MRN Enquiry Procedure — New 20-Day Rule Since September 2025
Since September 2025, the minimum waiting period for an enquiry request on open export declarations has been reduced from 70 to 20 days. This amendment to Art. 335 of Implementing Regulation (IA) 2015/2447 to the Union Customs Code is one of the most significant recent changes for exporters. If your MRN remains open and you are missing the CC599C/IE599 export confirmation — you now have substantially more time to resolve the situation before the 150-day deadline.
What Is an Enquiry Procedure?
The enquiry procedure (German: Nachforschungsersuchen, Polish: postepowanie poszukiwawcze) is a formal customs procedure initiated when the export confirmation message (CC599C, formerly IE599) has not been generated automatically following an export shipment.
The legal basis is Art. 335 of Implementing Regulation (IA) 2015/2447 to the Union Customs Code (UCC, Regulation 952/2013). The purpose of the procedure is to officially establish whether the goods have in fact left the customs territory of the European Union.
The mechanism is straightforward: the customs office of export (e.g., in Poland, Germany, or another EU Member State) contacts the customs office of exit (typically at the port through which the goods were shipped) and requests confirmation that the goods have departed. If the office of exit confirms the exit — the MRN is closed and the exporter receives their export confirmation.
Without the enquiry procedure, an open MRN remains unresolved — and the exporter has no proof of export for VAT purposes.
The New 20-Day Rule: What Changed in September 2025?
In September 2025, Art. 335 of Implementing Regulation (IA) 2015/2447 was amended. The key change:
| Parameter | Before September 2025 | Since September 2025 |
|---|---|---|
| Minimum waiting period | 70 days from release of goods | 20 days from release of goods |
| Earliest request date | Day 71 | Day 21 |
| Validity of export declaration | 150 days | 150 days (unchanged) |
| Remaining time to act after waiting period | 80 days (day 71–150) | 130 days (day 21–150) |
Why does this matter? Reducing the minimum waiting period from 70 to 20 days gives exporters 50 additional days to obtain their export confirmation before the 150-day validity of the declaration expires. More time to act means a significantly higher chance of success.
When Should You Initiate an Enquiry?
An enquiry procedure is warranted when:
- You know the goods have physically left the EU (the vessel has sailed), but you have not received the export confirmation CC599C/IE599
- At least 20 days have passed since the release of goods (new minimum since September 2025)
- Attempts to resolve the matter through the port system have not produced a result
- The MRN shows as “open” or “not closed” in the customs system
- You need the 0% VAT proof of export and are running out of time within the 150-day window
Important: Do not delay. After 150 days from the release of goods, obtaining a standard export confirmation becomes considerably more difficult. We recommend taking action no later than day 21.
How the Enquiry Procedure Works
The procedure follows a defined structure. Below we describe what happens at each stage — not how to conduct the procedure yourself (this requires specialist knowledge and access to customs systems).
Request to the customs office of export
The exporter or their authorized representative files a formal enquiry request with the customs office of export (the office that processed the original export declaration). The request must include the MRN, the export declaration, and any available evidence of the goods having left the EU.
Communication with the customs office of exit
The customs office of export contacts the customs office of exit — typically the customs authority at the port through which the goods were shipped (e.g., Hamburg, Rotterdam, Antwerp). It requests information on the status of the goods' departure.
Verification of the facts
The customs office of exit reviews its records and the data available from port-level systems. If it can confirm that the goods have left the port, it registers the exit in the customs system.
Outcome
In the best case, the export confirmation CC599C is issued retroactively — the MRN is closed, and the exporter receives their proof of export. If this is not possible, the customs office of export may issue an alternative exit confirmation or direct the exporter to use alternative documentary evidence.
Alternative Proof of Export
If the enquiry procedure does not result in the issuance of a standard CC599C confirmation, there are two alternative paths:
Alternative exit confirmation
The customs office of export may issue an alternative exit confirmation if the exit of goods has been demonstrated through other means. This confirmation carries the same legal weight as a standard CC599C for VAT purposes, although in practice it may be subject to closer scrutiny by the tax authority.
Alternative documentary evidence
In situations where no customs-issued confirmation is attainable, the tax authority may accept other forms of documentary evidence of export:
- Bill of Lading with an “on board” notation confirming the goods were loaded onto the vessel
- CMR consignment note with confirmation of receipt at the destination outside the EU
- Forwarder certificate attesting that the export took place
- Chamber of Commerce certificate from the country of destination
Recommendation: A standard CC599C export confirmation always provides the highest degree of legal certainty. It is advisable to exhaust all possibilities of obtaining one before resorting to alternative documentary evidence.
Why Use a Specialist?
The enquiry procedure is a technically and legally demanding process that requires specialist expertise:
- Access to port-level systems — identifying the root cause of an unclosed MRN often requires access to port systems at major European seaports. Individual exporters typically do not have this access.
- Contacts with foreign customs offices — direct working relationships with customs authorities at exit ports can accelerate the procedure from weeks to days.
- Documentation expertise — the quality of the request and the supporting documents has a direct impact on the outcome and duration of the procedure.
- Cross-border expertise — when goods are exported through foreign ports (DE, NL, BE), familiarity with each country's national customs procedures is essential.
The cost of engaging a specialist is negligible compared to the potential VAT correction — at a standard rate of 19–23% on the value of the exported goods, the financial exposure on a single declaration can run into tens of thousands of euros.
Frequently Asked Questions
What is an MRN enquiry procedure?
A formal customs procedure under Art. 335 of Implementing Regulation (IA) 2015/2447 to the Union Customs Code. It is initiated when the export confirmation CC599C/IE599 has not been issued automatically. The customs office of export contacts the customs office of exit to clarify whether the goods have left the EU customs territory.
How soon can I file an enquiry request?
Since September 2025 — after just 20 days from the release of goods (previously 70 days). This amendment to Art. 335 IA 2015/2447 gives exporters significantly more time to act before the 150-day validity of the export declaration expires.
What if my MRN has been open for more than 150 days?
After 150 days, obtaining a standard export confirmation is considerably more difficult, but not impossible. You may still be able to obtain an alternative exit confirmation or use alternative documentary evidence (e.g., Bill of Lading with “on board” notation, CMR). Contact a specialist as soon as possible — every day of delay reduces the chances of a successful outcome.
Can I file the enquiry request myself?
Formally, yes — the request is filed by the exporter or their authorized representative. In practice, it requires knowledge of customs procedures, access to port-level systems, and contacts with foreign customs offices. A specialist intermediary significantly accelerates the process and improves its success rate.
How long does the enquiry procedure take?
From a few days to several weeks — depending on the complexity of the case, the response time of the customs office of exit, and the quality of the supporting documentation. A specialist with direct contacts at European ports can significantly shorten this timeline.
Related Articles
Z Number — Export Registration in Hamburg | VAT 0% Export — CC599C Explained | What Happens If MRN Stays Open? | MRN Closure Timeline
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