TLDR: To justify transport costs related to exports outside the EU, the main document is the electronic certification of exit from the territory of the European Union (dematerialized customs declaration). In case of system failure, copy no. 3 of the SAD (endorsed by customs) is valid. Alternative elements (import declaration of the third country, accompanying documents for excise goods, transport documents) are accepted under strict conditions.
Main document for dematerialized declarations
The electronic exit certification issued as part of the dematerialized customs export declaration is the standard proof. It certifies the effective export of goods outside the EU and is valid for all operations where the procedure is fully digital.
Special case of express freight companies
For shipments via an express transport company, the electronic exit certification issued by its IT system is sufficient, provided that:
- the exporter is explicitly named in box 2 bis of the dematerialized export declaration;
- the document includes: the approval number for the express shipment clearance procedure, the names and addresses of the exporter and the consignee, the invoice numbers and dates, the description and value of the goods, the references of the air waybill or shipping note, the customs office code of export and the date of registration of the declaration;
- the document is signed by the responsible person of the company that carried out the customs clearance operations.
Paper-based procedure (fallback procedure)
In case of failure or unavailability of the electronic system, the supporting document is copy no. 3 of the SAD (Single Administrative Document), endorsed by the customs office at the EU exit point.
Alternative proof elements
The exporter may use alternative elements provided for in Article 74 of Annex III to the CGI, in place of the electronic certification or the SAD. These include:
- the customs import declaration of the exported goods, authenticated by the customs administration of the third country of final destination, or a certificate from this administration accompanied by an official translation. The data must be consistent with those of the export declaration (nature and quantity of the goods);
- for excise goods, the accompanying documents provided for in Article 302 M ter of the CGI, issued on paper or transmitted electronically via the Gamm@ teleprocedure, and endorsed by the customs office at the EU exit point.
Transport documents
Transport documents (international waybills, bills of lading, etc.) can serve as proof to justify VAT exemption only if the goods are shipped to a country outside the European Union. Documents certifying only transport to a place, port or airport located within the EU are not valid to justify an export outside the EU.
Obligations and formalities
The export declaration or the documents replacing it, as well as the alternative proof elements, constitute the essential justification of exports for VAT purposes. Exporters must retain these documents and be able to present them at any time for inspection by the authorities.