Open MRN After Export — 7 Most Common Reasons and How to Fix Them
Your company exported goods through a sea port, the container sailed weeks ago, but the MRN still shows as “open” in the system? You haven't received the IE599 (CC599C) message, and the VAT return deadline is approaching? This is one of the most common problems for exporters. In this article, we cover the 7 main reasons why an MRN is not closed and present concrete solutions for each.
What Is an Open MRN and Why Is It a Problem?
MRN (Movement Reference Number) is a unique 18-character number assigned to each export declaration in the European AES (Automated Export System). It identifies a specific shipment from the moment the export declaration is filed until the physical departure from EU territory is confirmed.
An “open” MRN means the export procedure has not been formally completed. The customs office of exit has not confirmed that the goods left the EU, so the IE599 message has not been generated. Without IE599, the exporter cannot apply the 0% VAT rate and faces significant tax consequences.
Reason 1: Missing Port System Registration
The most common cause. The export was not properly registered in the Port Community System (PCS) — Portbase for Rotterdam, ZAPP for Hamburg, APCS for Antwerp. Without registration, the port system cannot match the MRN to the vessel manifest, so the automatic closure process never starts.
How to fix: Contact the forwarder or port agent and ask them to register the export in the relevant PCS. Provide the MRN, container number, and booking reference.
Reason 2: Incorrect Data in the Export Declaration
Even a single character error in the container number, weight, or goods description can prevent the automatic matching between the export declaration and vessel manifest. The port system compares data fields and rejects mismatches.
How to fix: Compare the export declaration (EAD) data with the booking confirmation from the carrier. If discrepancies are found, request a correction through your customs agent. In some cases, a new matching attempt in the PCS is sufficient.
Reason 3: Terminal Did Not Confirm Loading
The terminal operator must confirm in the port system that the container was physically loaded onto the declared vessel. If this confirmation is missing — due to a system error or administrative oversight — the MRN remains open.
How to fix: Request the terminal operator to confirm the loading in the PCS. Your forwarder or port agent can facilitate this. A copy of the Bill of Lading confirming the vessel and container can support the request.
Reason 4: Communication Failure Between Customs Offices
MRN closure requires a chain of electronic messages between the customs office of exit and the customs office of export (IE518). Technical failures, system outages, or configuration issues between different member states' customs systems can break this chain.
How to fix: Contact the customs office of export (in Poland: through PUESC or your customs agent) and report the issue. They can send an enquiry to the customs office of exit to verify the export status.
Reason 5: Customs Agent Oversight
Sometimes the customs agent did not properly submit the export pre-notification to the port system, did not link the MRN with the booking, or did not follow up on the export status after filing the declaration.
How to fix: Verify with your agent that the export was properly registered in the port system. Request documented proof of pre-notification. If the agent cannot resolve the issue, consider engaging a specialist.
Reason 6: Route Change (Diversion)
The container was loaded onto a different vessel or left the EU through a different port than declared in the export declaration. For example, the declaration states Hamburg as the office of exit, but the container actually sailed from Rotterdam due to a carrier route change.
How to fix: This requires a LOI (Letter of Indemnity) procedure. A formal letter must be sent to the customs office of exit with evidence that the goods left through a different port. The letter should include the MRN, container number, actual vessel details, and a copy of the Bill of Lading. This process typically takes 1–4 weeks.
Reason 7: Goods Did Not Actually Leave the EU
In rare cases, the container was not loaded onto the vessel due to a booking cancellation, customs hold, or other logistics issue. The goods may still be at the port or have been returned to the exporter.
How to fix: Verify the container status with the carrier (Track & Trace) and the terminal. If the goods are confirmed as not exported, the export declaration must be invalidated (Art. 336 UCC-IA). A new export procedure will be needed for the next shipment attempt.
Summary
| Reason | Frequency | Resolution Time |
|---|---|---|
| 1. Missing port registration | Very common | 1–3 days |
| 2. Incorrect declaration data | Common | 2–7 days |
| 3. No loading confirmation | Moderate | 1–5 days |
| 4. Inter-office comm. failure | Occasional | 1–4 weeks |
| 5. Agent oversight | Common | 2–7 days |
| 6. Route change | Occasional | 1–4 weeks |
| 7. Goods not exported | Rare | Variable |
FAQ — Open MRN
How long does customs have to close an MRN?
Under EU regulations, an export declaration (MRN) should be closed automatically after the physical export of goods from the EU is confirmed. In practice, the standard time is 1–5 business days after the vessel departs. If the MRN is not closed within 150 days, it is subject to invalidation by the system, which significantly complicates obtaining proof of export.
Can I close an MRN myself in PUESC?
No. An exporter cannot close an MRN in PUESC on their own. Closure happens automatically after the customs office of exit confirms the export. However, you can monitor MRN status in PUESC and intervene if there are delays — e.g., by requesting a check in the port system (ZAPP, Portbase, APCS) or contacting customs.
My MRN has been open for over 3 months — what should I do?
After 90 days the situation becomes urgent, as the MRN is invalidated after 150 days. You should immediately identify the cause (usually missing port system registration or data errors), gather export evidence (Bill of Lading, booking confirmation), and file a request for manual MRN closure with the relevant customs office of exit.
Does an open MRN mean I must pay domestic VAT?
Yes, if you do not receive proof of export (CC599C/IE599) before the VAT return deadline, you must declare the transaction at your country's standard domestic VAT rate (e.g., 23% in Poland, 19% in Germany, 21% in the Netherlands). After obtaining proof of export, you can correct the VAT return and recover the overpaid tax, but this involves additional administrative costs and frozen funds.
Who is responsible for closing the MRN — exporter or forwarder?
Formally, responsibility for proper conduct of the export procedure lies with the exporter (or their customs representative). In practice, however, MRN closure depends on many parties: customs agent (correct declaration), forwarder (port system registration), carrier (vessel manifest), and terminal operator (loading confirmation). Coordination between all logistics chain participants is essential.
Legal basis: Art. 334-336 of Commission Implementing Regulation (EU) 2015/2447; Art. 41 of the Polish Act on Goods and Services Tax. This article is for informational purposes and does not constitute legal or tax advice. Updated: March 2026.