts as the customs office of export, while the customs office of exit at the foreign port is responsible for closing the procedure and generating CC599C — but only after the terminal transmits the CODECO message.
What is zollfrei and when does it occur?
Zollfrei (literally: customs-free) is a colloquial term used among freight forwarders for the customs release status assigned by the port system. In practice, it denotes the moment when ZAPP or BHT sets the reference status to "released" — the container may be loaded onto the vessel. For standard Z-numbers in Hamburg, this occurs approximately 2 hours after gate-in, provided the customs office has not ordered an additional inspection.
Legal basis
The export procedure, MRN closure and requirements for proof of export are governed by the following legal acts:
- Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code (UCC) — Articles 263–272 (formalities and export procedure, exit of goods from the customs territory of the Union), in particular Article 269 (export of Union goods).
- Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 — in particular Article 248(2) (150-day time limit and basis for invalidation of the export declaration).
- Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 — Article 329 (customs office of exit), Articles 333–334 (exit formalities and exit confirmation), Article 335 (invalidation of the export declaration).
- National VAT legislation of the respective EU Member State — provisions governing the VAT zero-rate for exports and the catalogue of documents accepted as proof of export. The specific evidentiary requirements vary by Member State; exporters should consult their national VAT rules or a tax advisor.
Article updated: February 2026. The information in this article is for informational and educational purposes only. For individual matters, consultation with a customs agency or tax advisor is recommended.
