Lossingsvergunning
Also known as: permission to unload, DVA arrival
A lossingsvergunning is permission to unload the container or the consignment at the place of destination. In the Netherlands you request it in DVA, as DVA arrival, after the T1 has arrived.
What is a lossingsvergunning?
A lossingsvergunning is permission from customs to unload goods travelling under a T1 at the stated place. Without that permission you may not open the doors and you may not take the goods off the means of transport. The T1 is still live. Unloading would break the supervision. In the Netherlands this runs through DVA, the system for T1 and T2 documents. The request is called DVA arrival, in plain Dutch toestemming tot lossing. Lossingsvergunning is the term used in the chain. It is a Dutch system item. In ATLAS or AES it does not exist under that name. The permission is the starting signal for the next step. After it is granted you may unload, and the clock starts for the follow-up declaration: an IMA into free circulation or an STO into the warehouse. Without a lossingsvergunning that follow-up declaration has no valid place of presentation.
When do you request a lossingsvergunning?
You request it after the goods have arrived at the place of destination, not earlier. The office of destination, or the authorised consignee, reports arrival and requests permission to unload. In DVA that is the arrival message, linked to the MRN of the T1 and to the goods location. On the warehouse route the order is tight. The T1 has a validity, in Dutch practice often fourteen days from departure. Within that period the request for the lossingsvergunning must be in. After that you have three days, seventy-two hours, to close the T1 with an IMA or an STO. If you request too early, while the container is still on the terminal or still on the way, DVA rejects it or the message lands on a location where the goods are not. If you request too late, the T1 is already under enquiry. The window sits between arrival and the end of the T1 time limit.
How does the lossingsvergunning relate to the T1?
The lossingsvergunning does not close the T1. It only opens the possibility to unload and to file the follow-up declaration. The T1 stays open until that follow-up declaration is accepted and discharge has followed. Anyone who treats the lossingsvergunning as discharge leaves the document open. The chain is: open the T1 at departure, report arrival, receive the lossingsvergunning, unload, file IMA or STO, discharge the T1. Each step refers to the same MRN. The lossingsvergunning is the link between travelling and placing. Without that link customs cannot see that the goods stand under supervision at the right location. On a warehouse track the lossingsvergunning is also the start of the seventy-two hour window. That window is short. Data that are then still missing (invoice, power of attorney, inspection result) push you towards an STO instead of an IMA, or towards an open T1. The permission itself buys no extra time.
What do you need to make the request?
The MRN of the T1, the goods location as it is known in DVA, and confirmation that the consignment is actually there. The location must match the authorisation of the authorised consignee or the office of destination. A home address that is not on the authorisation, or a warehouse that is not a customs warehouse while you want to file an STO, produces a rejection. In chains with an interface the consignee requests the lossingsvergunning from the party that holds the T1, or files it himself if he is the holder. The request typically arrives once the container has arrived. ATA alone is not enough. The consignment must be at the unloading location, not only in the country. Check the container number against the MRN. A T1 with several containers, or a shipment with a T1 and a separate import declaration, has numbers that mix. Filing the wrong combination is a standard reason for a refusal that arrives in the mail as a system error.
What goes wrong with the lossingsvergunning?
The most common mistake is that arrival is never seen. Without a terminal status or without a Portbase link, departure from the terminal stays unknown, and the DVA arrival is never sent. The T1 is live, the container stands at the warehouse, and nobody has asked permission to unload. The mail that then arrives is called request to unload or refused by system. The second mistake is unloading without permission. The doors open because the truck is there. Administratively the T1 is still live. Customs sees a consignment that has not been presented and has not been unloaded with permission. That is a breach of the transit, with an enquiry as a result. The third mistake is forgetting the follow-up declaration after the grant. The permission is in, the goods sit in the shed, and the three days run out. On day four the T1 is an open document. File the IMA or the STO within the window, even if you only want to clear the goods later.
How do you monitor lossingsvergunningen in the chain?
Put three statuses next to each other: T1 open, lossingsvergunning requested or granted, follow-up declaration present. A line with T1 open and no request, while the ATA is in, is work. A line with permission granted and no IMA or STO is work with a three-day clock. Link the goods location to the authorisation. A consignment that goes to a location that is not authorised will not get a lossingsvergunning, however well the T1 was drawn up. That is not a DVA fault. That is a location that is not on the authorised consignee's authorisation. Lossingsvergunning stays the Dutch term in every language. A German forwarder requests something else in ATLAS. A British declarant works in CDS. If you read this page because you arrive in the Netherlands, DVA arrival is the action and lossingsvergunning is the name that stands in the mails.