T1 transit explained for importers

T1, the external Union transit procedure, lets goods from outside the EU move from one point in the EU customs territory to another without paying import duty on the way. Article 226 of the Union Customs Code, Regulation (EU) No 952/2013, suspends import duty, other charges and commercial policy measures during the movement. Duty and VAT are dealt with where the transit ends. The movement runs in NCTS, the EU’s electronic transit system, under a guarantee and within a time limit set by customs.

The procedure exists because the EU is one customs territory with many tax territories. The European Commission’s Transit Manual says so directly: “goods can move under transit from their point of entry into the EU to the point of their final destination.”

What is T1 external transit?

The Transit Manual describes T1 as a procedure that “applies mainly to movements of non-Union goods.” It suspends import duties, other charges and trade policy measures “until the goods reach their destination in the Union.” Its companion, T2, covers Union goods that pass through a country outside the EU customs territory.

The legal basis is the Union Customs Code, with Delegated Regulation (EU) 2015/2446 and Implementing Regulation (EU) 2015/2447. The procedure starts at a customs office of departure and ends when the goods and the reference number of the transit declaration are presented at the customs office of destination.

At that point, in the Manual’s words, “the customs and local fiscal obligations are taken care of and the goods released for free circulation, or placed under another suspensive customs procedure.”

Can goods landing in Spain clear in Portugal?

Yes. A container moves under transit when it lands in one place but is to be cleared in another. The destination can be an inland customs office in the same country or an office in another member state.

Suppose a container of machine parts, made outside the EU for stock held in Portugal, lands at a Spanish port. Instead of releasing the goods in Spain, a T1 declaration is lodged at the Spanish office of departure. The container travels by road to the Portuguese office of destination. There it is released for free circulation, with duty and import VAT settled in Portugal, or placed in a customs warehouse.

The Spanish port is where the goods enter the EU. Portugal is where they are cleared. Transit is the procedure that connects the two.

What is the holder liable for?

The holder of the procedure is the person who lodges the transit declaration at the office of departure, or the person for whom it is lodged, under Article 5(35) of the Union Customs Code. Under Article 233(1) of the Union Customs Code, the holder is responsible for three things:

1. presenting the goods intact, with the required information, at the office of destination within the prescribed time limit;
2. observing the customs provisions relating to the procedure;
3. providing a guarantee, unless the customs legislation provides otherwise.

The Transit Manual adds that seals must be intact where they were applied. The holder’s obligations end when the goods and the required information are available at the office of destination, under Article 233(2). The office of departure then discharges the procedure and the holder’s liability, “unless major discrepancies have been noted.”

The carrier and the recipient carry part of the risk too. Under Article 233(3), a carrier or recipient who accepts the goods knowing they move under transit must also present them intact at destination within the time limit.

When an obligation is broken, a customs debt arises under Article 79 of the Code. The debtor includes “any person who was required to fulfil the obligations concerned.” In transit, Article 233(1) places those obligations on the holder.

The holder of a T1 declaration answers for the goods from the office of departure to the office of destination. If the container is not presented intact within the time limit, the duty the transit suspended can become the holder’s debt.

How does the transit guarantee work?

Duties are suspended during transit, so customs asks for security. The Transit Manual states that the holder “is required to furnish a guarantee” to ensure payment of any debt incurred during the operation. No guarantee data on the declaration means the declaration is not accepted. An insufficient guarantee means the goods are not released for transit.

The guarantee takes one of two shapes:

Guarantee	Covers	Amount
Individual, by cash deposit, guarantor’s undertaking or voucher	one transit operation	100 percent of the customs debt that may be incurred
Comprehensive, under an authorisation	several operations	100, 50, 30 or 0 percent of the reference amount

An individual guarantee covers one movement, calculated in general on the highest duties and charges for the goods in the country of departure. A comprehensive guarantee is sized once and covers many movements. Its reference amount rests on the previous 12 months of transit and the expected volume, at the highest rates in the country of the office of guarantee. Where that history is not available, the Manual fixes it at 10,000 euros for each transit operation. For Union transit, a guarantee is valid in all member states and, unless they are excluded in the guarantor’s undertaking, in Andorra and San Marino.

What do NCTS and the MRN do?

NCTS, the New Computerised Transit System, is described in the Manual as “a trans-European IT application for managing and controlling the transit system.” It is generally mandatory for Union transit, both external and internal.

The declaration is sent electronically. Once it is accepted, NCTS generates the movement’s master reference number (MRN), which identifies it. The MRN, or a paper transit accompanying document, travels with the goods. The office of departure sends an anticipated arrival record to the declared office of destination. When the goods arrive, the destination office sends an arrival advice back, and later its control results. The office of departure then discharges the procedure.

Who sets the T1 time limit?

The office of departure sets a time limit for presenting the goods at destination. Under Article 297 of the Implementing Regulation, as explained in the Transit Manual, that limit binds the authorities of every country the goods enter. They cannot change it. In setting it, the office of departure takes account of the means of transport and the itinerary, among other factors.

Late arrival is not automatically a breach. The holder is deemed to have complied if the holder or the carrier proves to the office of destination that the delay is not attributable to them.

What do authorised consignor and consignee change?

Article 233(4) of the Union Customs Code allows two simplifications. An authorised consignor can place goods under transit without presenting them at the office of departure. An authorised consignee can receive goods under transit at its own authorised place.

In NCTS terms, the authorised consignor creates the declaration in its own system and sends it without taking the goods to the customs office. The authorised consignee receives the goods and the MRN at its premises and sends the arrival notification to the office of destination.

The conditions are strict. Under Article 191 of Delegated Regulation (EU) 2015/2446, the applicant must be established in the EU, use Union transit regularly and meet criteria (a), (b) and (d) of Article 39 of the Code, under Article 191(1)(c). Under Article 193, an authorised consignor must already be authorised to provide a comprehensive guarantee or to use a guarantee waiver. A business established outside the EU therefore cannot hold either status itself.

How does transit compare with release at the port?

Both routes serve a container that lands in one member state for stock held in another. They settle duty and import VAT in different places.

Question	T1 transit to Portugal	Release at the port of arrival
Where the goods are released for free circulation	at the office of destination in Portugal	in the member state of entry, at the port
When the customs debt arises	on acceptance of the release declaration in Portugal	on acceptance of the release declaration at the port
Import VAT	due in Portugal on release; can go in the VAT return where article 27.º n.º 8 of the Código do IVA applies	due in the member state of entry on release, under that country’s rules
VAT registrations the route relies on	Portugal only	the country of entry and Portugal
Customs obligation on the way to Portugal	goods presented intact at destination within the time limit	none, because the goods already hold the status of Union goods
Security for the movement	transit guarantee covering the suspended duty and charges	no transit guarantee, because the goods are released at the port

Under Article 77 of the Union Customs Code, the customs debt on import arises on release for free circulation, at the time the declaration is accepted. Transit moves that moment to the destination. Release at the port keeps it at the port, and the stock then travels to Portugal as Union goods. Under Articles 21 and 40 of the VAT Directive, a transfer of the importer’s own goods to Portugal is then an intra-Community acquisition taking place in Portugal, where the transport ends. How a business from outside the EU registers there is covered in who needs a fiscal representative in Portugal.

Separately from the release route chosen, where the stock is sold on to VAT-registered business buyers in other member states, the import can be set up so that no import VAT is paid in Portugal. Those onward sales are zero rated under Article 138 of the VAT Directive, as explained in zero-rated B2B sales from stock in Portugal. EFC structures that route case by case, for business sales only; talk to EFC about a specific flow.

Where does a customs warehouse fit?

A transit can end by placing the goods under another suspensive procedure, such as customs warehousing, instead of releasing them. Release on arrival is the usual route. A customs warehouse suits higher-value goods that move in smaller volumes. Each release from the warehouse into free circulation is its own tax point, when duty and import VAT fall due. The facility and the procedure are described on the bonded warehouse page, and the cash effect of each route in bonded or release on arrival, in numbers.

This is general information, not legal or tax advice. The customs offices of departure and destination apply the rules to each movement.

How this runs at EFC

A container bound for EFC’s base in Portugal, run with its logistics partner, may land at another EU port first. Whether it clears at that port or travels to Portugal under transit is chosen with the client, on the goods, the flow and the registrations already held. On arrival in Portugal, the goods are released for free circulation or enter customs warehousing, and the transit is discharged against that arrival.

Sources

Label	Value	Source
Transit purpose	goods move from the point of entry to the point of final destination; obligations settled where transit ends	European Commission, Transit Manual, 31 July 2026, TAXUD/A1/TRA/001/2025-1-EN, Part I.1, opened 2026-07-23
T1 definition	applies mainly to non-Union goods; suspends duties, charges and trade policy measures until destination	Transit Manual, I.4.1.2 and I.4.1.2.1, opened 2026-07-23
Holder of the procedure	operator lodging the declaration; presents goods intact within the time limit; discharge unless major discrepancies	Transit Manual, I.4.1.2, opened 2026-07-23
NCTS and MRN	trans-European IT application; generally mandatory; MRN issued on acceptance	Transit Manual, I.4.1.3, I.4.1.3.1 and IV.2.3.1, opened 2026-07-23
Authorised consignor and consignee in NCTS	declaration from own system without presenting goods; goods and MRN received at own premises	Transit Manual, I.4.1.3.8, opened 2026-07-23
Guarantee	individual: 100 percent of the debt; comprehensive: 100, 50, 30 or 0 percent of the reference amount; for Union transit, valid in all member states and, unless excluded in the guarantor’s undertaking, Andorra and San Marino	Transit Manual, III.1.1, III.1.2, III.1.4 and III.1.5, opened 2026-07-23
Guarantee calculation	declaration refused without guarantee data; individual guarantee on highest rates in the country of departure; comprehensive reference amount on highest rates in the country of the office of guarantee, on 12 months, or 10,000 euros per operation	Transit Manual, III.2.1, III.2.2 and III.4.1.3, opened 2026-07-23
Time limit	set by the office of departure; binding; late arrival excused if not attributable	Transit Manual, IV.2.3.6, opened 2026-07-23
External transit	non-Union goods move without import duty, other charges or commercial policy measures	Regulation (EU) No 952/2013, Article 226, as adopted, on legislation.gov.uk, opened 2026-07-23
Obligations	holder, carrier and recipient; end of obligations; authorised consignor and consignee	Regulation (EU) No 952/2013, Article 233, as adopted, on legislation.gov.uk, opened 2026-07-23
Debt on non-compliance	debtor includes any person required to fulfil the obligations	Regulation (EU) No 952/2013, Article 79, as adopted, on legislation.gov.uk, opened 2026-07-23
Debt on release	incurred on release for free circulation, at acceptance of the declaration	Regulation (EU) No 952/2013, Article 77, as adopted, on legislation.gov.uk, opened 2026-07-23
Simplification conditions	established in the EU, regular use, Article 39(a), (b) and (d) criteria under Article 191(1)(c); comprehensive guarantee or waiver authorisation	Delegated Regulation (EU) 2015/2446, Article 191 and Article 193, as adopted, on legislation.gov.uk, opened 2026-07-23
Intra-Community supply to a business	exempt where the goods are dispatched to another member state for a buyer identified for VAT there	Directive 2006/112/EC, Article 138, EU text on legislation.gov.uk, opened 2026-09-24
Holder of the procedure, definition	person who lodges the declaration, or for whom it is lodged	Regulation (EU) No 952/2013, Article 5(35), as adopted, on legislation.gov.uk, opened 2026-07-23
Transfer of own goods	treated as an intra-Community acquisition; place where transport ends	Directive 2006/112/EC, Article 21 and Article 40, EU text on legislation.gov.uk, opened 2026-07-23
Portugal, import VAT in the return	option under article 27.º n.º 8, with conditions	Código do IVA, artigo 27.º, Portal das Finanças, opened 2026-07-23