Compilers guide on European statistics on international trade in goods : 2015 edition.
Date: 2015-10-08
Institutions: Eurostat
Subjects: EU law, economic indicator, goods and services, international trade, statistical method, trade statistics, user guide

ISSN 1681-4789
ISSN 2315-0815

Manuals  and  guidelines

Compilers guide on European statistics  
on international trade in goods
Rilis augiati siscilit venis nim 

2015 edition

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Manuals  and  guidelines

Compilers guide on European statistics 
on international trade in goods

2015 edition
2041 edition

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Luxembourg: Publications Office of the European Union, 2015

ISBN 978-92-79-51703-7
ISSN 2315-0815
doi:10.2785/14636
Cat. No: KS-GQ-15-010-EN-N

Theme 6: International trade
Collection: Manuals and guidelines

© European Union, 2015
Reproduction is authorised provided the source is acknowledged.

Contents 

Contents 
Table of figures ............................................................................................................................ 6 
List of Tables ............................................................................................................................... 7 
Acronyms and abbreviations ..................................................................................................... 8 
Preface .......................................................................................................................................... 9 
Introduction .......................................................................................................................... 10 
1 
1.1  History of International Trade in Goods Statistics ................................................. 15 
2  The framework ...................................................................................................................... 17 
2.1  Legal basis .................................................................................................................. 17 
Institutional arrangements ........................................................................................ 18 
2.2 
2.2.1  To whom legislation is addressed ..................................................................... 18 
2.2.2  Administrative structures in Member States ...................................................... 19 
2.2.3  Cooperation between institutions ...................................................................... 21 
2.3  Scope .......................................................................................................................... 22 
2.3.1  Intra-EU trade statistics ..................................................................................... 22 
2.3.2  Extra-EU trade statistics .................................................................................... 23 
2.3.3  List of exclusions and inclusions ....................................................................... 26 
2.3.4  Special cases for recording trade transactions ................................................. 34 
2.4  Statistical territory ..................................................................................................... 44 
2.5  Data sources............................................................................................................... 46 
2.5.1  Intra-EU trade statistics ..................................................................................... 46 
2.5.2  Extra-EU trade statistics .................................................................................... 48 
2.5.3  Data sources for specific goods or movements ................................................ 50 
2.6  Data collection process ............................................................................................. 52 
2.6.1  Intra-EU trade statistics ..................................................................................... 52 
2.6.2  Extra-EU trade statistics .................................................................................... 64 

3.1 

3  The data ................................................................................................................................. 70 
Identification number of the PSI/operator ............................................................... 70 
3.1.1  Intra-EU trade statistics ..................................................................................... 70 
3.1.2  Extra-EU trade statistics .................................................................................... 70 
3.2  Reference period ........................................................................................................ 71 
3.2.1  Intra-EU trade statistics ..................................................................................... 71 
3.2.2  Extra-EU trade statistics .................................................................................... 71 
3.3  Commodity Code ....................................................................................................... 72 
3.3.1  Combined Nomenclature ................................................................................... 72 
3.3.2  TARIC ................................................................................................................ 73 
3.3.3  Special Combined Nomenclature codes ........................................................... 73 
3.4  Partner Member State/partner country .................................................................... 74 
3.4.1  Geonomenclature .............................................................................................. 74 
3.4.2  Intra-EU trade statistics ..................................................................................... 75 
3.4.3  Extra-EU trade ................................................................................................... 76 
Importing or exporting Member State (extra-EU trade) ......................................... 77 
3.5.1  Member State of destination .............................................................................. 78 
3.5.2  Member State of actual export .......................................................................... 78 
3.6  Value ............................................................................................................................ 79 
3.6.1  Intra-EU trade statistics ..................................................................................... 79 

3.5 

Compilers guide on European statistics on international trade in goods 

3 

 
 
 
 
Contents 

3.6.2  Extra-EU trade statistics .................................................................................... 86 
3.7 
Invoicing currency (extra-EU trade) ......................................................................... 88 
3.8  Quantity ....................................................................................................................... 89 
3.9  Customs procedure ................................................................................................... 90 
3.9.1  Intra-EU trade statistics ..................................................................................... 90 
3.9.2  Extra-EU trade statistics .................................................................................... 91 
3.10  Statistical procedure ................................................................................................. 92 
3.10.1 Intra-EU trade statistics ..................................................................................... 92 
3.10.2 Extra-EU trade statistics .................................................................................... 93 
3.11  Nature of Transaction ................................................................................................ 94 
3.12  Preferential treatment on import ............................................................................ 105 
3.13  Mode of transport .................................................................................................... 106 
3.13.1 Intra-EU trade statistics ................................................................................... 107 
3.13.2 Extra-EU trade statistics .................................................................................. 107 
3.14  Region ....................................................................................................................... 109 
3.14.1 Intra-EU trade statistics ................................................................................... 109 
3.14.2 Extra-EU trade statistics .................................................................................. 110 
3.15  Delivery terms .......................................................................................................... 110 
4  Specific goods or movements .......................................................................................... 112 
4.1 
Industrial plant ......................................................................................................... 112 
4.2  Staggered consignments ........................................................................................ 113 
4.3  Vessels and aircraft ................................................................................................. 114 
4.3.1  Tools to identify the economic owner .............................................................. 115 
4.3.2  Transactions and variables to be recorded ..................................................... 118 
4.3.3  Data sources .................................................................................................... 121 
4.3.4  Leasing arrangements ..................................................................................... 123 
4.4  Motor vehicle and aircraft parts ............................................................................. 125 
4.5  Goods delivered to vessels and aircraft ................................................................ 125 
4.5.1  Data sources .................................................................................................... 127 
4.6  Goods delivered to and from offshore installations ............................................ 128 
4.6.1  Recording difficulties and data sources ........................................................... 129 
4.7  Sea products ............................................................................................................ 132 
4.8  Spacecraft ................................................................................................................. 133 
4.9  Electricity and gas ................................................................................................... 134 
4.9.1  The electricity sector business model .............................................................. 135 
4.9.2  The gas sector business model ....................................................................... 136 
4.9.3  VAT rules for electricity and gas supplies ........................................................ 137 
4.9.4  Data sources for recording electricity and gas ................................................ 138 
4.10  Military goods ........................................................................................................... 140 
5  Particular trade flows ......................................................................................................... 142 
5.1  Goods in transit........................................................................................................ 142 
5.1.1  Intra-EU trade statistics — Goods in simple circulation .................................. 142 
5.1.2  Extra-EU trade statistics .................................................................................. 143 
5.2  Triangular trade ........................................................................................................ 143 
5.2.1  Triangular trade within the context of VIES ..................................................... 145 
5.3  Quasi-transit ............................................................................................................. 146 
6  Thresholds within the Intrastat system ........................................................................... 151 
6.1  Exemption threshold ............................................................................................... 151 
6.1.1  How to calculate the exemption threshold ....................................................... 152 

Compilers guide on European statistics on international trade in goods 

4 

 
 
 
 
Contents 

6.2  Simplification threshold .......................................................................................... 153 
Individual transaction threshold ............................................................................ 153 
6.3 
7  Thresholds applicable in extra-EU trade ......................................................................... 155 
7.1  Statistical threshold applied by NSA ..................................................................... 155 
7.2  Thresholds applied by Customs ............................................................................ 156 
8  Quality ................................................................................................................................. 157 
8.1  Asymmetries............................................................................................................. 157 
9  Confidentiality .................................................................................................................... 159 
9.1  The principle of passive confidentiality ................................................................ 159 
9.2  Application of passive confidentiality in practice ................................................ 160 
9.3  Transmission of confidential data to Eurostat ..................................................... 161 
10 Data transmission .............................................................................................................. 162 
10.1  Doc MET 400 ............................................................................................................. 162 
10.2  Aggregated data ....................................................................................................... 162 
10.3  Detailed data ............................................................................................................. 163 
10.3.1 Transmission of revised data ........................................................................... 164 
10.4  Trade by business characteristics ......................................................................... 166 
10.5  Trade broken down by invoicing currency ........................................................... 166 
Glossary ................................................................................................................................... 167 

ANNEX 1  —  Summary  of 
encouragements ...................................................................................................................... 175 
ANNEX 2 — Contact details of the competent national authorities ................................... 188 

legal  requirements,  recommendations  and 

the 

A. 
B. 
C. 
D. 
E. 
F. 
G. 
H. 

ANNEX 3  —  Allocation  of  customs  procedure  to  type  of  trade  and  statistical 
procedure ................................................................................................................................. 192 
General remarks ....................................................................................................... 192 
Instructions for the use of this annex .................................................................... 192 
SAD Box 37 — 1st subdivision ................................................................................ 192 
SAD Box 1 — 1st subdivision ................................................................................. 193 
SAD box 37 — 2nd subdivision ............................................................................... 193 
Legend to the tables ................................................................................................ 194 
Allocation table for Imports/Arrivals ...................................................................... 195 
Allocation table for Exports/Dispatches ................................................................ 202 
ANNEX 4 — Reconciliation table between ITGS and BoP statistics .................................. 205 
INDEX ........................................................................................................................................ 218 

Compilers guide on European statistics on international trade in goods 

5 

 
 
 
 
 
Table of figures 

Table of figures 
Figure 1: Goods dispatched from home country to embassy .................................................... 29 
Figure 2: Goods imported from home country to embassy ........................................................ 29 
Figure 3: Goods obtained by an embassy ................................................................................. 30 
Figure 4: Goods exported to an international organisation ........................................................ 30 
Figure 5: Goods obtained from an international organisation .................................................... 30 
Figure 6: Decision tree on software............................................................................................ 31 
Figure 7: Treatment of repairs .................................................................................................... 33 
Figure 8: Goods with negligible value sent for processing ......................................................... 36 
Figure 9: Distance sale ............................................................................................................... 38 
Figure 10: Import under SASP ................................................................................................... 66 
Figure 11: Export under SASP ................................................................................................... 66 
Figure 12: Scheme of type of traders with EORI registration ..................................................... 69 
Figure 13: Calculation of statistical value for one item with delivery term EXW ........................ 81 
Figure 14: Calculation of  statistical value for two items with delivery term CIF ........................ 82 
Figure 15: Calculation of statistical value for two items with delivery term DDU ....................... 83 
Figure 16: Standard case of processing under contract ............................................................ 98 
Figure 17: Processing with subsequent sale to another Member State ..................................... 98 
Figure 18: Processing with subsequent sale in Member State of processing ........................... 99 
Figure 19: Return of unprocessed goods ................................................................................... 99 
Figure 20: Processing with subsequent sale within the initial Member State of export ........... 100 
Figure 21: Processing under contract with several suppliers ................................................... 101 
Figure 22: Processing under contract with subsequent sub-contracting ................................. 102 
Figure 23: Processing under contract in several countries arranged by ordering party .......... 102 
Figure 24: Multi-country processing ......................................................................................... 103 
Figure 25: Non-resident transaction ......................................................................................... 105 
Figure 26: Trade in vessels/aircraft — only legal ownership transferred ................................. 115 
Figure 27: Trade in vessels/aircraft — legal and economic ownership transferred to two 
different entities ......................................................................................................................... 115 
Figure 28: Decision tree for vessels ......................................................................................... 117 
Figure 29: Decision tree for aircraft .......................................................................................... 117 
Figure 30: Trade in vessels/aircraft — interlinked transaction ................................................. 119 
Figure 31: Trade in vessels/aircraft — economic ownership transferred within the MS .......... 120 
Figure 32: Trade in vessels/aircraft — economic ownership transferred to another MS ......... 120 
Figure 33: Recording of arrivals/imports relating to offshore installations ............................... 130 
Figure 34: Recording of dispatches/exports related to offshore installations .......................... 131 
Figure 35: Simple circulation between Member States ............................................................ 142 
Figure 36: Triangular trade — standard case .......................................................................... 143 
Figure 37: Triangular trade with 1st purchaser and customer from the same MS ................... 144 
Figure 38: Triangular trade with supplier and 1st purchaser in the same Member State ......... 144 
Figure 39: Triangular trade with supplier and customer in the same Member State ............... 144 
Figure 40: Triangular trade with 1st purchaser in a non-member country ................................ 145 
Figure 41: Triangular trade with customer in a non-member country ...................................... 145 
Figure 42: Triangular trade with supplier in a non-member country ........................................ 145 
Figure 43: Triangular trade within the context of VAT recapitulative statements (VIES) ......... 146 
Figure 44: Quasi-import ............................................................................................................ 147 
Figure 45: Quasi-export ............................................................................................................ 148 
Figure 46: Example of a quasi-import transaction .................................................................... 150 
Figure 47: Coverage levels for Member States with simplification thresholds ......................... 151

Compilers guide on European statistics on international trade in goods 

6 

 
 
 
 
List of tables 

List of Tables 
Table 1: Summary of the new legal requirements, recommendations, encouragements 
and compilation rules .................................................................................................................. 10 
Table 2: Institutional arrangements in Member States ............................................................... 19 
Table 3: VAT, customs and statistical territories of Member States ........................................... 45 
Table 4: Currency codes for Trade by Invoicing Currency ......................................................... 88 
Table 5: Product codes based on SITC for Trade by Invoicing Currency .................................. 89 
Table 6: Conceptual overview of the relation between statistical and customs procedures ...... 93 
Table 7: Nature of transactions codes ........................................................................................ 95 
Table 8: Preference codes ........................................................................................................ 106 
Table 9: Mode of transport codes ............................................................................................. 107 
Table 10: Delivery terms codes ................................................................................................ 111 
Table 11: Scenarios of the reporting deliveries to vessels and aircraft .................................... 126 
Table 12: Data sources for trade in electricity and gas ............................................................ 140 
Table 13: Sections of Doc MET 400 ......................................................................................... 163 
Table 14: Determination of revision levels ................................................................................ 165 

Compilers guide on European statistics on international trade in goods 

7 

 
 
 
 
 
Acronyms and abbreviations 

Acronyms and abbreviations 

BoP 
BPM6 

CCC 
CN 
CPC 
D.E. 
DG TAXUD 
EEZ 
EORI 
ESA 
GSP 
IMTS 
ITGS 
MCC 
MS 
NA 
NoT 
NSA 
NSI 
PSI 
SAD 
SASP 
SITC 
TARIC 
TSO 
UCC 
UN 
VAT 
VIES 

Balance of Payments 
Balance of Payments and International Investment Position Manual, Sixth 
Edition 
Community Customs Code 
Combined Nomenclature 
Customs Procedure Code 
Data Element 
Directorate General for Taxation and Customs Union 
Exclusive Economic Zone 
Economic Operators Registration and Identification 
European System of Accounts 
Generalised System of Preferences 
International Merchandise Trade Statistics 
International Trade in Goods Statistics 
Modernised Customs Code 
Member State 
National Accounts 
Nature of Transaction 
National Statistical Authority 
National Statistical Institute 
Provider of Statistical Information 
Single Administrative Document 
Single Authorisation for Simplified Procedure 
Standard International Trade Classification 
Tarif Intégré Communautaire 
Transmission System Operator 
Union Customs Code 
United Nations 
Value Added Tax 
VAT Information Exchange System 

Compilers guide on European statistics on international trade in goods 

8 

 
 
 
 
 
Preface 

Preface 
European statistics on international trade in goods (ITGS) published by Eurostat measure  the value and 
quantity of goods traded between EU Member States (intra-EU trade) and goods traded by EU Member 
States  with  non-EU  countries  (extra-EU  trade).  The  term  ‘goods’  in  this  context  means  all  movable 
property including electricity. The term ‘European’ means that the statistics are compiled on the basis of 
the concepts and definitions set out in EU legislation. 
European  ITGS  are  the  official  harmonised  source  of  information  about  exports,  imports  and  the  trade 
balances of the EU, its Member States and the euro area. They serve the needs of many different users, 
including  governments,  businesses,  academic  and  EU  researchers  and  the  general  public.  The  growing 
interest  in  timely  and  high-quality  trade  in  goods  statistics  has  made  the  harmonisation  of  compilation 
practices among EU Member States a primary necessity.  
The  purpose  of  this  Compilers  Guide  is  to  provide  the  producers  of  European  ITGS  both  with 
clarifications  on  how  to  correctly  apply  the  EU  legal  provisions  and  with  recommendations  on  how  to 
further improve the compilation practices and their harmonisation where the legislation has left room for 
subsidiarity. 
Based  on  concrete  examples,  clear  text  and  definitions  and  systematic  legislative  references,  the 
Compilers  Guide  is  meant  to  serve  as  a  practical  reference  document  for  all  National  Statistical 
Authorities  involved  in  the  compilation  of  European  ITGS.    It  is  in  no  way  intended  to  replace  or 
complement any national instructions regulating the provision of statistical information by the economic 
operators involved in intra- and extra-EU trade in goods. 
This Guide was produced by Unit G5: Goods – Production and International Trade, in close cooperation 
with  the  EU  Member  States;  it  should  be  seen  as  a  living  document,  reflecting  the  latest  EU  legal 
provisions in force and the progress achieved in the enhancement of the harmonisation of Member States' 
compilation practices.  
Given  the  cross-cutting  nature  of  the  ITGS  collection  and  legislation  and  the  importance  of  quality 
monitoring of the European statistics, consideration is given to complementing this Guide at a later stage 
with a section dedicated to methods and practices for ensuring data quality.  

Sophie Limpach 
Head of Unit G5 – Goods - Production and International Trade 
Eurostat 

October 2015 

Compilers guide on European statistics on international trade in goods 

9 

 
 
 
 
 
 
 
 
 
Introduction  1 

1  Introduction 
1. 
International  Trade  in  Goods  Statistics  (ITGS)  are  a  part  of  the  official  European  Union  (EU) 
statistics which provide data on movement of goods between countries. Trade statistics serve the needs of 
different users, including governments, businesses, academic and EU researchers and the general public. 
The  interest  in  ITGS  is  increasing,  therefore  production  of  timely  and  high  quality  data  is  of  primary 
importance for the producers of statistics. 
2.  The Compilers Guide on European statistics on international trade in goods (further referred to as 
the Compilers Guide) provides clarifications and recommendations on how to apply the provisions laid 
down  on  statistics  relating  to  Member  States’  trade  in  goods  with  other  Member  States  and  with  non-
member countries. The ITGS legislation has been closely aligned to the International Merchandise Trade 
Statistics  (IMTS)    concepts  and  definitions  adopted  in  2010  by  the  United  Nations  (UN)  Statistical 
Commission.  
3.  The  Compilers  Guide  should  serve  the  needs  of  national  statistical  authorities  (NSAs)  responsible 
for  the  production  of  ITGS.  The  relevant  legislation  is  explained  in  a  systematic  and  comprehensive 
approach  which  should  facilitate  the  application  of  the  legal  provisions  and  ensure  harmonisation  of 
compilation  practices  among  Member  States.  The  Compilers  Guide  is  not  intended  to  replace  or 
complement  any  national  provisions  or  instructions  on  ITGS  data  collection  designated  for  economic 
operators involved in intra-EU and extra-EU trade in goods. 
4.  Within  the  meaning  of  the  Compilers  Guide  the  terms  ‘required’,  ‘recommended’  and 
‘encouraged’  are  consistently  used.  The  term  ‘required’  refers  to  a  legal  requirement  set  by  the  EU 
legislation which Member States have to comply with. The legal requirements are in force and applicable 
as  set  in  the  relevant  regulations.  The  term  ‘recommended’  refers  to  a  standard  which  Member  States 
should  follow  to  ensure  the  harmonisation  and  the  good  quality  of  ITGS.  The  term  ‘encouraged’ 
indicates  a  desirable  practice  that  is  not  part  of  the  standard.  The  term  ‘recommended’  refers  to  a 
recommendation endorsed by the ITGS Steering Group. Both, legal requirements and recommendations 
are  assessed  as  part  of  the  annual  quality  assessment  procedure.  Only  the  legal  requirements  are  the 
subject  of  compliance  monitoring.  A  complete  summary  of  the  requirements,  recommendations  and 
encouragements is set out in  Annex 1 while the list of newly endorsed requirements, recommendations 
and encouragements is provided in Table 1.  
5.  Moreover  the  Compilers  Guide  contains  compilation  rules.  Compilation  rules  explain  how  a 
transaction/case  or  some  of  its  aspects  shall/should  be  treated  (e.g.  which  code  shall/should  be  used). 
Those  ones  which  are  binding  are  formulated  using  ‘shall’,  while  the  other  ones  are  formulated  using 
‘should’.  As  the  compilation  of  ITGS  should  be  harmonised  across  Member  States,  the  binding/non-
binding status of compilation rules is confirmed by the  ITGS Steering Group. All compilation rules are 
enumerated in Annex 1 while Table 1 contains only newly endorsed compilation rules.  

Table 1: Summary of the new legal requirements, recommendations, encouragements 
and compilation rules 

Wording of requirements, recommendations and 
encouragements 

No of § in the 
Guide 

References to 
the legislation 
and other 
documents 

Applied 
from 
year 

2. THE FRAMEWORK 

REQUIREMENTS 
L26.  National  Customs  are  required  to  provide  NSAs  with  any 
available  information  to  identify  the  person  who  carries  out 
dispatches and arrivals of goods under inward processing or 
processing under customs control. 

L27.  NSAs are required to create the conditions enabling PSIs to 
use  automatic  data  processing  and  electronic  data 
transmission systems. 

L28.  NSAs  are  required  to  establish  the  penalty  system  under 
which  any  PSI  not  fulfilling  his/her  obligations  to  provide 
Intrastat information is liable to the penalties. 

188 

279 

220 

Reg. No 638/2004, 
Art. 5(2a) 

2015 

Reg. No 638/2004, 
Art. 5(4) 

Reg. No 638/2004, 
Art. 7(3) 

2005 

2005 

Compilers guide on European statistics on international trade in goods 

10 

 
 
 
Introduction  1 

References to 
the legislation 
and other 
documents 

Reg. No 638/2004, 
Art. 8(3) 

Reg. No 638/2004, 
Art. 8(1) 

Reg. No 471/2009, 
Art. 7(1) 

Applied 
from 
year 

2005 

2005 

2010 

2015 

2016 

2016 

2016 

233 

245 

287 

282 

258 

259 

260 

261 

2016 

Wording of requirements, recommendations and 
encouragements 

No of § in the 
Guide 

L29.  The  tax  administration  in  a  Member  State  is  required  to 
inform  VAT  registered  operators  on  their  possible  obligation 
to provide Intrastat information. 

L30.  NSAs  are  required  to  set  up  and  manage  Intrastat  register 

of intra-Community operators. 

L31.  National  Customs  are  required  to  provide  NSAs  customs 
declarations  lodged  with  them  at  the  latest  the  month 
following the month of acceptance. 

RECOMMENDATIONS 

R23.  It  is  recommended  that  NSAs  revise  data,  which  are 
considered  final,  where  the  revision  is  significant  for  the 
interpretation of the data. 

R29.  It  is  recommended  that  NSAs  estimate  the  total  trade 
below  the  exemption  threshold  by  using  the  most  reliable 
data  sources  —  current  month’s  or  historical  administrative 
data  (VIES  or  VAT)  —  available  at  the  time  the  estimation 
process should be launched. 

R30. It  is  recommended  that  NSAs  estimate  the  total  trade  of 
PSIs  late  in  submitting  their  Intrastat  declarations  by  using 
the  most  reliable  data  sources  —  current  month’s  or 
historical administrative data (VAT or VIES), current month’s 
or  historical  Intrastat  data  —  available  at  the  time  the 
estimation process should be launched. 

R31. It  is  recommended  that  NSAs  allocate  the  estimated  total 
trade below the exemption threshold by product and partner 
Member State by using data collected from the most similar 
traders above the exemption threshold. ‘Most similar traders’ 
should  be  understood  as  traders  with  a  most  similar  activity 
or/and  of  most  similar  size.  ‘Traders  with  a  most  similar 
activity’ means ‘traders with the same NACE activity code or 
with a NACE activity code as similar as possible’. ‘Traders of 
most  similar  size’  means  ‘just-above-threshold  traders’.  As 
regards 
the  allocation  by  partner  Member  State,  an 
alternative  to  the  use  of  most  similar  traders’  data  would 
consist in applying the pattern captured from VIES data. 
R32. As  regards  the  PSIs  late  in  submitting  their  Intrastat 
declarations,  it  is  recommended  that  NSAs  allocate  the 
estimated  total  trade  by  product  and  partner  Member  State 
by  using  their  historical  Intrastat  data  or,  if  not  available  or 
not relevant, by  using Intrastat data collected from the most 
similar  traders.  ‘Most  similar  traders’  should  be  understood 
as traders  with a most similar activity or/and of most similar 
size. ‘Traders with a most similar activity’ means ‘traders with 
the  same  NACE  activity  code  or  with  a  NACE  activity  code 
as similar as possible’. ‘Traders  of most similar size’ means 
‘traders with most similar trade value or turnover’. As regards 
the allocation by partner Member State, an alternative to the 
use of the PSI’s historical Intrastat data or of similar traders’ 
data  would  consist  in  applying  the  pattern  captured  from 
VIES data. 

R33. It is recommended that, to the extent possible, NSAs avoid 
estimating  the  main  PSIs’  trade  by  taking  any  necessary 
measures to get their Intrastat declarations in due time. 

257 

ENCOURAGEMENTS 

E1.  Member  States  are  encouraged 

the 
cooperation  of  national  statistical  authorities  with  tax  and 
customs administrations through establishing working groups 
and  other 
for  discussions  and  exchange  of 
information. 

formalise 

forums 

to 

E42.  NSAs  are  encouraged 

tax 
administrations  how  distance  sales  are  recorded  on  the 

to  analyse  with 

their 

39, 40, 41, 124, 
137, 254 

137 

2016 

2014 

2015 

Compilers guide on European statistics on international trade in goods 

11 

 
 
 
 
 
 
 
 
 
 
 
Introduction  1 

Wording of requirements, recommendations and 
encouragements 

No of § in the 
Guide 

References to 
the legislation 
and other 
documents 

Applied 
from 
year 

national  VAT  return  and  to  find  solutions  to  ensure  full 
coverage of this type of trade. 

E43.  NSAs  are  encouraged  to  define  rules  how  PSIs  should 

submit corrective Intrastat declaration. 

E50.  NSAs are encouraged to regularly assess the quality of the 
administrative  data  —  VAT  and  VIES  data  —  in  terms  of 
accuracy, timeliness and, where possible, comparability with 
Intrastat data — in the view of:  
a) 

identifying  the  most  appropriate  estimation  methods  for 
trade below threshold and non/late response; 

b)  measuring how far VIES data can be used to allocate the 
estimates  for  missing  intra-EU  trade  by  partner  Member 
State; 

c)  measuring  how  far  the  administrative  data  can  be  used 

to control the quality of Intrastat data. 

E51.  NSAs  are  encouraged  to  monitor  the  accuracy  of  the 
non/late  response  estimates  at  product  and  partner  level  by 
comparison  with  real  data  when  Intrastat  declarations  are 
submitted.  They  should  improve  their  estimation  method  in 
the case this monitoring reveals quality issues. 

3. THE DATA 

L32.  The  competent  national  authorities  are  required 

REQUIREMENTS 
to 
provide  access  to  data  in  EORI  database  at  the  request  of 
NSA. 

ENCOURAGEMENTS 

E56.  Where  NSAs  collect  the  statistical  value  and  other  optional 
information within Intrastat they are encouraged to collect it 
only  from  the  most  important  traders  by  defining  thresholds 
only above which PSIs are obliged to provide this additional 
information [former E13 and E33]. 

283 

250 

2015 

2016 

262 

2016 

307 

Reg. No 113/2010, 
Art. 15(4) 

2010 

411, 750 

2016 

4. SPECIFIC GOODS OR MOVEMENTS 

REQUIREMENTS 
L33.  NSAs  are  required  to  record  only  the  physical  flows  of 

electricity and gas in intra-EU and extra-EU trade statistics. 

668 

RECOMMENDATIONS 

R24.  It  is  recommended  that  NSAs  establish  methodologies  for 
the estimations of transit trade of gas where the collection of 
data is not possible. 

R25. It  is  recommended  that  NSAs  compare  ITGS  quantitative 
data  with  the  data  of  the  energy  statistics,  grid  operators  or 
any  other  available  quantitative  data  in  order  to  verify 
whether further reconciliation is needed and to identify exact 
reasons of discrepancies. 

R34. It  is  recommended  that  NSAs  acquaint  themselves  with 
information  on  how  their  national  legislation  defines  the 
accounting  standards,  in  particular  those  related  to  leasing 
arrangements,  as  they  can  be  very  helpful  in  determining  a 
change in economic ownership [former E20]. 

R35. It  is  recommended  that  NSAs  use  Intrastat  system  for 
collection of data on intra-EU supplies to vessels and aircraft 
only in case the Customs is not providing with the necessary 

701 

705 

555 

615 

Reg. No 638/2004, 
Art. 3 
Reg. No 1982/2004, 
Art. 23(1) 
Reg. No 471/2009, 
Art. 3 
Reg. No 113/2010, 
Art. 24(1) 

2005 

2006 

2016 

2015 

2015 

2016 

Compilers guide on European statistics on international trade in goods 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Introduction  1 

Wording of requirements, recommendations and 
encouragements 

No of § in the 
Guide 

data. 

ENCOURAGEMENTS 

References to 
the legislation 
and other 
documents 

Applied 
from 
year 

637 

674 

695 

701 

701 

704 

535 

608 

616 

623 

633 

647 

E44.  NSAs are encouraged to analyse the recording practices in 
from  offshore 
Customs  of 
installations  in  order  to  ensure  complete  coverage  of  trade 
statistics and to avoid double counting. 

the  goods  moving 

to  and 

E45.  NSAs are encouraged to develop the necessary knowledge 
about  functioning  of  electricity  and  gas  markets  at  the 
national  and  the  EU  levels  in  order  to  be  able  to  correctly 
develop  methodologies  for  the  collection  of  the  statistical 
data. 

E46.  NSAs  are  encouraged  to  analyse  with  tax  administrations 
the  national  provisions  concerning  recording  of  gas  and 
electricity  transactions  on  VAT  returns  and  to  evaluate  its 
possible reuse for ITGS purposes. 

E47.  NSAs are encouraged to use for the estimation of statistical 
value  of  electricity  and  gas  long-term  contract  prices  and 
other available information which correctly reflects the value 
of electricity and gas on the particular market. 

E48.  NSAs  are  encouraged  to  consult  transmission  system 
operators,  who  could  estimate  the  share  of  transit  trade  in 
the total flows of electricity and gas.  

E49.  NSAs  are  encouraged  to  identify  alternative  data  sources 
for  quality  checks  and  compilation  of  ITGS  in  gas  and 
electricity regarding physical flows, prices or values. 

E52.  NSAs  are  encouraged 

the  application  of 
simplified  reporting  for  industrial  plant  in  the  way  which 
minimises  the  asymmetries  in  the  trade  in  goods  with  other 
Member States. 

to  manage 

E53.  NSAs are encouraged to analyse national VAT  regulations 
in order to clear define the scope of goods which can benefit 
from  simplifications  of  reporting  deliveries  for  vessels  and 
aircraft. 

E54.  NSAs  are  encouraged  to  establish  a  control  system  which 
would  eliminate  the  risk  of  double  counting  of  data  on 
deliveries for vessels and aircraft .from two sources (customs 
and Intrastat declarations). 

E55.  NSAs are encouraged to analyse the recording practices in 
Customs  of  supplies  to  vessels  and  aircraft  in  order  to 
identify  whether  simplifications  applied  are  not 
in 
contradiction with statistical requirements. 

COMPILATION RULES 

C54. Since  the  coastal  states  have  the  right  to  authorize  and 
regulate  drilling  on  the  their  continental  shelf  where  these 
rights  are  allocated  to  a  Member  State,  for  statistical 
recording the statistical territory of that Member State should 
be extended to the continental shelf. 

C55. The  reporting  Member  State  and  partner  country  Member 
States  for  the  investment  goods  for  the  construction  or 
technical  improvement  of  the  offshore  installation  or  goods 
acquired  or  produced  by  the  offshore  installation  should  be 
determined  according  to  rules  valid  for  goods  delivered  to 
offshore installation. 

C56. The  substance  of  the  transaction,  not  a  title  of  the  contract, 
shall be considered in order to identify the economic owner 
of the vessels and aircraft. [former R7] 

C57. When the list of indicative criteria as referred to in paragraph 
551  is  used  to  decide  on  the  economic  owner  of  a 
vessel/aircraft as many criteria as possible, depending on the 
availability of information, shall be evaluated [former R8]. 

548, 593, 595 

552 

2015 

2015 

2015 

2016 

2015 

2015 

2016 

2016 

2016 

2016 

2015 

2015 

2015 

2015 

Compilers guide on European statistics on international trade in goods 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Introduction  1 

References to 
the legislation 
and other 
documents 

Applied 
from 
year 

2015 

Wording of requirements, recommendations and 
encouragements 

No of § in the 
Guide 

C58.  When  the  business  accounts  are  used  to  decide  on  the 
economic  owner  and  national  acts  define  the  accounting 
standards, 
leasing 
arrangements,  in  line  with  the  substance  of  IAS17  then  the 
intention of an entity to include/exclude vessel/aircraft as an 
asset in/from its balance sheet  shall indicate that there is a 
transfer of economic ownership. 

in  particular 

related 

those 

to 

554 

5. PARTICULAR TRADE FLOWS 

REQUIREMENTS 
L34.  NSAs  are  required  to  ensure  that  any  goods  in  transit  are 

not recorded in ITGS. 

711 

Reg. No 638/2004, 
Art. 3  
Reg. No 471/2009, 
Art. 3 

2005 

2006 

6. THRESHOLDS WITHIN INTRASTAT SYSTEM 

REQUIREMENTS 
L35.  Member  States  are  required  to  determine  the  exemption 
threshold each year in annual values in such way that that at 
least 97% of the total dispatches and at least 93% of the total 
arrivals,  expressed  in  value,  of  the  relevant  Member  State’s 
taxable persons is provided. 

L36.  Member  States  are  required  when  applying  simplification 
threshold to determine it in such  a way that a maximum 6% 
of  the  total  dispatches  and  arrivals  is  affected  by  the 
simplification. 

752 

Reg. No 638/2004, 
Art. 10 

2005 

764, 752 

Reg. No 1982/2004, 
Art. 13(3a) 

2005 

L37.  NSAs  are 

required 
questionnaire annually. 

8. QUALITY 

REQUIREMENTS 
to  provide  completed  quality 

791 

9. CONFIDENTIALITY 

REQUIREMENTS 
L38.  NSAs  are  required  to  transmit  to  Eurostat  data  which  are 

confidential. 

L39.  NSAs  are  required  to  apply  active  confidentiality  when 
compiling  and  transmitting  intra-EU  and  extra-EU  trade 
statistics by business characteristics. 

L40.  NSAs  are  required  to  apply  passive  confidentiality  when 
compiling  and  transmitting  monthly  intra-EU  and  extra-EU 
trade statistics. 

810 

797 

798 

Reg. No 638/2004, 
Art. 13(2) 
Reg. No 1982/2004, 
Art. 26(3) 
Reg. No 471/2009, 
Art. 9(2) 
Reg. No 92/2010, 
Art. 3(3) 

Reg. No 638/2004, 
Art. 12(1) 

Reg. No 1982/2004, 
Art. 13a(8) 
Reg. No 113/2010, 
Art. 15(9) 

Reg. No 638/2004, 
Art. 11 
Reg. No 471/2009, 
Art. 10, second 
subparagraph 

2005 

2010 

2005 

2010 

2005 

2010 

Compilers guide on European statistics on international trade in goods 

14 

 
 
 
 
 
 
 
 
 
 
 
Introduction  1 

L41.  NSAs  are  required  to  supressed  confidential  data  in  such 
way  that  they  may  be  published  at  least  at  chapter  level  of 
the CN provided confidentiality is thereby ensured. 

805 

Reg. No 1982/2004, 
Art. 25(7) 
Reg. No 92/2010, 
Art. 2(5) 

2005 

2010 

10. DATA TRANSMISSION 

REQUIREMENTS 
L42.  NSAs  are  required  to  inform  the  public  about  the  major 

revision when they have occurred. 

L43.  NSAs  are  required  to  transmit  estimates  of  extra-EU  trade 
from  delayed  or  incomplete  customs  declaration  at  least  at 
chapter level and by partner country. 

RECOMMENDATIONS 

R26. It is recommended that NSAs send a pre-announcement to 
Eurostat  of  revisions  of  a  certain  size  between 
two 
subsequent  data  transmissions  if  possible  up  to  1  month 
before  the  data  delivery,  otherwise  up  to  1  week  before  the 
data delivery itself or at the latest on the day the data is sent. 
R27. When  estimates  for  missing  intra-EU  trade  are  compiled  at 
CN8  level,  it  is  recommended  that  NSAs  estimate  and 
transmit to Eurostat not only the statistical value but as well 
the  net  mass  and  the  supplementary  quantity  wherever 
relevant. 

R28. It is recommended that NSAs compile distinct estimates for 
trade  below  threshold  and  estimates  for  non/late  response 
and  keep  this  distinction  in  the  data  transmissions  to 
Eurostat by using the threshold indicators 3 (trade below the 
exemption  threshold)  and  4  (non/late-response)  instead  of 
indicator 8 (no distinction between trade below threshold and 
non/late response). 

842 

826 

Commission 
Recommendation 
COM(2005)217 

Reg. No 92/2010, 
Art. 2(3) 

833, 835 

827 

826 

2012 

2010 

2013 

2016 

2016 

1.1  History of International Trade in Goods Statistics 
6.  Traditionally ITGS are based on the data collected by customs administrations on trade transactions 
between countries. Customs declarations are used for statistical purposes as the basic data source which 
provides detailed information on exports and imports of goods with a geographical breakdown. Therefore 
the developments and changes in customs systems have direct implications on statistical data compilation. 
The  harmonisation  of  customs  procedures  in  the  EU,  the  introduction  of  the  Combined  Nomenclature 
(CN)  in  1988 and  the  Single  Administrative  Document  (SAD)   have  had  a  very positive  impact  on  the 
development of trade statistics as well. 
7.  The first EU legislation related to ITGS was adopted in 1975(1); it provided general guidelines on 
data collection and imposed the obligation on Member States to transmit their data to Eurostat. 
8.  The advent of the Single Market on 1 January 1993, with its removal of customs formalities between 
Member States and subsequent loss of trade statistics data sources, required the establishment of a new 
data collection system: Intrastat was introduced by Council Regulation (EEC) No 3330/91 of 7 November 
1991  on  the  statistics  relating  to  the  trading  of  goods  between  Member  States  and  has  been  applicable 
since  1993.  Since  then  ITGS  are  based  on  two  data  compilation  systems:  intra-EU  trade  and  extra-EU 
trade  statistics.  Extra-EU  trade  data,  which  relate  to  trading  of  goods  with  non-member  countries, 
continue to be collected by customs administrations and are based on the records of trade transactions in 
customs declarations, whereas the most of intra-EU trade data is directly collected from traders once per 
month within the Intrastat system. 
9.  The Intrastat system had to ensure the collection of trade information in order to satisfy user needs 
in  measuring  progress  in  integrating  Europe's  economies,  helping  European  businesses  conduct  market 

(1)  Regulation (EEC) No 1736/75 of the Council of 24 June1975 on the external trade statistics of the Community and statistics of trade between 

Member States. 

Compilers guide on European statistics on international trade in goods 

15 

 
 
 
 
 
 
 
                                                           
Introduction  1 

analyses and providing information for Balance of Payments statistics, National Accounts and short-term 
economic studies. 
10.  The Intrastat system can be characterised as follows: a) data are directly collected from traders b) it 
is closely interlinked with the VAT system relating to intra-EU trade in order to ensure completeness and 
quality of the statistical data and c) a threshold system is established to simplify data provision and reduce 
overall burden on traders. 
11.  Although the introduction of the Intrastat system was already considered as a huge simplification for 
traders (small and medium size traders were released from reporting, there were far fewer data elements 
to be provided in comparison with customs declarations and only once per month, not per transaction as 
required by Customs before), it was chosen in 1996 as a pilot project for the SLIM (Simpler Legislation 
for the Internal Market) initiative launched by internal market ministers. The aim of this initiative was to 
further simplify Intrastat reporting. 
12.  The studies have shown that the interests of data providers (who want formalities to be simplified) 
are not easy to reconcile with the data users (who generally want readily available detailed information). 
Nevertheless,  the  Commission  and  Member  States  managed  to  reach  a  consensus  on  simplifying  the 
Intrastat data collection system in two ways: the number of statistical variables and the amount of product 
nomenclature codes were reduced. Council Regulation (EEC) No 3330/91 was amended by the following 
measures: Regulation (EC) No 1182/1999 of the European Parliament and of the Council and Regulation 
(EC) No 1624/2000 of the European Parliament and of the Council. 
13.  The  legislation  on  intra-EU  trade  statistics  (Regulation  (EC)  No 638/2004  of  the  European 
Parliament  and  of  the  Council)  applicable  since  1  January  2005  and  amended  by  Regulation  (EC) 
No 222/2009  of  the  European  Parliament  and  of  the  Council,  continues  the  effort  of  improving  and 
adapting  the  statistical  system  in  order  to  take  better  into  account  both  users'  needs  and  the  burden  on 
information  providers.  Moreover  the  threshold  system  was  adapted  with  a  view  to  exempting  a  larger 
number of businesses, the number of nomenclature headings was reduced and several simplified reporting 
measures were introduced. 
14.  Despite the simplifications already achieved, further, substantial simplification initiatives are to be 
continued.  The  strategy  of  the  EU  on  growth  and  jobs  (Europe  2020)(1)  aims,  among  other  things,  to 
reduce  the  administrative  burden  on  businesses  caused  by  the  requirements  of  public  administrations. 
While the statistical burden accounts for a relatively small part of the total administrative burden in the 
Member  States,  the  reporting  burden  based  on  Intrastat,  forms  a  significant  proportion  of  all  statistical 
reporting obligations. 
15.  In  the  future,  the  Intrastat  system  should  focus  on  further  easing  of  the  reporting  burden  without 
affecting  the timeliness and quality of the data, as the Council concluded(2) in November 2011 that the 
reduction of the burden achieved so far had not been sufficient.  
16.  The  SIMSTAT  proposal  (Single  Market  Statistics)  is  the  Commission's  answer  to  the  Council's 
request  to  redevelop  the  Intrastat  system  in  a  way  which  ensures  a  reduction  of  the  burden  put  on  the 
operators, while maintaining a sound level of quality. The proposal is based on two pillars: 1) to maintain 
the  collection  of  dispatches  —  with  some  changes  —  but  allow  each  Member  State  to  decide  how  to 
implement  the  compilation  of  arrivals  and  2)  to  exchange  micro-data  on  dispatches  among  Member 
States.  
17.  Moreover ITGS will be confronted with another challenge: globalisation, which is one of the most 
important  economic  phenomena.  Globalisation  affects  ITGS  on  both  sides  of  the  production  process: 
input and output.  On the one hand current data collection systems are facing  problems such as transfer 
pricing  etc.  On  the  other  hand  users  require  more  information  on  the  activities  of  multinational 
enterprises, in particular analysing global value chains, their intra-firm trade. 

(1)   http://ec.europa.eu/europe2020/index_en.htm 
(2)   http://www.consilium.europa.eu/ueDocs/cms_Data/docs/pressData/en/ecofin/126455.pdf 

Compilers guide on European statistics on international trade in goods 

16 

 
 
 
                                                           
The framework  2 

2  The framework 

2.1  Legal basis 

Intra-EU trade 
Basic regulation 

Regulation (EC) No 638/2004 of the European Parliament and of the Council 

amended by  Regulation (EC) No 222/2009 of the European Parliament and of the Council 

Commission Regulation (EU) No 1093/2013 

Regulation (EC) No 659/2014 of the European Parliament and of the Council 

Implementing provisions 

Commission Regulation (EC) No 1982/2004 

amended by  Commission Regulation (EC) No 1915/2005 

Commission Regulation (EU) No 91/2010 

Commission Regulation (EU) No 96/2010 

Commission Regulation (EU) No 1093/2013 

Extra-EU trade 
Basic regulation 

Regulation (EC) No 471/2009 of the European Parliament and of the Council 

Implementing provisions 

Commission Regulation (EU) No 113/2010 
Commission Regulation (EU) No 92/2010 

18.  ITGS  is  based  on  EU  legislation  in  order  to  ensure  a  harmonised  approach  for  the  production  of 
statistics by all Member States. The European Union legislation known as the ‘Acquis Communautaire’ 
comprises primary legislation and secondary legislation. The primary legislation consists of the Treaties 
— two basic are: Treaty on European Union and Treaty on functioning of the European Union, and other 
agreements  possessing  similar  status.  The  treaties  are  amended  to  make  the  EU  more  efficient  and 
transparent, to prepare for accession of new member countries or to introduce new areas of cooperation 
(e.g.  Treaty  of  Amsterdam,  Nice,  Lisbon  etc.).  The  secondary  legislation  consists  of  regulations, 
directives, decisions, recommendations and opinions based upon the Treaties. Article 338 of the Treaty on 
the Functioning of the European Union provides the legal  basis for  the production of EU  statistics. The 
legislation concerning statistics falls under the ordinary procedure which means that the Council and the 
European Parliament jointly adopt the legal acts in this area. The Article also specifies the principles of 
EU  statistics:  impartiality,  reliability,  objectivity,  scientific  independence,  cost-effectiveness  and 
statistical confidentiality. 
19.  Secondary legislation relating to ITGS is laid down in the regulations. The regulations are directly 
applicable in  Member  States.  Member  States  do not need to  adopt national  laws  in order  to  implement 
European regulations. European Union law takes precedence over the national laws of the Member States. 
Therefore, Member States have to legislate in the light of the provisions laid down in the EU regulations. 
20.  EU regulations do not interfere in the compilation methods of the data required for national needs 
and are directly applicable for European statistics only. However, the deviation from EU legislation and 
collection of data for national purposes normally requires additional national legal provisions. 
21.  The legal provisions on ITGS are determined in several regulations and address intra-EU trade and 
extra-EU  trade  statistics  separately.  The  ‘basic  regulations’  —  acts  adopted  by  the  Council  and  the 
European Parliament in accordance with Article 294 of the Treaty, establish the essential rules governing 
ITGS. The ‘implementing provisions’ are adopted by the Commission and define further details necessary 
for the implementation of certain articles of the basic regulations.  

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17 

 
 
 
 
 
 
 
 
 
 
The framework  2 

22.  The Treaty of Lisbon introduced new legislative instruments; the Commission can adopt two types 
of  implementing  provisions:  implementing  acts  and  delegated  acts.  These  acts  can  take  a  form  of 
regulations, directives, etc. however in ITGS context only regulations by now are adopted.  
23.  The Commission can provide implementing rules only for articles of the basic regulation for which 
it has been given the implementing power. The implementing acts are adopted via Comitology procedure 
and therefore the task to control the Commission falls upon Member States. 
24.  The  delegated  acts  can  be  adopted  only  by  the  Commission  and  only  if  the  basic  regulation 
authorises to adopt a delegated act. The delegated act can amend only non-essential elements of the basic 
regulation. The delegated acts are adopted via different procedure and the act will not be officially voted 
in the Comitology committee. However the Commission powers can be monitored by Member States in 
the context of the Council. 
25.  The  basic  regulation  and  implementing/delegated  acts  are  hierarchically  interrelated.  Therefore, 
when  consulting  the  legal  texts,  the  basic  regulation  should  be  examined  first  and  thereafter  the 
implementing provisions for further details.  
26.  Customs legislation and fiscal provisions governing value added tax areas have a direct impact on 
the availability and collection of trade statistics as well. The regulations on ITGS refer to the respective 
legal  acts  when  a  direct  implication  exists.  However,  in  order  to  be  able  to  produce  ITGS,  a  good 
knowledge of the customs and VAT legal provisions is necessary. 
27.  Customs legislation. The Customs Code represents the backbone of the EU customs legislation as it 
contains general rules and procedures for the implementation of the tariff and other measures introduced 
at  the  EU  level  in  connection  with  trade  in  goods  between  the  EU  and  non-member  countries.  The 
Community Customs Code (CCC) was established by Council Regulation (EEC) No 2913/92.  
28.  In order to facilitate trade, to simplify customs procedures and to enable the usage of modern tools 
and  technology  the  new  Modernised  Customs  Code  (MCC)  was  drawn  up.  However,  only  some 
provisions  became  immediately  applicable;  all  other  provisions  should  have  been  applicable  once  the 
implementing provisions were applicable, originally planned for 24 June 2013 at the latest.  
29.  As all secondary legislation has to be adapted to the modified legislative procedures established by 
the Lisbon Treaty, the recast of the MCC has been prepared and submitted to the European Parliament 
and  the  Council.  Even  though  the  recast  of  the  MCC  laying  down  the  Union  Customs  Code(1)  was 
adopted on 9 October 2013, most of the provisions will only become applicable from 1 June 2016, after 
adoption  of  the  implementing  and  delegated  acts.  This  means  when  referring  to  the  current  customs 
provisions, the CCC, and thus also its terminology, is used in the Compilers Guide. 
30.  In addition to the EU legislation, some specifications are agreed by Member States and Eurostat in 
so called  'Gentlemen’s agreements' which are not legally binding. An example of such an agreement is 
the  ITGS  data  transmission  to  Eurostat  format  and  other  technical  arrangements  defined  in 
'Doc MET 400'. Each revised version is adopted by the ITGS Steering Group. Although the document has 
no legal force all Member States transmit the data to Eurostat in line with its requirements. 

2.2 

Institutional arrangements 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(c) 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 2(c) 

2.2.1  To whom legislation is addressed 
31.  The  main  actors  referred  to  in  the  legislation  are  the  Commission  (Eurostat),  the  Member  States, 
national  authorities  and  the  parties  responsible  for  providing  the  information  (PSI)  ,  i.e.  the  economic 

(1)  Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code. 

Compilers guide on European statistics on international trade in goods 

18 

 
 
 
                                                           
The framework  2 

operators. The regulations define responsibilities of every stakeholder: Eurostat collects and publishes EU 
statistics; Member States compile ITGS in line with the established rules and transmit them to Eurostat 
within defined deadlines. The PSIs have the obligation to provide correct information in due time to the 
NSAs.  In  certain  articles  the  obligation  to  provide  necessary  data  to  the  NSAs  or  the  requirement  to 
exchange the data are directly imposed on other national administrations. 
32.  Responsibility of Eurostat. In a broader sense Eurostat is a Commission department responsible for 
developing work on the statistics including ITGS. It draws up the proposals for legislation and monitors 
its correct application; it provides methodological and technical assistance (development of IT tools for 
the collection and transmission of data) and it publishes ITGS data. 
33.  Responsibilities of Member States. In line with the principle of subsidiarity, the ITGS legislation, 
in a majority of cases, imposes obligations on Member States, while letting them decide how to organise 
data collection and how to share responsibilities between national administrations. 
34.  National  statistical  authorities.  In  some  cases  the  legislation  addresses  ‘national  (statistical) 
authorities’.  These  are  the  bodies  responsible  in  each  Member  State  for  producing  EU  statistics  on 
international  trade  in  goods.  However,  the  legislation  does  not  determine  any  criteria  or  requirements 
about which concrete institution in a Member State should be responsible or how it should function. 

2.2.2  Administrative structures in Member States 
35.  Various  institutional  arrangements  exist  in  Member  States  for  the  production  of  ITGS.  The 
collection,  processing  and  dissemination  of  statistical  information  may  be  carried  out  by  one  or  more 
national institutions. Each Member State has its own institutional arrangements and the activities of the 
institutions  involved  are  defined  by  the  national  law.  The  main  national  organisations  involved  in  the 
compilation  of  ITGS  are  national  statistical  institutes  (NSIs),  Customs,  central  banks  and  other 
governmental  agencies.  The  Table  2  shows  how  the  functions  of  ITGS  data  collection,  processing  and 
dissemination are shared between national administrations in Member States. 

Table 2: Institutional arrangements in Member States 

Member 
State(1)  

Leading 
administration 

Primary data 
collection 

Data processing(2) 
and control 

Dissemination 

BE 
Intrastat 
Extrastat 

BG 
Intrastat 
Extrastat 

CZ 
Intrastat 
Extrastat 

DK 
Intrastat 
Extrastat 

DE 
Intrastat 
Extrastat 

EE 
Intrastat 
Extrastat 

IE 
Intrastat 
Extrastat 

National Bank 
National Bank 

National Bank 
Customs 

National Bank 
National Bank 

National Bank 
National Bank 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

VAT Offices 
Customs 

Customs 
Customs 

NSI 
Customs 

NSI 
Customs 

NSI 
Customs 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI/Customs 

NSI 
NSI 

Revenue & Customs 
Revenue & Customs 

Revenue & Customs/NSI 
Revenue & Customs/NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

(1)  In the context of this table Intrastat/Extrastat should be understood as data collection system for intra-EU/extra-EU trade statistics. 
(2)  By data processing is meant validity and credibility checks, estimation of missing trade, adjustments and quality related analysis. 

Compilers guide on European statistics on international trade in goods 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Member 
State(1)  

Leading 
administration 

Primary data 
collection 

Data processing(2) 
and control 

Dissemination 

The framework  2 

EL 
Intrastat 
Extrastat 

ES 
Intrastat 
Extrastat 

FR 
Intrastat 
Extrastat 

HR 
Intrastat 
Extrastat 

IT 
Intrastat 
Extrastat 

CY 
Intrastat 
Extrastat 

LV 
Intrastat 
Extrastat 

LT 
Intrastat 
Extrastat 

LU 
Intrastat 
Extrastat 

HU 
Intrastat 
Extrastat 

MT 
Intrastat 
Extrastat 

NL 
Intrastat 
Extrastat 

AT 
Intrastat 
Extrastat 

PL 
Intrastat 
Extrastat 

PT 
Intrastat 
Extrastat 

RO 
Intrastat 
Extrastat 

SI 
Intrastat 
Extrastat 

NSI 
NSI 

Customs 
Customs 

Customs 
Customs 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

VAT Offices 
Customs 

Customs 
Customs 

Customs 
Customs 

Customs 
Customs 

Customs 
Customs 

VAT Offices 
Customs 

NSI 
Customs 

Customs 
Customs 

NSI 
Customs 

NSI 
Customs 

VAT offices/NSI 
Customs 

NSI 
Customs 

NSI 
Customs 

Customs 
Customs 

NSI 
Customs 

NSI 
Customs 

Customs 
Customs 

NSI 
NSI 

Customs 
Customs 

Customs 
Customs 

Custom/NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

Customs 
Customs 

Customs 
Customs 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

Customs 
Customs 

NSI 
NSI 

NSI 
Customs 

Customs/NSI 
NSI 

NSI/Customs 

NSI 
NSI 

NSI 
NSI 

NSI 
NSI 

(1)   In the context of this table Intrastat/Extrastat should be understood as data collection system for intra-EU/extra-EU trade statistics. 
(2)  By data processing is meant validity and credibility checks, estimation of missing trade, adjustments and quality related analysis. 

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20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
The framework  2 

Member 
State(1) 

Leading 
administration 

Primary data 
collection 

Data processing(2) 
and control 

Dissemination 

SK 
Intrastat 
Extrastat 

FI 
Intrastat 
Extrastat 

SE 
Intrastat 
Extrastat 

UK 
Intrastat 
Extrastat 

NSI 
NSI 

Customs 
Customs 

NSI 
NSI 

Customs 
Customs 

Customs 
Customs 

NSI 
Customs 

NSI 
NSI 

Customs 
Customs 

NSI 
NSI 

NSI 
NSI 

Customs 
Customs 

NSI 
NSI 

Revenue & Customs 
Revenue & Customs 

Revenue & Customs 
Revenue & Customs 

Revenue & Customs 
Revenue & Customs 

Revenue & Customs 
Revenue & Customs 

(1)   In the context of this table Intrastat/Extrastat should be understood as data collection system for intra-EU/extra-EU trade statistics. 
(2)  By data processing is meant validity and credibility checks, estimation of missing trade, adjustments and quality related analysis. 

2.2.3  Cooperation between institutions 
36.  The good quality of ITGS is highly dependent on the close cooperation of three major institutions: 
NSA, customs and tax administrations. ITGS result from the combination of data from various sources: 
customs records and registers, VAT/VIES records and tax registers and Intrastat declarations. For specific 
goods or movements additional data sources are necessary, such as ships and aircraft registers. In order to 
establish  regular  data  inflows  to  NSAs  it  is  necessary  to  establish  a  good  cooperation  with  the 
administrations responsible for the management of the registers as well. 
37.  Although  the  majority  of  NSAs  in  Member  States  have  established  good  contacts  with  their 
colleagues in other administrations and set up necessary data exchange systems, various problems persist. 
Smooth information flows to the NSA from other administrations on legislative and procedural changes 
affecting  statistical  data  are  not  always  ensured.  Every  institution  seeks  to  implement  its  own  mandate 
and  the  needs  of  other  administrations  are  not  always  taken  into  account.  Moreover,  when  cooperation 
between institutions is not intensive, the needs and problems of statisticians might not be known to others. 
38.  Cooperation between NSA and Customs. Customs records on import and export transactions are 
the  basis  for  extra-EU  trade  data  but  in  specific  cases  these  records  are  also  source  of  information  for 
intra-EU  trade  statistics.  A  good  knowledge  of  customs  procedures  and  legislation  is  required  for 
statisticians in order to be able to correctly define the scope of statistics and produce good quality data. 
Regular  contact  of  statisticians  with  customs  officials  is  required  when  solving  data  quality  problems. 
Therefore  MSs  are  encouraged  to  formalise  cooperation  while  establishing  working  groups  and  other 
forums for discussions and exchange of information. 
39.  Cooperation between NSA  and tax administration.    Close  cooperation  with  tax administrations 
becomes  significant  as  the  Intrastat  system  is  very  dependent  on  the  scope  and  quality  of  the  data 
provided by tax administrations: information on VAT returns, recapitulative statements by traders, VAT 
registers,  etc.  MSs  are  encouraged  to  establish  a  regular  working  group  composed  of  NSA  and  tax 
administration  representatives  in  order  to  discuss  the  developments  of  tax  legislation  and  to  highlight 
statistical requirements. 
40.  Principles of effective inter-institutional cooperation. Although there are no defined rules on how 
institutions should work together, certain good practices are encouraged: 

  establishment of inter-institutional agreements which clearly define functions and responsibilities 

of each institution; 
regular meetings of formal working groups; 

 
  participation of statisticians in legislative/procedural development groups of other institutions; 
  definition of procedures on correction of data; 
  establishment of informal regular contacts at expert level; 
  participation of experts of other institutions in statistical conferences, training and international 

meetings. 

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21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The framework  2 

2.3  Scope 

Intra-EU trade statistics 

2.3.1 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Articles 2, 3 and 7 

41.  As a general guideline, in line with the UN  recommendations on International Merchandise Trade 
Statistics,  intra-EU  trade  statistics  should  record  all  goods  which  add  to  or  subtract  from  the  stock  of 
material  resources  of  a  Member  State  by  entering  (arrival)  or  leaving  (dispatch)  its  economic  territory. 
Therefore  intra-EU  trade  statistics  concern  the  movement  of  goods  between  the  statistical  territories  of 
Member  States.  Basically  all  moveable goods  entering or leaving  a  Member  State,  including  electricity 
and gas, must be recorded. For almost all transactions (except for  some specific movements) the goods 
must physically move between Member States. 
42.  The most important definitions(1) relating to the scope of the intra-EU trade statistics are as follows: 
  Goods:  all moveable property, including electric current. In more abstract terms this refers to 
physical,  produced  objects  for  which  a  demand  exists,  over  which  ownership  rights  can  be 
established  and  whose  ownership  can  be  transferred  from  one  institutional  unit  to  another  by 
engaging  in  transactions  on  markets,  plus  certain  types  of  so  called  knowledge-capturing 
products stored on physical media which can cross borders physically. 

  Specific  goods  or  movements:  goods  or  movements  which,  by  their  very  nature,  call  for 
specific  provisions,  and  in  particular  industrial  plant,  vessels  and  aircraft,  sea  products,  goods 
delivered  to  vessels  and  aircraft,  staggered  consignments,  military  goods,  goods  to  or  from 
offshore installations, spacecraft, motor vehicle and aircraft parts, electricity and gas and waste 
products; 

  Community goods:  

(i)  goods  entirely obtained  in  the  customs  territory  of  the  EU,  without  the  addition  of goods 
from non-member countries or territories which are not part of the customs territory of the 
EU; 

(ii)  goods from non-member countries or territories which are not part of the customs territory 

of the EU, which have been released for free circulation in a Member State; 

(iii)  goods  obtained  in  the  customs  territory  of  the  EU  either  from  the  goods  referred  to 

exclusively in point (ii) or from the goods referred to in points (i) and (ii). 

It can generally be assumed that any goods which circulate between Member States and which 
are not under customs control are Community goods. 

  Goods in simple circulation between Member States:  Community goods dispatched from one 
Member State to another, which, on the way to the Member State of destination, travel directly 
through another Member State or stop for reasons related only to the transport of the goods. 

43.  Using these definitions, the scope of intra-EU trade statistics is defined as follows: statistics relating 
to the trading of goods between Member States shall cover dispatches and arrivals of goods: 

  Dispatches  shall  cover  the  following  goods  leaving  the  Member  State  of  dispatch  for  a 

destination in another Member State: 
a)  Community goods, except goods which are in simple circulation between Member States; 
b)  goods  placed  in  the  Member  State  of  dispatch  under  the  inward  processing  customs 

procedure or the processing under customs control procedure. 

  Arrivals  shall  cover  the  following  goods  entering  the  Member  State  of  arrival,  which  were 

initially dispatched from another Member State: 
a)  Community goods, except goods which are in simple circulation between Member States; 
b)  goods formerly placed in the Member State of dispatch under the inward processing customs 
procedure  or  the  processing  under  customs  control  procedure,  which  are  maintained  in 

(1)  Extra-EU trade statistics apply, mutatis mutandis, the same definition as intra-EU trade statistics. 

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The framework  2 

accordance  with  these  procedures  or  released  for  free  circulation  in  the  Member  State  of 
arrival. 

44.  The scope of intra-EU trade statistics covers some transactions with ‘non-Community goods’ which 
enter  the  EU  in  a  given  Member  State  without  release  for  free  circulation,  and  move  on  to  another 
Member  State  under  customs  inward  processing  procedures  (as  defined  in  Article  3(2)(b).  This 
information on non-Community goods must be provided by customs authorities if customs declaration is 
available.  Then  the  information  shall  be  added  to  intra-EU  trade  statistics.  However  in  line  with  the 
Community Customs Code implementing provisions, Article 512(1) the transfer between different places 
designated in the same Single Authorisation may be undertaken without any customs formalities. In other 
words  Customs  might not  have  available  the  information about  the goods  under  inward  processing and 
processing  under  customs  control  moving  between  two  Member  States.  In  such  cases  the  information 
shall be collected on Intrastat declaration. More information on the inclusion of customs data for intra-EU 
trade purposes can be found in paragraphs 183 and 214. 
45.  It should be noted that the use of the term ‘trade’ in ‘trade statistics’ is a reflection of the dominant 
role  of  buying  and  selling  in  the  generation  of  the  cross-border  flows  of  goods.  However,  many  other 
movements of goods between countries which do not result from trade transactions are covered as well. 
The  general  concept  of  intra-EU  trade  statistics  is  independent  of  the  ownership  of  the  goods  and 
concerns only their physical movement. Nevertheless, since most traded commodities can be assumed to 
cross the border as part of a normal buying and selling operation between an importer and an exporter, the 
change of ownership  is largely approximated  by  the cross-border  movement  of goods  for  BoP  and NA 
purposes. 
46.  The link between change of ownership and movement of goods is important as the Intrastat system 
attempts to maintain a close link between the system for collecting statistical information and the fiscal 
formalities — VAT and VIES — which exist in the context of trade of goods between Member States. 
This link makes it possible, in particular, to check the quality of the information collected and produces 
inclusion criteria for statistical samples using VAT data. 
47.  A  practical  consequence  of  this  link  is  that  the  majority  of  the  parties  that  are  obliged  to  provide 
statistical information are also responsible for submitting VAT returns (‘taxable person as defined in Title 
III of Directive 2006/112/EC’). 
48.  The  operational  scope  of  the  VAT  and  Intrastat  should  cover  most  of  the  trade.  However,  the 
following  special  cases  which  fall  outside  the  scope  of  VAT  or  intra-EU  trade  statistics  should  be 
mentioned: 

'triangular trade' according to tax definition; 

  goods for processing (reported  on Intrastat declaration, but on VAT return as services); 
 
  electricity, gas delivered by pipelines and other specific transactions which are not considered as 
intra-EU acquisitions and supplies should be recorded in intra-EU trade statistics but not in VAT. 
49.  As  a  result  of  the  lack  of  coverage  of  VAT  data,  it  is  difficult  to  operationally  define  full  trade 
coverage in an accurate manner. NSAs shall use all available means, including also non-VAT sources in 
order to ensure total trade coverage. Another consequence is that the coverage rate of the data collection 
cannot be defined exactly. For practical purposes, it is defined as value ratio of all collected Intrastat data 
to data reported to total intra-EU trade. For more information on the definition of 100% trade coverage 
refer to the chapter 6. Thresholds within the Intrastat system. 

2.3.2  Extra-EU trade statistics 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Preamble, point (10) and 
Articles 2 and 3 

50.  UN recommendations define the scope of IMTS in correspondence with the statistical territory, i.e. 
imports  of  a  country  are  flows  of  goods  into  its  statistical  territory  and  exports  are  the  flows  out of  its 
statistical territory. In that manner, the applied trade system depends on the practical interpretation of the 
statistical territory. The definition of statistical territory has several territorial aspects (for more details see 
chapter  2.4 Statistical 
to  UN 
recommendation  customs  warehouses,  all  types  of  free  zones,  premises  for  inward  processing  and  free 

territory).  For  determining 

trade  system  according 

the  applied 

Compilers guide on European statistics on international trade in goods 

23 

 
 
 
The framework  2 

circulation areas should be considered. The scope of extra-EU trade statistics is based on the application 
of customs procedures. 
51.  Customs warehouses allow imported non-Community goods to be held in the territory of the EU 
without the duties and taxes being paid and thus to choose when the duties are paid or to avoid them if the 
goods are later re-exported without entering into the free circulation area. 
52.  Customs  warehouses  (and  free  zones)  are  generally  used  for  the  storage  of  goods.  The  amount  of 
working  or  processing  allowed  on  goods  held  in  warehouses  is  limited  essentially  to  keeping  them 
preserved with a view to subsequent distribution. 
53.  As  a  general  rule,  Community  goods  cannot  be  subject  to  customs  warehousing  procedure,  but 
might  be  stored  in  the  premises  of  a  customs  warehouse  separated  from  goods  under  customs 
warehousing procedure. As a result, in principle there are no export flows to customs warehouses from 
the free circulation area. 
54.  However,  in  order  to  benefit  from  EU  legislation  governing  export  refunds  or  the  repayment  of 
import  duties,  some  Community  goods  might  still  be  subject  to  customs  warehousing  procedure  (see 
Example 1B). And also, with the permission of Customs, in practice it is possible to process goods under 
inward processing or processing under customs control on the premises of a customs warehouse (or free 
zone) according to the rules and requirements laid down for those procedures (see Example 1C and 1D). 
55.  Free zones are special areas within the customs territory of the EU. Goods placed within these areas 
are  free  of  import  duties,  VAT  and  other  import  charges,  i.e.  from  the  economic  point  of  view  they 
provide similar advantages to customs warehouses. 
56.  Unlike customs warehousing, free zone treatment applies to both non-Community and Community 
goods, and can affect both import and export flows. In addition, there may be special reliefs available in 
free zones from other taxes, excise or local duties. These will differ from one zone to another. 
57.  The  main  idea  of  free  zones  is  to  facilitate  trading  procedures  by  allowing  fewer  customs 
formalities. As a result there are two types of free zones defined by the CCC: 

  Control  type  I  free  zones  have  a  perimeter  fence  (which  is  supervised  by  Customs)  so  that 
goods  placed  there  are  automatically  under  this  regime.  No  customs  declaration  is  needed  to 
store goods in a control type I free zone. 

  The  rules  for  control  type  II  free  zones  are  essentially  the  same  as  those  governing  customs 
warehouses.  This  means  that,  unlike  traditional-style  free  zones,  the  goods  are  subject  to  a 
declaration in order to be able to benefit from the arrangement. 

58.  Member States make use of free zones to differing extents. In some Member States there exist no 
free  zones  at  all,  while  others  use  them  quite  extensively.  There  is  a  comprehensive  list  of  free  zones 
published by Directorate General for Taxation and Customs Union (DG TAXUD)(1). 

Special trade system 
59.  The UN IMTS manual defines two trade systems: general trade and special trade. Under the general 
trade  system,  statistical  territory  includes  customs  warehouses,  all  types  of  free  zones,  free  circulation 
area  and  premises  for  inward  processing.  UN  recommends  implementing  the  general  trade  system  for 
ITGS. 
60.  On the other hand, customs warehouses, all types of free zones and premises for inward processing 
are excluded from the statistical territory by the strict definition of the special trade, thus only imports 
and exports of the free circulation area are recorded. 
61.  The  relaxed  definition  of  special  trade  adds  industrial  free  zones  and  premises  of  inward 
processing  to  the  statistical  territory.  The  EU  concept  related  to  extra-EU  trade  follows  the  relaxed 
definition of the special trade system, whereas intra-EU trade is close to the general trade system. 
62.  The extra-EU trade basic regulation defines the scope as follows: 

(1) http://ec.europa.eu/taxation_customs/resources/documents/customs/procedural_aspects/imports/free_zones/list_freezones.pdf 

Compilers guide on European statistics on international trade in goods 

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The framework  2 

  Exports  shall  cover  goods  leaving  the  EU  in  accordance  with  one  of  the  following  customs 

procedures or customs approved treatment: 

a)  exportation; 
b)  outward processing; 
c)  re-exportation following either inward processing or processing under customs control. 
  Imports  shall  cover  goods  entering  the  EU  in  accordance  with  one  of  the  following  customs 

procedures: 

a)  release for free circulation; 
b)  inward processing; 
c)  processing under customs control. 

63.  Therefore, the extra-EU trade legislation does not exclude customs warehouses and free zones from 
the statistical territory by definition, but implicitly, by not  requiring the customs warehousing/free zone 
procedures to be recorded. This is also confirmed by the extra-EU trade basic regulation preamble (10). 
64.  The legislation, when defining the scope of extra-EU trade statistics, combines physical movement 
of  goods  (goods  leave  the  statistical  and  thus  the  custom  territory  of  the  EU)  with  listed  customs 
procedures/customs-approved  treatment.  So  the  definitions  cited  in  the  previous  paragraphs,  and  the 
exceptions described in paragraphs 54 and 55 highlight the slightly different approach of the UN and the 
EU in defining the scope of IMTS/ITGS. The UN recommendations follow a territorial approach, while 
the EU legislation rather a procedural one to define the scope of trade in goods statistics. 
65.  As  the  CCC  does  not  differentiate  between  industrial  and  commercial  free  zones  and  does  not 
acknowledge the premises of inward processing as a particular type of territorial area, from the statistical 
point  of  view,  free  zones  shall  be  considered  as  commercial  free  zones  by  default.  However,  inward 
processing  activity,  irrespective  of  whether  this  is  carried  out  in  the  free  circulation  area,  in  a  customs 
warehouse  or  in  a  free  zone,  is  included  in  ITGS  (≈  premises  of  inward  processing).  And  also, 
Community goods stored in customs warehouses and in type II free zones shall be considered as virtually 
staying in the free circulation area to remain consistent with the definition of special trade. 

General trade system 
66.  In  addition  to  the  special  trade  concept  of  EU  statistics,  several  Member  States  prepare  national 
figures  according  to  the  general  trade  system  in  line  with  UN  recommendations.  This  requires  close 
cooperation  with  national  Customs  to  obtain  relevant  records  on  customs  warehousing,  and  free  zone 
activity,  if  possible.  It  might  involve  additional  data  sources  or  data  collection.  According  to  the 
Community Customs Code implementing provisions Article 274 no supplementary declaration is required 
for  customs  warehousing  in  local  clearance,  and  type  I  free  zones  have  no  harmonised  rules  for  the 
declaration of goods. 

Example 1   
A) Customs warehousing 
Non-Community  goods  are  imported  into  the  EU  and  (1)  put  in  a  customs  warehouse  under  customs  warehousing 
procedure (7100). For general trade, customs warehouse being part of the statistical territory, this means the recording 
of imports. 
In 2/a the goods are subsequently released for free circulation (4071) and enter the free circulation area, thus cross the 
border of the EU statistical territory in the special trade concept. For general trade, this is an internal movement within 
the statistical territory and no transaction is recorded. 
In 2/b the goods are sold and re-exported from the warehouse and never enter the free circulation area of EU. In this 
case  general  trade  records  the  exports,  and  as  a  result  of  the  chain  of  transactions  shows  both  imports  and  exports, 
while special trade recorded no trade at all. 

  CPC 

Imports 

        Exports 

Special     General      Special   General 
    —            100 
   100             — 

  1  7100 
 2/a  4071 
 2/b  3171 
(*) Increase of price due to sale in customs warehouse. 

                         —        120(*) 

B) Customs warehousing for exports 
Community goods are (1) put under customs warehousing procedure (7600) to claim export refunds. For general trade, 
this is an internal movement, while for special trade goods leaving the statistical territory should be recorded as exports. 
The subsequent (2) exportation procedure (1076) should be recorded as general exports. 

Compilers guide on European statistics on international trade in goods 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
The framework  2 

Note: This case is exceptional, as generally the customs warehousing procedure cannot be used for Community goods. 
The  EU  concept  follows  in  this  case  the  general  trade  concept  and  records  the  exportation  from  the  customs 
warehousing procedure according to Annex 3 Allocation of customs procedure to type of trade and statistical procedure. 

  CPC 

Imports 

       Exports 

  1  7600 
  2  1076 

Special  General   Special  General 

         100          — 
         —          100 

C) Customs warehousing combined with inward processing 
Non-Community  goods  are  imported  into  the  EU  and  (1)  put  in  a  customs  warehouse  under  customs  warehousing 
procedure (7100). General trade records the import. 
(2)  The  goods  leave  the  customs  warehouse  to  be  processed  (or  processing  started  in  the  premises  of  the  customs 
warehouse, it does not affect the recording for statistics) under customs procedure code 5171. 
(3) After processing, goods are returned to the customs warehouse under customs procedure code 7151. According to 
special trade, this procedure should be recorded as exports of goods, as goods leave the statistical territory. However, 
according to EU concept and general trade concept, the movement is not recorded. 
(4)  The goods leave the EU from the customs warehouse. According to  the  Community Customs Code implementing 
provisions, customs procedure code 3151 shall be used instead of 3171.  The movement is recorded by general trade 
and EU rules. 

  CPC 

Imports 

       Exports 

Special  General   Special  General 

100 
100  — 

  1  7100  — 
  2  5171 
  3  7151 
  4     3151(!) 

          —            — 
         120          120 

D) Customs warehousing combined with processing under customs control 
Non-Community  goods  are  imported  into  the  EU  and  (1)  put  in  a  customs  warehouse  under  customs  warehousing 
procedure (7100). General trade records the import. 
(2) The goods leave the customs warehouse to be processed (or processing is started in the premise of the customs 
warehouse, it does not affect the recording) under customs procedure code 9171. The movement is recorded by special 
trade concept. 
(3)  After  processing,  goods  are  released  for  free  circulation  (customs  procedure  code  4091).  As  both  general  and 
special trade has already recorded the imports, no transaction is recorded here. 

  CPC 

Imports 

 Exports 

Special   General   Special  General 

  1  7100  — 
  2  9171 
  3     4091(!)  — 

100 
100  — 
— 

E) Free zone, type II 
Basically, the administration of Free zone type II is the same as that of a customs warehouse, see in Example A. The 
customs procedure code is adjusted to 78 for free zones. 

  CPC 

Imports 

        Exports 

Special  General   Special  General 

100 
100  — 

  1  7800  — 
 2/a  4078 
 2/b  3178 
(*) Increase of price due to sale in free zone before re-exportation. 

           —         120(*) 

67.  The  Example  1  illustrates  compilation  of  special  and  general  trade  based  on  customs  procedures 
rather  than  on  the  movements  of  domestic  and  foreign  goods  between  different  territorial  elements  as 
described  by  IMTS  2010.  As  the  EU  legislation  does  not  recognise  special  or  general  trade  system  the 
example shows how the EU customs procedures may be transposed into these systems. However Member 
States may define different rules for compilation of their national special or general trade. They can use 
also the list of exclusion applicable for special trade when defining the scope of general trade. 

2.3.3  List of exclusions and inclusions 

Intra-EU trade 
Commission Regulation (EC) No 1982/2004, Annex I 

Extra-EU trade 
Commission Regulation (EU) No 113/2010, Annex I 

68.  The Annexes to the above regulations list the goods and types of trade that are excluded from intra-
EU and extra-EU trade statistics. In most cases the list is the same but there are a few exceptions which 
are  described  below.  Trade  transactions  which  do  not  appear  in  the  list  are  generally  included  in  trade 

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The framework  2 

statistics.  Moreover,  some  transactions  which  are  excluded  from  trade  statistics  may  be  useful  for  the 
compilation of BoP, so although the list of exclusions refers to goods exempted from the scope of ITGS, 
data collection for other purposes is still possible (e.g. repair transactions). 
69.  Monetary gold. Monetary gold is gold owned by national governments and authorities (or by others 
who are subject to the effective control of the national government/authorities, such as authorised banks) 
and held as a reserve asset. Transactions in monetary gold occur only between monetary authorities and 
their  counterparts  in  other  economies  or  between  monetary  authorities  and  international  monetary 
organisations. As monetary gold is treated as a financial asset rather than as goods, such transactions are 
excluded  from  intra-EU  and  extra-EU  trade  statistics.  Gold  bullion  held  as  reserve  assets  by  non-
monetary institutions is included in ITGS as non-monetary gold if physically crossing the border. 
70.  Monetary  gold  is  rarely  moved  physically  from  one  country  to  another,  therefore  such  records 
seldom  appear  on  customs  declarations.  The  Combined  Nomenclature  code  7108 20 00  is  allocated  for 
monetary  gold.  NSAs  are  encouraged  to  establish  additional  procedures  in  order  to  check  all  records 
with this CN code. If the records relate to the movements of monetary gold they shall be excluded from 
statistical data. 
71.  Non-monetary gold in line with the Balance of Payments Manual 6 (BPM6) covers all gold other 
than monetary gold, including the gold held in allocated gold accounts and is included in intra-EU and 
extra-EU trade statistics. It can be in any form: coins, ingots, bars, powder etc. with a purity of at least 
995  parts  per  thousand.  Jewellery,  watches  and  other  gold  goods  should  not  be  classified  under  non-
monetary gold, but under their respective goods code. 

Example 2   
A bank buys gold bars for investment purposes on behalf of its client or for its own needs which are physically moved 
from one country to another. This transaction should be considered as non-monetary gold and included in statistics. 

72.  Means  of  payment  which  are  legal  tender  and  securities,  coins  (CN 7118 90 00)  and  banknotes 
(CN 4907 00 30) in any currency, postage stamps and other stamps (such as road tax discs, motorway toll 
prepayment stickers) that represent evidence of financial claims (CN 4907 00 10) are excluded from intra-
EU and extra-EU trade statistics provided they are in circulation. 
73.  Means of payment which are not in circulation, such as un-issued bank notes, securities and coins 
should be included in intra-EU and extra-EU trade statistics as products of the printing or manufacturing 
industry. The value should be the transaction value of the printing or metal stamping costs involved in the 
production  and  any  delivery  costs  of  the  goods.  For  used  notes  which  are  not  in  circulation,  the  value 
should be the cost of acquiring the notes and any delivery costs. Postage stamps and similar stamps (e.g. 
highway vignettes, road tax discs, motorway toll, repayment stickers and the like), provided that they are 
the subject of a commercial transaction, shall be included in intra-EU and extra-EU trade statistics in the 
same  way  as  un-issued  bank  notes  not  in  circulation.  If  coins  in  circulation  (CN 7118 90 00)  are  sold 
above  their  face  value  as  collectibles  they  are  no  longer  means  of  payment  but  commodities  to  be 
included in intra-EU and extra-EU trade statistics with their transaction value, as their function as store of 
value prevails (e.g. a set of Euro coins of a Member State in mint or proof — CN 9705 00 00). NSAs are 
encouraged to set a special check in the processing routine to distinguish coins in circulation traded as 
collectibles. 

Example 3   
The smartboxes as pre-paid cheques for the culinary, wellbeing, sport, escape/travel, entertainment services should be 
considered as means of payment. If they are delivered from Italy to the clients/consumers of the services in Germany 
they  are  ‘in  circulation’  and  consequently  they  shall  be  excluded  from  the  trade  in  goods  statistics  in  Italy  as  well  as 
Germany. 
If the smartboxes are dispatched from Italy  after their production (for instance after the printing of voucher and guide, 
their completing into a smartbox), they should be included in the trade in goods statistics. CN code 4911 99 00 covering 
travel tickets, cinema tickets as well as other admission tickets and retail rebate stamps should be used. 

74.  Goods  for  or  following  temporary  use  (e.g.  hire,  loan  or  operational  leasing,  temporary  storage 
abroad and following return) provided all the following conditions are met are excluded from ITGS: 

  no processing is or was planned or carried out; and 
 

the expected duration of the temporary use was or is not intended to be longer than 24 months; 
and 

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The framework  2 

 

the  dispatch/arrival  has  not to  be  declared as  a  supply/acquisition  for VAT purposes (intra-EU 
trade only); and 

  no change of ownership took place or is intended to take place (extra-EU trade only). 

75.  Goods falling within the scope of this exclusion enter or leave Member States for a specific purpose 
with  the  intention  of  returning  to  the  Member  State  or  country  of  dispatch  within  a  specified  period 
without having undergone any change, except normal depreciation due to their use. 

Example 4   
Goods for hire and operational lease (see paragraphs 157 — 159), 
Goods for display or use at exhibitions, fairs, meetings or similar events, 
Professional equipment, 
Containers,  pallets,  packing,  samples  and  other  goods  moving  in  connection  with  a  commercial  operation,  which 
themselves are not a subject of commercial operation, 
Goods moving for sports purposes. 

76.  When one of the conditions for movements of goods previously exempted because of temporary use 
is not met (e.g. they undergo a process, or stay longer than two years, a change of ownership takes place 
or they are declared for VAT) the goods must be included in intra-EU and extra-EU trade statistics (for 
further information on processing, see chapter Processing trade). 
77.  The  reference  period  shall  be  the  calendar  month  when  the  event  breaking  the  conditions  of  the 
provision took place, i.e. the transaction should be recorded not as a correction or revision of the trade of 
a previous reference period, but accounted for in the actual reference period when it became reportable. 

Example 5   
An  operational  leasing  contract  originally  concluded  for  24  months  but  prolonged  for  a  further  5  months  should  be 
recorded in the month the prolongation is decided. 

78.  The reference period for goods on  hire  and operational  leasing with  an intended duration  of  more 
than two years is the  month when the goods arrive or are dispatched. This is usually at the start of the 
hire/leasing arrangement. Operational and financial leasing is defined as follows (for further information 
on leasing, see chapter Goods under financial and operational lease): 

  Operational leasing relates to leases which do not substantially transfer all the risks and rewards 
associated with legal ownership to the lessee. Under an operational lease, the lessee acquires the 
right to use goods for a certain period of time, but they are expected to be returned at the end of 
the period in more or less the same condition as when they were hired out, apart from normal 
wear and tear. 

  Goods  purchased  under  financial  leasing  must  be  included  in  the  statistics  in  the  usual  way. 
Financial  leasing  relates  to  agreements  whereby  the  risks  and  rewards  of  ownership  are 
transferred to the lessee and at the end of the contract the lessee may become the legal owner of 
the goods. 

79.  Goods  dispatched  to  or  arrived  from  territorial  enclaves.  Territorial  enclaves  for  statistical 
purposes  include  embassies  and  national  armed  forces  stationed  outside  the  territory  of  the  mother 
country. Goods moving between: 

  a Member State and its territorial enclaves in other Member States/non-member countries; and 
 

the host Member State and territorial enclaves of other Member States/non-member countries or 
international organisations are excluded from ITGS. 

80.  Territorial enclaves are parts of the economic territory of a given country which are located within 
the  geographical  boundaries  of  other  countries.  They  include  embassies,  consulates,  national  armed 
forces,  scientific  stations  and  similar  emplacements.  Such  enclaves  are  usually  established  by  treaty  or 
other formal agreement. 
81.  The movement of goods between a Member State and its territorial enclaves established in another 
country is considered as an internal flow and must be excluded from ITGS. Such flows are also excluded 
from ITGS of the host Member State, since the enclaves are not part of the host Member State’s territory. 

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The framework  2 

Example 6   
A) Intra-EU trade 
Goods  dispatched  from  France  to  the  French  embassy  in  the  UK  will  not  be  reported  as  a  dispatch  in  France  or  an 
arrival  in  the  UK.  Intrastat  declarations  will  not  be  requested  from  foreign  embassies.  Moreover  the  French  embassy 
would not be a taxable person. 

Figure 1: Goods dispatched from home country to embassy 

Goods dispatched from the UK to a UK visiting forces base located in Germany will not be reported as a dispatch in the 
UK or an arrival in Germany. Intrastat declarations will not be requested from visiting forces bases. 

B) Extra-EU trade 
Goods dispatched from France to the French embassy in the  United States. This movement of goods will be normally 
recorded  by  Customs  on  a  customs  declaration  indicating  the  United  States  as  the  partner  country.  The  transactions 
should be identified and excluded from statistics. 

Figure 2: Goods imported from home country to embassy 

82.  The  movement  of  goods  between  a  Member  State  and  its  territorial  enclaves  established  in  non-
member  countries  will  be  normally  recorded  by  Customs  on  customs  declarations  indicating  that  non-
member  country  as  partner  country.  In  practice  to  detect  such  transactions  whenever  reported  on  the 
customs  declaration  is  not  always  an  easy  task  for  statisticians.  NSAs  are  encouraged  to  introduce 
special procedures in order to detect and eliminate them from the statistical database. Statisticians could 
detect  such  records  based  on  address  and  the  name  of  importer  (exporter)  indicated  on  declarations  or 
based on national extensions of customs procedure codes whenever available. 
83.  NSAs are encouraged to discuss the national declaring practices of the goods imported/exported by 
foreign embassies and other international institutions with their national Customs and find out the most 
appropriate methods for exclusion of these records. 
84.  The  movement  of  goods  between  a  host  Member  State  and  territorial  enclaves  of  other  Member 
States  or  non-member  countries  or  international  organisations  (such  as  NATO,  United  Nations)  are 
excluded from ITGS. According to BPM6 such transactions should be recorded under services. 

Example 7   
Goods obtained in France by the German embassy in Paris should not be reported as an arrival/import in France nor as 
an arrival in Germany. 

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29 

   
 
 
 
 
Figure 3: Goods obtained by an embassy 

The framework  2 

85.  The goods received or sent abroad by international organisations are included in imports and exports 
of the Member State which receives the goods from the international organisation or exports the goods to 
it. The partner country code QV or QW (countries and territories not specified) shall be used for goods 
received or sent abroad by international organisations. However the trade with international organisations 
established on the territory of a Member State is excluded. 

Example 8   
A) Intra-EU trade: 
Goods from the UK were dispatched to NATO military base in Belgium. This transaction should be recorded as dispatch 
from the UK with undefined partner country QV. Belgium should not record an arrival from the UK. 

B) Extra-EU trade — exports:  
The  goods  are  exported  from  the  UK  to  NATO  military  base  in  Turkey.  UK  ITGS  should  record  exports  of  goods 
indicating as a partner country QW. Turkey should normally exclude these transactions from its trade statistics. 
Figure 4: Goods exported to an international organisation 

C) Extra-EU trade — imports: 
If Poland receives goods from international organisations, imports in Poland should be recorded with partner country QV 
or QW accordingly (QW —— unspecified countries in extra-EU trade, QV — unspecified countries in intra-EU trade). 

Figure 5: Goods obtained from an international organisation 

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30 

     
 
 
 
 
 
The framework  2 

86.  Software  and  licences.  Carriers  of  customised  information  (such  as  diskettes,  CD-ROMs) 
containing  software  or  other  customised  information  developed  to  order  for  a  particular  client  are 
excluded  from  ITGS,  but  recorded  under  services.  Customised  software  refers  to  software  that  is 
developed to order for a particular client and made to special requirements, either as unique programs or 
adaptations from standard programs. Other customised information includes customised blueprints, audio 
and  videotapes  containing  original  recordings  (‘master  tapes’),  authors’  drafts  of  books  and  inter-
company data and accounts. 
87.  Supply of licences or rights for the use of previously supplied software should not be reported for 
ITGS. 

Example 9   
A Swedish software company provides a Belgian firm with specific software for its accounts; a French musician sends 
an audio tape of the original recording of his music to a German studio for mixing. 

88.  Other  items  similarly  excluded  from  intra-EU  and  extra-EU  trade  statistics  are  software  supplied 
which does not involve a physical exchange of goods (transmitted via the internet). 
89.  However, carriers of information containing mass produced software for general or commercial use 
should be included in intra-EU and extra-EU trade statistics. The term ‘general or commercial use’ refers 
to products (such as CD-ROMs) with stored computer software and/or data publicly available to any user 
which  can  be  bought  ‘off-the-shelf’  from  the  supplier.  These  items  are  usually  produced  in  a  standard 
form  to  carry  out  the  same  applications  or  functions  and  may  be  supplied  with  a  manual  and  software 
licence. Such goods are to be recorded under the CN code of the carrier of the information. 

Example 10  
CD-ROMs containing operating systems such as Windows, Linux and Mac. 
Audio and video CD-ROMS with mass produced music or films. 

90.  Where goods are delivered to supplement mass produced software (such as updates contained on a 
CD-ROM), the supply should be included in  intra-EU and extra-EU trade statistics, unless the price for 
the supply was already included when the software was initially purchased/sold and a separate invoice is 
not produced. Similarly, the initial purchase of hardware sold with the restriction to use only part of its 
capacity should be included in intra-EU and extra-EU trade statistics but no further declarations should be 
made on subsequent payments to unlock additional (hidden) capacity. 
Figure 6: Decision tree on software 

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31 

 Is software / information delivered on physical carrier?  NO Services => excluded from ITGS YES CD, DVD, Flash drive, hardware, book, blueprint etc. Is software / information customised?  NO Services => excluded from ITGS YES …adapted/developed to order for a particular client Goods => included in ITGS Is licence delivered together with software?  Licence fees excluded from value reported for ITGS NO YES Licence fees included in value reported for ITGS  
 
 
 
The framework  2 

91.  Software transmitted via the Internet. The electronic delivery by downloading of software (e.g. 
operation system software downloads, application software downloads) or sending via email where there 
is  no physical exchange of  goods  between Member  States  or between  Member  States  and  non-member 
countries  is  excluded  from  intra-EU  and  extra-EU  trade  statistics.  This  exclusion  applies  to  both  mass 
produced and customised software developed specifically for a particular client. 
92.  Samples  and  advertising  material.  Goods  supplied  free  of  charge  which  are  themselves  not  the 
subject of a commercial transaction, provided that the movement is with the sole intention of preparing or 
supporting  an  intended  subsequent  trade  transaction  by  demonstrating  the  characteristics  of  goods  or 
services such as: 

  advertising material 
  commercial samples 

are excluded from ITGS. 

Example 11  
Advertising material could be all goods (such as brochures, leaflets, badges and pens), the primary benefit and use of 
which is for publicity. 
Samples could  be all goods  which are used to illustrate their function or perhaps to allow potential customers to test 
them out prior to purchase. The sample does not have to be defaced or altered in any way to prevent it being sold on as 
the whole point of providing a commercial sample might be to demonstrate its functionality. 

93.  Repairs. Goods sent for and returned after repair and the associated replacement parts used in the 
repair are excluded from intra-EU and extra-EU trade statistics. Member States may record this trade for 
national purposes under NoT code 6, but must not include it in ITGS transmitted to Eurostat. 
94.  A repair entails the restoration of goods to their original function or condition. The objective of the 
operation  is  simply  to  maintain  the  goods  in  working  order;  this  may  involve  some  rebuilding, 
replacement or enhancements but does not change the nature of the goods in any way. The repair should 
not be used to improve the technical performance of the goods(1). 

Example 12  
Repairs (maintenance): 

—  simple replacement of part of an item, 
—  charging of batteries, 
—  repair of damage to goods incurred during transport, 
—  re-painting, when the painting is old or defective.  

Services (similarly excluded from intra-EU and extra-EU trade statistics): 

—  technical  maintenance  activities  for  aircraft,  which  are  carried  out  due  to  legal  requirements  (e.g.  controls, 

        mandatory periodic replacements), 

—  testing, adjusting, regulating or certification of goods (e.g. aircraft, machines, apparatus, vehicles), 
—  ironing, washing, cleaning, drying operations, 
—  packaging and labelling operations, 
—  sharpening, simple grinding or cutting, 
—  assembly/reconstruction of goods after transport, 
—  simple sorting, sifting, weighing, dividing and filtering of goods. 

95.  Associated replacement parts are goods which are integrated in a repaired commodity as part of the 
repair (e.g. new brakes in a car) in the Member State where the repair is carried out. These parts/goods are 
excluded from reporting. This is also the case if an invoice is issued separately for the part(s). However, 
goods which move in order to be used as spare or replacement parts should be reported. 

Example 13  
A Slovenian company sends a broken PC to a  Croatian company for repair. The Croatian company replaces the hard 
disk and sends the repaired PC back, together with the defective hard disk. Neither the arrival of the PC from Slovenia 
nor the dispatch of the PC to Slovenia is included in Croatian ITGS. Moreover, neither the dispatch of the new hard disk 
to  Slovenia  [associated  replacement  parts]  nor  the  dispatch  of  the  defective  hard  disk  [replaced  defective  parts]  to 
Slovenia is included in ITGS. 

(1)   Commission Regulation (EEC) No 2454/93, Article 587. 

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The repairer buys spare hard disks in Hungary, so the arrival from Hungary will be included in Croatian ITGS. If he/she 
realises  that  some  of  them  are  defective  and  he/she  sends  them  back  to  Hungary,  this  dispatch  will  be  included  in 
Croatian ITGS as well. 

Figure 7: Treatment of repairs 

The framework  2 

96.  It  should  be  noted  that  goods  subjected  to  processing  activities  must  be  included  in  intra-EU  and 
extra-EU trade statistics and recorded with the Nature of Transaction code 4 (with a view to processing) 
or  5  (following  processing).  Processing  is defined  as  covering  operations  (transformation,  construction, 
assembly, enhancement, renovation, modification, conversion) with the objective of producing a new or 
really improved item. This does not necessarily involve a change in the product classification. Particular 
attention should be paid to the differentiation of repair and processing activities for vessels and aircraft 
Further information about processing can be found under sub-chapter Processing trade. 
97.  Active  means  of  transport  travelling  in  the  course  of  their  work,  including  spacecraft 
launchers at the time of launching. Means of transport (seagoing ships, barges, aircraft, road vehicles, 
rail etc.) travelling between Member States or between Member States and non-member countries during 
the  course  of  their  activities  are  excluded  from  intra-EU  and  extra-EU  trade  statistics.  'Course  of 
activities'  refers  to  means  of  transport  engaged  in  the  transport  of  goods  and/or  persons  from  one 
destination  to  another,  including  any  stop  offs  in  between.  Spacecraft  launchers  (such  as  the  Ariane 
Rocket)  are  treated  as  a  means  of  transport  at  the  time  they  are  launched  into  space  and  therefore  also 
excluded. 

Example 14  
A container ship transports its load from France to the UK, the goods are included in trade statistics but the vessel itself 
is not the subject of any transaction or change of ownership therefore is not accounted for in the trade statistics. 

98.  Inactive  means  of  transport  (e.g.  containers,  pallets,  skids,  crates  etc.)  used  to  facilitate 
transportation  of  commodities  are  excluded  from  intra-EU  and  extra-EU  trade  statistics  when  they  are 
themselves not the subject of the trade transaction. Even if the buyer has to provide a deposit in order to 
assure that the inactive mean of transport will return to the seller, it is out of scope of ITGS. 
99.  Goods  declared  orally  to  customs  authorities  (extra-EU  trade  only).  Goods  moving  between 
Member States and non-member countries that are declared orally to Customs are excluded from extra-
EU  trade  provided  that  they  are  either  of  a  commercial  nature  where  their  value  does  not  exceed  the 
statistical  threshold  of  EUR 1 000  or  1 000  kilograms  or  of  a  non-commercial  nature  (see  chapter 
7. Thresholds — extra-EU trade). 

Example 15  
Goods brought into France by a traveller returning from a holiday in Canada are not recorded in extra-EU trade statistics 
if they were declared orally to Customs (goods of non-commercial nature). 
A consignment of goods valued at EUR 450 and weighing 800 kg imported by a Belgian business from Norway, which is 
orally declared by the importer, is not recorded in extra-EU trade statistics. 

100. Goods  released  for  free  circulation  after  being  subject  to  the  customs  procedures  of  inward 
processing  or  processing  under  customs  control  (extra-EU  trade  only).  Goods  imported  into  a 
Member  State  under  the  customs  procedure  of  inward  processing  or  processing  under  customs  control, 
which are subsequently transferred to free circulation in the same Member State, are excluded from extra-
EU trade statistics. This is because, under the Special trade system relaxed definition, such goods would 
have  already  been  included  in  extra-EU  trade  statistics  when  they  were  initially  imported  and  so  the 
exclusion is necessary in order to avoid double counting. 

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33 

 SI: before repair SI: after repair HU: Supplier of spare parts HR: repairer     Replacement parts Defective parts Goods to be repaired Included in ITGS Excluded from ITGS  
 
 
 
The framework  2 

101. Goods  imported  into  a  Member  State  under  the  customs  procedure  of  inward  processing  or 
processing under customs control, which are subsequently released for free circulation in another Member 
State, should be recorded in the original (importing) Member State in extra-EU trade statistics as imports 
for processing, and then in intra-EU trade statistics as a dispatch to the subsequent Member State. 

2.3.4  Special cases for recording trade transactions 

Processing trade 

Intra-EU trade 
Commission Regulation (EC) No 1982/2004, footnote 2 in Annex III 

Extra-EU trade 
Commission Regulation (EU) No 113/2010, footnote 2 in Annex II 
102. If goods move across countries’ borders in connection with processing transactions, they are in the 
scope of ITGS (both intra-EU and extra-EU trade statistics). This holds for both the raw materials and the 
semi-finished products sent out to be processed and the processed goods returning after processing if they 
are part of processing even if there is no change of ownership. 
103. Processing covers activities (manufacture, construction, assembling, improvement, renovation, etc.) 
with  the  aim  to  obtain  a  new  or  really  improved  commodity.  A  processing  activity  is  not  inherently 
connected  with  a  reclassification  of  the  goods  within  the  Combined  Nomenclature.  However,  if  the 
commodity code changes, the operation should be recorded as processing. 

Example 16  

—  Industrial assembly of products (the components are used for the production of a new product), 
—  Mixing goods of different qualities to produce goods of a new quality, 
—  Bottling of liquid (e.g. wine from barrels), 
—  Canning of goods (e.g. tinned food), 
—  Making up of textiles into products (e.g. clothing, handbags, curtains), 
—  Dilution or concentration of liquids (e.g. orange juice). 

104. If the treatment of a commodity relates only to its restoration to the original functioning including 
certain  ameliorations,  it  is  not  a  processing  transaction  to  be  declared  but  a  repair/maintenance  to  be 
exempted from ITGS. 
105. It is characteristic for processing that a company in another country processes material owned by an 
ordering customer. The material provided to the processor is not subject to a change of ownership. During 
processing,  the  processor  may  add  other  materials  he  owns  or  buys.  After  processing  the  goods  are 
returned to the ordering customer (the owner of the goods) or sent to another customer on behalf of the 
ordering customer. 
106. Nature  of  Transaction  (NoT)  distinguishes  between  the  processing  operations  with  and  without 
transfer of ownership to the processor. Processing activities on a processor’s own account (the processor 
becomes the owner of the goods used in the processing as well as afterwards the finished products) shall 
be  registered  under  NoT  code  1.  If  no  change  of  ownership  between  the  owner  of  the  goods  and  the 
processor occurs, NoT code 4 and 5 shall be used. 
107. If  the  materials  to  be  processed  come  partly  with  and  partly  without  change  of  ownership  the 
following principle to distinguish ‘processing under contract’ and ‘processing activities on a processor’s 
own account’ for the purpose of ITGS shall be applied: 

  When  the  value  of  material  provided  by  the  ordering  party  without  transfer  of  ownership  is 

significant, then the transaction should be treated as processing under contract; 

  When  the  value  of  material  provided  by  the  ordering  party  without  transfer  of  ownership  is 
negligible, then the transaction should be treated as processing activities on a processor’s own 
account. 

As the goods to be processed are usually delivered free of charge, the minor importance of such goods for 
the functioning of the finished product may indicated that their value is negligible. 
108. Also  NACE  rev.  2  deals  with  the  similar  issue  when  defining  treatment  of  outputs  of  outsourced 
activities. According to Eurostat NACE rev. 2 guidelines, p. 31: ‘Classification of Products by Activity 

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34 

 
 
 
The framework  2 

distinguishes between goods produced for own account and the services performed on goods on a fee or 
contract  basis.  Specific  categories  and  subcategories,  having  the  heading  ‘sub-contracted  operations  as 
part of manufacturing of…’ include partial or whole operations within the process of production of the 
products mentioned, carried out by a contractor on materials owned by the principal. These contractors 
are paid for work done and can include the provision of a small quantity of additional materials needed 
for this work.’(1) 
109. However  NACE  rev.  2  guidelines  do  not  specify  the  threshold  defining  when  the  proportion  of 
goods  sent  for  processing  to  the  final  product  is  so  significant  that  a  company  is  considered  as  the 
principal ordering processing services and that the processor acts under contract. The classification of the 
processor's output as goods or services (sub-contracted operations as part of manufacturing of ...) may be 
a hint for the usage of NoT codes 1 or 4/5. 

Example 17  
A)  A  sports  car  is  moved  temporarily  from  Italy  to  Germany  for  tuning  activities  (e.g.  improved  performance, 
modifications  of  the  car  body).  In  addition  to  the  labour  costs,  some  attached  car  parts  procured  by  the  domestic 
contractor are invoiced. As after the work is finished there is a really improved sports car the transaction is declared as 
processing in Italy as well as in Germany. 
B) Among other things, the engine and gearbox unit are provided free of charge by the German ordering party for the 
production  of  a  car  in  the  Czech  Republic.  The  foreign  producer  invoices  the  complete  car  when  it  is  imported  into 
Germany without the value of the engine and gearbox unit. The transaction is declared as processing both for dispatch 
and for re-arrival. However the value of the complete car including the engine and gearbox unit is reported for statistical 
purposes. 
C)  An  old  car  is  transported  temporarily  from  Germany  to  Poland  to  restore  the  paint  (washing,  polishing  and 
conserving). The transaction is not a ‘processing’ activity in the context of ITGS as the finished activities are only simply 
measures  to  keep  the  car  in  original  condition.  The  cross-border  movement  of  the  car  is  exempted  from  a  statistical 
declaration as repair/maintenance. 
D) A German company sends a vehicle chassis of a truck to the UK to manufacture a fire-fighting vehicle. The finished 
fire-fighting  vehicle  comes  back  to  the  German  company  which  pays  for  the  added  superstructure  (material)  and  the 
assembly (processing fee). Even if the value of the added superstructure is higher than the value of the truck (chassis) 
provided, the transaction is declared as processing. 
E)  A  German  ordering  party,  company  X,    provides  the  company  emblem  of    value  EUR 40  free  of  charge  to  the 
Austrian producers, company Y,  to be used in manufacturing of the off-road vehicle. There are additional parts of value 
EUR 100 purchased by German company X from a Slovenian company Z1 and delivered directly from Slovenia to the 
Austrian producer, to be used in the production as well. Company Y purchases additional goods of value EUR 1 000 on 
the  domestic  market  and  of  value  EUR 1 000  in  another  country,  to  be  used  in  manufacturing  of  the  off-road  vehicle. 
Company Y delivers the finished vehicle to company X decreasing the price by the value of goods delivered by German 
company  X  free  of  charge.  The  Austrian  Company  Y  does  not  become  owner  of  the  goods  provided  by  the  German 
company  X.  Even  though  the  cross-border  movements  of  emblem,  parts  and  the  finished  vehicle  are  declared  within 
Intrastat, they are not reported as processing under contract. 

(1)   http://epp.eurostat.ec.europa.eu/cache/ity_offpub/ks-ra-07-015/en/ks-ra-07-015-en.pdf 

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Figure 8: Goods with negligible value sent for processing 

The framework  2 

110. In  case  of  processing  transactions,  the  value  of  the  goods  shall  be  the  total  amount  which  would 
have been invoiced in case of sale or purchase, i.e. current sales value has to be established both for the 
primary material delivered free of charge and for the finished product respectively. If certain values are 
unknown, accurate estimates, for instance with the help of current market prices of the same or similar 
commodities, have to be made. 
111. Inward/outward processing. In trade with non-member countries the processing activities may be 
identified  through the following customs procedure: the inward processing and  the outward processing. 
However  it  is not possible to establish from  customs  procedures whether  a  change of  ownership of the 
goods  to  the  processor  took  place.  Processing  transactions  can  also  be  recorded  as  ‘normal’ 
exports/imports.  Therefore  it  is  very  important  that  the  correct  application  of  NoT  coding  is  promoted 
among  Customs  and  declarants  (not  the  automatic  completion  of  NoT  code  4  and  5  in  the  case  of 
inward/outward processing) in order to enable the proper adjustments of extra-EU trade for BoP purposes. 
112. Doc MET 400 mentions the following procedures in the case of processing arrangements approved 
by Customs: 
 

Inward processing — codes 4100, 4171, 4110, 5100, 5121, 5171 (import) and 3151, 3141 (re-
export); 

  Outward processing — codes 2100 (export) and 6121, 6321 (re-import). 

However  a  more  detailed  list  of  the  customs  procedures  relating  to  inward/outward  processing  can  be 
found in ANNEX 3: Allocation of customs procedure to type of trade and statistical procedure. 

Sales to and purchases from private individuals 

Intra-EU trade 
113. Purchases/acquisitions of goods by companies registered for VAT in one Member State from private 
persons residing in another Member State or sales/supplies of goods by the companies to private persons 
from  another  Member  State  have  to  be  declared  for  Intrastat  even  though  the  private  person  is  not  a 
provider of statistical information. There is no specific exemption from this rule. 

Compilers guide on European statistics on international trade in goods 

36 

 AT Company Y –  processor/seller Goods purchased by processor in MS B €1 000 Company Z2 – supplier DE SI Company X – ordering party/purchaser Company Z1 – supplier Goods purchased by processor in another country for €1 000 - NoT 11 Company Z3 – supplier Payment for goods delivered to processor €100  NoT 11 €100 NoT 99 €100 Payment for goods delivered by processor €2 360 NoT 11 €2 500 = €40 + €100 + €1 000 +  + €1 000 € + €360 (trade margin of company Y) NoT 11 €2 500 NoT 99 €40 NoT 99 €40  
 
 
 
The framework  2 

 Extra-EU trade 

Commission Regulation (EU) No 113/2010, Annex I, point (j) 

114.  ‘Goods of a non-commercial nature’ are goods whose entry for the customs procedure in question is 
on  an  occasional  basis  and  whose  nature  and  quantity  indicate  that  they  are  intended  for  the  private, 
personal  or  family  use  of  the  consignees  or  persons  carrying  them,  or  which  are  clearly  intended  as 
gifts(1). 
115. In  the  case  of  an  oral  customs  declaration,  these  goods  are  excluded  from  ITGS.  There  is  no 
threshold for goods of a non-commercial nature. The customs authorities are free to ask for an oral or a 
written  declaration  for  such  goods.  If  the  customs  authorities  request  a  written  or  electronic  customs 
declaration, the declaration will also be used for statistical purposes. 

Distance sale 
116. Distance sale. Distance selling means that a supplier sells goods to private individuals or customers 
established  in another  Member  State  who do not apply  VAT  to  their  intra-EU  acquisitions of goods(2). 
The supplier takes care of the transport of the goods to the customers. The goods are transported from one 
Member State to another Member State by or on behalf of the supplier. A typical example is mail order 
companies, phone, tele-sales or physical goods ordered over the internet. The distance sales arrangements 
are not applicable to second-hand goods and works of art, for which special VAT rules apply.  
117. However, the distance sale should be distinguished from the arrangements which look like distance 
sale  but  are  not.  The  fiscal  distance  sale  implies  that  goods  are  directly  transported  from  the  Member 
State other than Member State of consumption, i.e. the Member State where the private individual takes 
delivery of the goods. 
118. A  supply  to  a  private  individual  occurring  after  the  trader  has  stored  the  goods  in  a  distribution 
centre placed in the Member State of consumption must not be considered as distance sale. In this case 
two distinct operations have to be identified: first a movement of goods following the standard rules of 
intra-EU  supply  and  acquisition  of  goods  (transfer  of  goods),  secondly  an  internal  sale  in  the  Member 
State  of  consumption.  So  if  the  business  model  involves  not  only  the  trader  and  the  private 
individual/customer  but  also  another  intermediary  company  (for  example  a  subsidiary  company 
established in the Member State of consumption), there is not distance sale. 
119. Each  Member  State  has  established  thresholds  in  its  national  currency,  which  define  whether  a 
trader needs to be registered for VAT in the Member State of destination of goods. If the trader does not 
exceed the threshold in the Member States of destination, he is not obliged to register as VAT payer in 
that  Member  State.  In  this  case,  the  place  of  supply  remains  in  the  Member  State  of  origin  (where  the 
transport  operation  begins).  In  practice  it  means  that  the  trader  will  charge  the  foreign  customer  his 
national VAT rate and will transmit this amount to the national tax administration. The only exception to 
this rule is the supplied goods subject to excise duty: although the distance sales value does not reach the 
threshold, the place of supply shall always be the Member State of destination of goods.  
120. When  the  annual  value  of  goods  supplied  to  the  customers  in  another  Member  State  exceeds  the 
distance sales threshold, the trader is obliged to register for VAT in that Member State. In this case, the 
place of supply is shifted to the Member State of destination (where transport ends). The trader (supplier 
of goods) will charge his customers local VAT rate and will transfer this amount to the tax administration 
of  the  Member  State  of  destination.  Depending  on  the  business  model,  the  trader  may  register  as  an 
established trader or he may register as a non-established trader and appoint a tax representative.  
121. The  trader  may  register  voluntarily  in  the  Member  State  of  destination,  although  his  annual  trade 
value does not exceed the threshold. In some Member States, the distance seller, who wishes to register in 
the Member State of destination as VAT payer, however did not yet exceed the threshold defined in that 
Member State, needs to obtain an authorisation for shifting the place of supply to the Member State of 
destination  from  his  national  tax  administration,  i.e.  for  being  able  to  charge  the  local  VAT  in  the 

(1)   Commission Regulation (EEC) No 2454/93, Article 1, point 6. 
(2)   Article 33(1)(a)  of Council Directive No 2006/112/EC: The supply of goods  is carried out for a taxable person,  or a non-taxable legal person, 

whose intra-Community acquisitions of goods are not subject to VAT pursuant to Article 3(1) or for any other non-taxable person. 

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The framework  2 

Member  State  of  destination.  And  vice  versa,  when  registering  for  VAT  in  the  Member  State  of 
destination,  the  local  tax  administration  might  ask  from  the  trader  the  above  mentioned  authorisation 
issued by the tax administration of the Member State of origin. This information might be useful for the 
NSA  of  small  Member  States,  where  the  Intrastat  exemption  threshold  is  lower  than  the  distance  sale 
threshold, for better monitoring of Intrastat trade flows.  
Reporting of distance sale transactions in Intrastat 
122. Who has to report for Intrastat distance sales transactions? The supplier of goods should report 
dispatches whenever the Intrastat exemption threshold is exceeded. There are no specific rules in Intrastat 
for the reporting of distance sales transactions with regard  to the content, valuation or timing. Standard 
rules apply.  
123. In the majority of Member States, Intrastat thresholds are higher than the distance sales thresholds, 
therefore  only  part  of  this  trade  will  be  reported  as  arrivals  under  the  Intrastat  system.  According  to 
Article  34  of  Directive  2006/112/EC  the  maximum  distance  sale  threshold  is  defined  as  EUR 100 000, 
however, in practice, the majority of Member States are applying much lower thresholds, which are close 
to EUR 35 000. This amount is significantly lower than Intrastat thresholds in nearly all Member States. 
However NSAs are encouraged to consult their tax administration about the VAT registration threshold 
applied to distance sales.  

Distance seller above the distance sales threshold and Intrastat exemption threshold 
124. As  a  general  rule,  acquisitions  of  goods  by  traders  (taxable  persons)  from  private  individuals 
residing in another Member State or dispatches of goods to private individuals of another Member State 
have  to  be  declared  for  Intrastat  only  by  traders  above  the  Intrastat  exemption  threshold.  The  private 
individuals,  as  long  as  they  are  not  regarded  as  taxable  persons,  are  not  required  to  provide  Intrastat 
declarations. Therefore the supply of goods by taxable persons to private individuals within distance sales 
arrangements should be reported in Intrastat following standard rules.  
125. In  the  dispatching  Member  State,  the  trader  should  provide  an  Intrastat  declaration  (reporting 
dispatches),  submit  regular  VAT  returns  and  (possibly)  VIES  declarations.  The  national  rules  define  in 
which box of VAT return this amount is declared. As distance sales from a VAT point of view are not 
considered  as  intra-EU  supplies,  this  amount  may  not  be  recorded  in  intra-EU  trade  relevant  boxes. 
Therefore the possibilities of using the VAT data by NSAs for completeness checks of Intrastat data are 
not the same across the Member States.  
126. In  the  acquiring  Member  State,  the  private  individual  who  receives  the  goods  is  not  liable  for 
Intrastat. In this context the PSI can be: 

 

 

the  non-established  trader,  that  is  registered  for  VAT  purposes  in  the  Member  State  of 
consumption; or  
the legal person that takes delivery of the goods, when there is a breaking load in a distribution 
centre before the private individual receives the goods.  

Figure 9: Distance sale 

Compilers guide on European statistics on international trade in goods 

38 

 MS B Supplier's  registration for VAT Consumer MS A Supplier Goods Invoice Intrastat declaration  Dispatch Intrastat declaration  Arrival  
 
 
 
The framework  2 

127. If the national rules do not require to report this transaction in the box of VAT return related to intra-
EU  acquisitions,  then  it  might  be  difficult  to  ensure  completeness  of  trade  recorded  in  Intrastat  upon 
arrivals. Moreover, all the common problems related to the collection of Intrastat declarations from non-
established traders will have to be considered.  
128.  Distance sales business often involves several Member States when  the distance seller establishes 
distribution centres in other Member States. Although the sales contract, which gives rise to the dispatch 
of  goods,  is  concluded  between  a  private  individual  (or  another  non-taxable  person)  and  the  distance 
seller  in  the  Member  State  where  the  mother  company  is  established,  the  goods  are  dispatched  to  the 
client by the nearest distribution centre, which may be situated in the third dispatching Member State.  
129. The  mother  company  establishing  distribution  centres  in  other  Member  States  has  to  register  its 
business in that Member State, to comply with the local VAT rules and provide Intrastat declaration when 
exceeding Intrastat exemption threshold. All movements of goods for business purposes between taxable 
persons (e.g. between mother company and distribution centres or supply of goods from other Member 
States to the distribution centres) will follow standard rules of intra-EU supply/acquisition of goods. Only 
the  final  delivery  of  goods  from  the  distribution  centre  to  non-taxable  person  in  another  Member  State 
will be a subject to the rules applicable to distance sales.  
130. If a consumer returns the goods bought under distance sale to the supplier or its distribution centre 
because  the  goods  do  not  correspond  to  his/her  wishes,  Member  States  may  require  from  the  supplier 
registered for VAT in the Member State of consumption to declare also these returned goods as dispatch 
in that Member State. If the distribution centre is located in the Member State of consumption than the 
return of goods is not reported for intra-EU trade. 

Distance seller below the distance sales threshold but above Intrastat exemption threshold 
131. The cases where the distance seller is below distance sales threshold, but above Intrastat exemption 
threshold  are  more  theoretical  than  acquire  in  practice:  only  one  Member  State  has  got  Intrastat 
exemption threshold below EUR 35 000.  
132. In the dispatching Member State the trader should report dispatches when exceeding the Intrastat 
exemption threshold. However this trade is not reported as intra-EU supply on VAT returns and the VIES 
declaration is not lodged, as the place of supply remains in the Member State of dispatch. Consequently it 
is not possible to use VAT data for monitoring this type of trade flows in Intrastat.  
133. In the acquiring Member State the private individual receives the goods, however he is not liable 
to  report  to  Intrastat.  The  VAT  obligations  of  trader  would  remain  in  the  Member  State  of  dispatch, 
therefore  the  taxable  person  liable  to  provide  Intrastat  declaration  cannot  be  identified  in  the  acquiring 
Member State. There is no legal obligation for distance seller (from dispatching Member State) to provide 
Intrastat declaration in acquiring Member State either. Therefore the arrival flow will not be recorded in 
Intrastat. 

Data analysis 
134. Consequences  for  data  analysis.  The  distance  sales  may  distort  the  detailed  mirror  data 
comparisons  of  two  Member  States.  The  discrepancy  in  the  mirror  data  will  appear  when  the  distance 
sales  are  reported  to  Intrastat  in  the  dispatching  Member  State,  but not recorded  in  the  arrival  Member 
State,  because  distance  seller  is  below  VAT  distance  sale  and  Intrastat  exemption  thresholds.  However 
the amount of not reported trade would be statistically insignificant. 
135. Comparisons with VAT data. Distance sales may distort Intrastat trade data comparisons with the 
VAT data related to intra-EU acquisitions and supplies. From VAT point of view the distance sales are 
not considered as intra-EU supplies and acquisitions, therefore the taxable amount of distance sales may 
not  be  recorded  in  the  VAT  return  boxes  relevant  for  Intrastat.  The  national  rules  define  reporting 
obligations  and  practices.  The  Member  States  can  decide  in  which  boxes  of  the  VAT  return  this 
information has to be entered. 
136. In some Member States the value of distance sales (when the trader is above distance sales threshold 
and  the  place  of  supply  is  acquiring  Member  State)  is  nevertheless  recorded  in  the  boxes  of  the  VAT 
returns related to intra-EU acquisitions and supplies. VIES declaration is as well provided, which makes 
statistical  comparisons  of  data  easier.  NSAs  are  encouraged  to  analyse  with  their  tax  administrations 
how distance sales are recorded on the national VAT return and to find solutions to ensure full coverage 
of this type of trade. 

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The framework  2 

137. Reporting obligations of returned goods in case of distance sales. The returned goods should be 
reported in Intrastat following standard rules. However in case of distance sales, the dispatch of returned 
goods will not be reported because the dispatcher is not a taxable person. Only arrivals by taxable persons 
should be reported in Intrastat. 

Waste products 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 

138. Although waste materials (including recoverable material) belong to the category of specific goods 
or  movements  the  normal  rules  apply  for  them.  They  are  in  the  scope  of  the  ITGS  to  be  recorded  as 
border-crossing goods transactions since the waste is not mentioned on the list of exclusions. 
139. Cross-border trade of waste can be differentiated into selling/buying transactions of valuable waste 
containing recoverable (valuable) materials, the processing of valuable waste, and the disposal of waste: 

  Buying/selling  of  valuable  waste:  This  is  a  trade  transaction  between  two  entities  which  is 
considered as a purchase/selling transaction for tax purposes. In ITGS this has to be declared as a 
normal purchase (NoT 11). Example: Purchase/sale of iron scrap (CN 7204 10 00). 

  Processing  of  valuable  waste.  In  this  case  the  owner  of  the  valuable  waste  commissions  a 
processor  to  extract  valuable  materials  from  waste  and  to  subsequently  return  these  recovered 
materials.  In  ITGS  this  has  to  be  reported  as  processing  (NoT  41/51).  Example:  processing  of 
defective catalysts (CN 8421 39 60). 

  Disposal  of  waste.  A  company  exports  waste  for  disposal  against  payment,  i.e.  the  company 
pays for the disposal services of the exported waste. In this case, it makes no difference whether 
the waste contains valuable materials that can potentially be recovered. In ITGS this should be 
reported  with  NoT  99,  the  actual  weight  and  1  unit  of  value.  Example:  Disposal  of  liquid 
chemical waste (CN 3825 69 00). 

140. Waste  and  scrap  should  be  recorded  and  classified  under  the  appropriate  commodity  heading, 
whenever  a  special  CN  code  for  waste  goods  is  allocated  (e.g.  CN 7602 00  —  Aluminium  waste  and 
scrap, CN 5103 00 00 — Waste of animal hair, CN 3825 10 — Municipal waste, etc.). However if there 
are no specific CN codes allocated to certain waste products, general rules for the interpretation of the CN 
shall be used. 
141. If the waste has no market value and its shipment is seen only as a service, and the exporter pays for 
waste disposal (the value of waste might be negative), then for practical reasons the negative value shall 
be adjusted close to zero or to 1 unit of value. 
142. The collection of information in Intrastat from traders about the waste which has no market value, 
and  its  movement  is  related  to  the  service  might  be  difficult,  as  they  might  not  be  required  to  provide 
VAT returns, which would prevent them from being identified. Moreover, they would be excluded from 
reporting to Intrastat as their trade would be below the exemption threshold. If a company is an Intrastat 
reporter because of trade with other goods then it shall also report trade in waste even with 0 value. 
143. In  extra-EU  trade  statistics,  the  waste  with  positive  or  negative  value  will  have  to  be  declared  to 
Customs. If the waste has a negative value, statistical value shall be adjusted close to zero or to 1 unit of 
value. 

Migrant effects, humanitarian aid and other similar items relieved from customs duties 
and taxes 

Extra-EU trade 
Commission Regulation (EU) No 113/2010, Annex I, point (j) 

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144. The commodities such as bridal outfits, trousseaux and household effects involved in moving house 
or  personal  property  acquired  by  inheritance(1),  goods  for  the  benefit  of  disaster  victims(2)  and  similar 
customs-free commodities have to be recorded by statistics in principle. However due to the application 
of the exemption thresholds in Intrastat or the possibility of declaring such goods orally to Customs, in 
practice such goods will not be covered by statistics. 

Intra-EU trade 
145. In Intrastat these goods should be reported only in cases where a private individual being considered 
a taxable person exceeds the exemption thresholds. 

Extra-EU trade 
146. According to point j) of the list of exclusions, commodities that may be orally declared to Customs 
and  that  are  of  non-commercial  nature  are  generally  exempted  from  a  customs  written  or  electronic 
declaration. In this respect this is applicable for migrants’ effects, humanitarian aid and similar goods. 
147.  However  if  the  national  Customs  requires  these  types  of  goods  to  be  declared  on  paper  or 
electronically, such goods should not be excluded from statistics. 
148. If these goods have to be declared to Customs, the specific commodity codes would be used: 

  9905 00 00 for migrants’ effects; 
  9919 00 00 for other commodities. 

Newspapers and periodicals under subscription 
149. Border-crossing  movements  of  newspapers  and  periodicals  are  in  principle  in  the  scope  of  ITGS. 
Only  if  the  general  exemptions  may  be  applied  (extra-EU  trade:  below  EUR 1 000/1 000 kg  per 
consignment;  intra-EU  trade:  company  is  below  the  current  national  statistical  exemption  threshold), 
newspapers and periodicals are not reported. 
150. The  newspapers  and  periodicals  sent  under  direct  subscription  are  excluded  from  the  general 
merchandise statistics not only according to BPM6, but also according to IMTS 2010. Although European 
ITGS  regulations  do  not  address  these  types  of  goods,  trade  in  periodicals  under  direct  subscription 
should be considered as trade in services. 

Goods under financial and operational lease 

Intra-EU trade 
Commission Regulation (EC) No 1982/2004, footnote 1 in Annex III 

Extra-EU trade 
Commission Regulation (EU) No 113/2010, footnote 1 in Annex II 

Financial leasing 
151. Financial  leasing  includes  commercial  transactions  where  the  lessor  receives  lease  payments  to 
cover its ownership costs. The lessee is responsible for maintenance, insurance, and taxes. Some financial 
leases  are  conditional  sales  or  hire  purchase  agreements.  The  leasing  rates  are  calculated  so  that  they 
cover the whole or nearly the complete value of the commodity. The benefits and risks of the ownership 
are passed over to the lessee; at the end of the contract, the lessee becomes also the  legal owner of the 
commodities.  All  cross  border  movement  of  goods  related  to  financial  leasing  should  be  recorded  in 
ITGS. However other provisions might be applicable for some specific movements. 
152. During the lease period the lessee is not the legal owner of the good, although he can be considered 
as the economic owner as the lessor has no interest in the goods being returned. After the leasing period 
the lessee has usually a contractual buying option at the residual market value. For this reason, financial 
leasing  is  considered  as  an  atypical  lease  contract  (instalments  against  cession  of  right  to  use)  with 

(1)   Council Regulation (EC) No 1186/2009, Articles 3, 12 and 17. 
(2)   Council Regulation (EC) No 1186/2009, Article 74. 

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The framework  2 

transfer of the risks of material damage and price variation to the lessee in combination with a subsequent 
buying option on the reduced residual value. 
153. Characteristic for such contracts is the fixed minimum leasing period during which a termination of 
the contract by the lessee is impossible. 
154. The  following  characteristics  could  lead  to  a  leasing  which  is  classified  as  financial  leasing  and 
differentiated from operational leasing: 

  a  fixed  minimum  leasing  period  covers  a  substantial  part  of  the  economic  life  of  the  goods 

(without right to terminate the contract by the lessee); 
the investment risk is born by the lessee; 

 
  various options after the end of the minimum leasing period (purchase, return, etc., especially if 

the transfer takes place under special conditions); 

  costs for measures to preserve value (maintenance, insurance) are born by the lessee; 
 
the leased good is specifically built for the lessee and cannot be used by third parties; 
 
the lessee capitalises the leasing object (straight-line depreciation over the machine life). 
155. For vessels and aircraft, the differentiation between financial and operational leasing cannot be made 
solely  on  the  basis  of  the  title  of  the  leasing  contract.  As  various  forms  of  leasing  contracts  exist, 
supplementary  criteria  for  vessels  and  aircraft  have  to  be  analysed  and  assessed  before  deciding  if  the 
vessel has to be recorded in ITGS or not. The decision on a record should be made on the basis of certain 
criteria to determine if the leasing is linked with a change of economic ownership of the vessel/aircraft or 
not. For more information on the treatment of vessels and aircraft, please refer to chapter 4.3 Vessels and 
aircraft. 

Operational leasing 
156. Operational  leasing  is a  kind  of  leasing  that  resembles  hire  but in  many  cases it  includes  further 
services which are not typical of hire. Essential characteristics are: 

 

 

there is in principal not a fixed minimum term of lease and hence a right of cancellation at any 
time within the cancellation period; or 
it  may  be  that  there  is  a  fixed  lease  term  within  which  a  termination  of  the  agreement  is  not 
allowed but it is very short; 
the lessee records the leasing rates as expenses; 

 
  supplementary services such as maintenance and repair are at the expense of the lessor; 
 

the attribution on the balance sheet and capitalisation is effected by the lessor. He depreciates the 
leasing objects on a straight-line basis over the usual economic life of the goods (amortisation). 

157. Operational  leasing  transactions  with  a  duration  of  less  than  24  months  should  be  excluded  from 
ITGS  statistics  and  recorded  under  services  for  all  goods  which  do  not  fall  under  the  provisions  of 
specific movements. For some specific movements other provisions might be applicable. 
158. In connection with the recording of vessels and aircraft, it is necessary to get further information to 
assess if there is a change of economic ownership or not. 

Receptacles 

Intra-EU trade 
Commission Regulation (EC) No 1982/2004, Annex I, point (c) 

Extra-EU trade 
Commission Regulation (EU) No 113/2010, Annex I, point (c) 

159. Empty  receptacles  (e.g.  empty  bottles,  fire  extinguishers  etc.)  which  are  temporarily  imported  or 
exported with the aim of filling them with goods should, as a general rule, as commodities for temporary 
use be exempted from reporting. 

Call off and Consignment stock transactions 
160. A  distinction  is  drawn  between  the  terms  consignment  stock  transactions  and  call  off  stock 
transactions. Transferred goods still held within the control and ownership of the supplier are known as 

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consignment stocks. If the customer is instead effectively in control of the stocks — the customer is able 
to take the goods from the stores at will — then this is classified as call off stock. As regards intra-EU 
trade,  goods  supplied  from  one  Member  State  to  another  Member  State  under  the  consignment  stock 
system or the call off stock system must be declared as a dispatch from one Member State with a value 
based on the open market value of the goods and similarly as an arrival in the other with a value based on 
the market value of the goods (see chapter 3.6  Value). 
161. Consignment  stock.  When  a  trader  transfers  his  own  stocks  to  another  Member  State  to  create  a 
stock  he  controls,  it  can  be  treated  as  an  intra-EU  supply  of  goods.  Since  this  transfer  of  goods  is 
effectively  an  intra-EU  acquisition  of  the  trader's  own  goods  in  another  Member  State,  the  trader  must 
account  for  the  acquisition  VAT  for  the  movement  of  the  goods  under  the  target  country's  rules  — 
typically a VAT registration of the trader in the target country is required. Subsequently, the trader will 
need  to  file  periodic  VAT  returns  to  report  both  the  arrival  of  the  goods  in  the  Member  State  and  the 
onward  sale  to  customers.  The  reference  period  is the  calendar  month  during which  the  dispatches  and 
arrivals of the goods take place (see chapter 3.2 Reference period). As regards the nature of transaction, 
generally code ‘1’ will be used (see chapter 3.11 Nature of Transaction) 
162. Call  off  stock.  When  a  trader  moves  goods  to  another  Member  State,  and  generally  a  single 
customer takes control of the stock, then two taxable transactions are concerned. First there is an intra-EU 
supply  from  one  Member  State  where  the  intra-EU  acquisition  in  the  other  Member  State  follows  and 
second there is the event when goods are ‘called off’ (i.e. a national taxable transaction). 
163. In this context it is basically necessary for the trader from the supplying Member State to register for 
VAT as this trader effects an intra-EU acquisition in the other Member State. But in the frame of the call 
off  stock  system  Member  States'  tax  administrations  allow  a  different  simplification  (to  limit 
administrative  burden), which generally aims  to  avoid  this  necessity to  register  in  the  Member  State  of 
acquisition,  whereby  the  intra-EU  acquisition  is  declared  by  the  customer  in  the  other  Member  State. 
Subsequently  the  responsibility  to  declare  the  arrivals  to  the  Intrastat  authorities  usually  passes  to  the 
customer. 
164. The different simplification options from the VAT point of view in Member States may also have an 
adverse  effect  on  the  reference  period.  As  a  general  rule  to  ensure  comparability  with  fiscal  data,  the 
reference period should be defined as the calendar month for which the same transaction is recorded for 
fiscal purposes. As regards the nature of transaction, generally code ‘1’ will be used. 

Example 18  
Trader AT1 delivers metal goods to its call of stock facility in Slovakia. Customer SK1 is able to take the goods for the 
stores  at  will  and  may  use  the  metal  goods  in  the  frame  of  a  production  process  or  sell  the  metal  goods  to  another 
customer trading partner e.g. SK2. 
Depending on the VAT-rules in Member States: 
—  If simplification is possible: AT1 will report a dispatch from Austria to Slovakia. SK1 will report an arrival in Slovakia 

from Austria. 

—  If simplification is not possible: AT1 — registered in Slovakia — will report the dispatch from Austria to Slovakia and 

the arrival from Austria in Slovakia. 

Emergency aid 

Intra-EU trade 
Commission Regulation (EC) No 1982/2004, Annex III 

Extra-EU trade 
Commission Regulation (EU) No 113/2010, Annex II 

165. The  ITGS  records  both  the  delivery  of  ‘goods  for  first  aid  in  emergencies’  and  ‘humanitarian  aid 
shipments’.  These  deliveries  may  cover  variety  of  goods:  food,  clothing,  medicaments  etc.  whether 
provided by governments, international or non-governmental organisation to organisations or individuals 
from other country. 
166. For  simplification  reasons,  there  is  a  possibility from  the  point  of  view  of  customs  law  to  declare 
‘imports of goods for the first aid in emergencies’ pooled under the special commodity code 9919 00 00 
provided  the  importer  is  a  charitable  or  philanthropic  organisation  (aid  agency)  as  recognised  by  the 
national law and approved by the competent  national authorities (e.g. Charity Commission for England 
and Wales). Reporting such goods for exports and within Intrastat follows general rules. 

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The framework  2 

167. If  the  aid  supplies  are  provided  free  of  charge  as  is  usually  the  case,  the  NoT  code  ‘3’  shall  be 
declared as nature of transaction. 

2.4  Statistical territory 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 4 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 2(b) 

168. Statistical territory. The statistical territory of a Member State is generally defined by its customs 
territory  as  defined  in  Article  3  of  Council  Regulation  (EEC)  No  2913/92  (with  the  exception  of 
Heligoland(1) which belongs to the statistical but not the customs territory of Germany). 
169. Intra-EU trade statistics are produced on goods traded between the statistical territories of Member 
States.  If  goods  are  traded with  territories  outside  the  statistical  territory  of  the  EU  the  trade  should be 
recorded in general within extra-EU trade. However, for some specific movements intra-EU and extra-EU 
trade statistics are not linked to the statistical territory (e.g. special rules on vessels and aircraft). 
170. The customs territory of the EU includes the territorial waters, the inland maritime waters and the 
airspace of the Member States, except the territorial waters, the inland maritime waters and the airspace 
of those territories which are not part of the customs territory of the EU. 
171. Exclusive economic zones. Every coastal state may establish the breadth of its territorial sea up to a 
limit not exceeding 12 nautical miles and this part of the territory belongs to its customs territory and thus 
its  statistical  territory.  However,  in  addition,  a  country  may  also  define  an  exclusive  economic  zone 
(which was given binding international recognition by the Third United Nations Convention on the Law 
of the Sea in 1982) as a zone beyond and adjacent to the territorial sea, not exceeding 200 nautical miles, 
in which it has sovereign rights for the purpose of exploring and exploiting, conserving and managing the 
natural resources. This zone may coincide with the Member State’s continental shelf(2). These exclusive 
economic  zones  do  not  belong  to  the  statistical  territory  of  the  Member  States.  However  the  exclusive 
right of a Member State to exploit seabed and subsoil in these zones is considered when compiling trade 
in goods delivered to and from offshore installations. 
172. VAT  territory.  Some  parts  of  the  EU  customs  territory  do  not  belong  to  the  EU  fiscal  territory; 
consequently  the  VAT  Directive  is  not  entirely  applicable  in  these  territories.  Trade  between  these 
territories and other Member States is recorded via customs declarations (see chapter 2.5 Data sources). 

(1)   Island in the North Sea. 
(2)   The  continental  shelf  of  a  coastal  state  comprises  the  seabed  and  subsoil  of  the  submarine  areas  that  extend  beyond  its  territorial  sea 
throughout the natural prolongation of its land territory to the outer edge of the continental margin, or to a distance of 200 nautical miles from the 
baselines from which the breadth of the territorial sea is measured where the outer edge of the continental margin does not extend up to that 
distance (Article 77.1 of UN Convention on the Law of the Sea). 
So the continental shelf can spread out beyond the exclusive economic zone of a country depending on the seabed topography. Therefore the 
wording ‘may coincide’ is used in the paragraph instead of the wording ‘coincides’. 

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Table 3: VAT, customs and statistical territories of Member States 

Member State/Country/Territory 

VAT 

Customs 

Statistical 

The framework  2 

Belgium (BE) 

Bulgaria (BG) 

Czech Republic (CZ) 

Denmark (DK) 

the Faeroe Islands (FO)  

Greenland (GL) 

Germany (DE) 

the Island of Heligoland (DE) 

the territory of Büsingen (CH) 

Estonia (EE) 

Ireland (IE) 

Greece (EL) 

Mount Athos (EL) 

Spain including Balearic Islands (ES) 

Ceuta (XC) 

Melilla (XL) 

Canary Islands (ES) 

France including Corsica and Monaco (FR) 

French Guiana (FR) 

Guadeloupe (FR) 

Martinique (FR) 

Réunion (FR) 
Mayotte (YT)(2) 

New Caledonia (NC) 

Saint-Pierre and Miquelon (PM) 

Wallis and Futuna Islands (WF) 

French Polynesia (PF) 

French Southern (TF) and Antarctic Territories 

Croatia 

Italy including Sicily and Sardinia (IT) 

the municipalities of Livigno (IT) 

Campione d'Italia (CH) 

the Italian water of Lake Lugano (IT) 

San Marino (SM) 

Cyprus including UK Sovereign Base Areas, Akrotiri 
and Dhekelia (CY) 

Latvia (LV) 

Lithuania (LT) 

Luxembourg (LU) 

Hungary (HU) 

Y 

Y 

Y 

Y 

N 

N 

Y 

N 

N 

Y 

Y 

Y 

N 

Y 

N 

N 

N 

Y 

N 

N 

N 

N 

N 

N 

N 

N 

N 

N 

Y 

Y 

N 

N 

N 

N 

Y 

Y 

Y 

Y 

Y 

Explanation:  Y : the area is part of the relevant territory. 

N : the area is not part of the relevant territory. 

(1) The statistical information for intra-EU trade statistics is obtained via the customs declaration. 
(2) Mayotte has been part of the statistical territory of France since 1 January 2014. 

Y 

Y 

Y 

Y 

N 

N 

Y 

N 

N 

Y 

Y 

Y 

Y 

Y 

N 

N 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

N 

N 

N 

N 

Y 

Y 

N 

N 

N 

N 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

N 

Y 

Y 

N 

Y 

Y 

Y 
Y(1) 

Y 

N 

N 
Y(1) 

Y 
Y(1) 
Y(1) 
Y(1) 
Y(1) 
Y(1) 

N 

N 

N 

N 

N 

Y 

Y 

N 

N 

N 

N 

Y 

Y 

Y 

Y 

Y 

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The framework  2 

Member State/Country/Territory 

VAT 

Customs 

Statistical 

Malta (MT) 

The Netherlands in Europe (NL) 

Austria (AT) 

Poland (PL) 

Portugal including Azores and Madeira (PT) 

Romania (RO) 

Slovenia (SL) 

Slovakia (SK) 

Finland (FI) 

the Aland Islands (FI) 

Sweden (SE) 

United Kingdom including the Isle of Man (GB) 

the Channel Islands (GB) 

Gibraltar (GI) 

Explanation:  Y : the area is part of the relevant territory. 

N : the area is not part of the relevant territory. 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

Y 

Y 

N 

N 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 
Y(1) 

Y 

Y 
Y(1) 

N 

(1) The statistical information for intra-EU trade statistics is obtained via the customs declaration. 

173. As a general rule, it can be said that trade between territories with the country code of one of the 28 
Member States (BE, BG, CZ, DK, DE, EE, IE, GR, ES, FR, HR, IT, CY, LV, LT, LU, HU, MT, NL, AT, 
PL,  PT,  RO,  SI,  SK,  FI,  SE,  GB)  belongs  to  intra-EU  trade  statistics  and  trade  of  a  reporting  Member 
State with a territory which has another country code belongs to extra-EU trade statistics. 
174. It is recommended that NSAs include a table in manuals to PSIs showing the territories which are 
included in and excluded from the statistical territory of each Member State and  to state clearly that for 
movements to or from an excluded territory, an Intrastat declaration must not be made. This prevents the 
duplication  of  effort  for  businesses  trading  with  these  territories  and  prevents  the  data  being  declared 
twice. 

2.5  Data sources 

Intra-EU trade statistics 

2.5.1 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Articles 5, 9 and 10 

Commission Regulation (EC) No 1982/2004, Articles 4, 5, 15, 16, 18, 23 and 24 

Intrastat declaration 
175. Intrastat  declaration  and  format.  The  Intrastat  declaration  is  the  standard  data  source  in  the 
INTRASTAT  data  collection  system,  used  for  the  provision  of  statistical  information  about  trade  in 
Community  goods.  Each  Member  State  organises  independently  how  Intrastat  data  are  supplied  by  the 
PSIs; however electronic data transmission is promoted by Eurostat and by the Member States. 
176. The  format  of  Intrastat  declarations  may  not  be  the  same  in  each  particular  Member  State.  The 
graphic form of  the declaration is developed individually by each Member State, as well as the way of 
uploading the declaration into the system. The declaration is used to submit information to the Intrastat 
system or to transmit corrections of the previously transmitted data. NSAs may require PSIs to submit a 
so-called  ‘Null  Intrastat  declaration’  if  they  did  not  carry  out  trade  transactions  during  the  reporting 
period. 
177. Mandatory data which have to be collected by the NSAs and optional information which may also 
be collected for national needs are defined in the basic regulation on intra-EU trade statistics. 

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Mandatory data elements 
—  The  individual  identification  number  allocated  to  the  party  responsible  for 
providing information in accordance with Article 214 of Directive 2006/112/EC 

—  The reference period 
—  The flow (arrival, dispatch) 
—  The commodity, identified by the eight-digit code of the Combined Nomenclature 
—  The Partner Member State 
—  The value of goods 
—  The quantity of the goods 

—  The nature of transaction 

Optional data elements 
—  The  identification  of  the  goods,  at  a  more  detailed  level  than  the  Combined 

Nomenclature 

—  The Country of origin, on arrival 
—  The region of origin, on dispatch, and the region of destination, on arrival 
—  The delivery terms 
—  The mode of transport 
—  The statistical procedure 

Types of Intrastat declaration 
178. The standard Intrastat declaration covers all required information which shall be collected by the 
responsible parties. However, with a view to reducing the burden of reporting on PSIs the simplification 
of the Intrastat system was introduced. A prime means of reducing the burden on PSIs is to limit the data 
elements  on  the  Intrastat  declarations.  Therefore  some  Member  States  introduced  simplified  Intrastat 
declarations which make it easier for the PSIs to provide information to the NSAs. 

Data provided by tax administration 
179. The  responsibility  for  the  collection/compilation  of  intra-EU  trade  statistics  varies  across  Member 
States. In some Member States it is the sole responsibility of either  the statistical office, customs or tax 
administrations,  while  in  others  it  is  a  joint  responsibility.  However  tax  administrations  in  all  Member 
States are obliged to provide the NSAs with information collected within the VAT system. 
180. Usually  the  tax  administration  has  the  responsibility  for  maintaining  a  VAT  register.  This  is  an 
important  source  of  data  as  it  identifies  who  might  be  required  to  make  Intrastat  declarations  and  also 
helps keep track of VAT ID numbers. 
181. Other tax sources of data used in the compilation of intra-EU trade are VAT returns and VIES data. 
In line with the regulations on intra-EU trade statistics, the national tax administrations are required to 
provide  statistically  relevant information  to  the  NSA.  VAT  and  VIES  data  can  be  used  as  a  source  for 
statistical  estimations  of  trade  below  thresholds  and  non-response.  They  are  also  useful  in  terms  of 
assessing the quality of Intrastat declarations. 

Data provided by Customs 
182. Although the major part of information on intra-EU trade is collected on Intrastat declarations, some 
intra-EU movements are covered by customs declarations for example:  

  goods for processing moving between two Member States (e.g. inward processing). 

In addition to the declared EU partner country code, NSAs should check other data elements 
— in particular, the CPC in Box 37 — to establish particulars of the actual movement taking 
place.  ANNEX  3:  Allocation  of  customs  procedure  to  type  of  trade  and  statistical  procedure 
identifies the CPCs most likely to be associated with such movements (although there may be 
variations used at a national level) and which should be recorded under intra-EU trade. 

  movements to/from or between special territories which are inside the customs, but outside the 

fiscal territory of the EU. 
○  Special  territories  which  do  not  have  their  own  ISO  country  code  (e.g.  Aland  Islands, 

Livigno, etc.) so the country code of the ‘mother’ Member State is used. 

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Whilst  reviewing  the  other  data  elements,  NSAs  should  pay  particular  attention  to  the 
information declared in the first sub-division of SAD-Box 1 (Declaration). In this example, 
the code ‘CO’ should be used to distinguish these movements and establish the accuracy of 
the declaration. 

○  Special territories which have their own ISO country code (e.g. Guadeloupe, Canary Islands, 

etc.). 
For these particular types of special territories, NSAs should consider changing the declared 
country  code  to  that  of  their  ‘mother’  Member  State  and  record  the  movement  in  intra-EU 
trade statistics. 

Example 19  
A)  Goods  undergoing  inward  processing  in  Germany  and  then  sent  to  France  would  be  covered  by  a  customs 
declaration  in  France  using  CPC  4054xxx  (if  entering  free  circulation)  or  5154xxx  (if  being  further  processed).  Such 
movements should be recorded as dispatch/arrival between Germany and France. 
B)  Goods  sent  from  the  Aland  Islands  to  the  United  Kingdom  should  be  covered  by  a  customs  declaration.  The 
appearance of an EU country code as the ‘partner’ country together with ‘CO’ declared in Box 1 (Declaration) indicates 
that this movement should be recorded (for statistical purposes) as an Intrastat dispatch/arrival between Finland and the 
UK. 
C)  Goods  sent  from  Guadeloupe  to  the  Netherlands  should  be  covered  by  a  customs  declaration. Where  the  country 
code for the Special Territory (GD) is used, together with ‘CO’ declared in Box 1 (Declaration), such movements should 
be recorded (for statistical purposes) as an Intrastat dispatch/arrival between France and the Netherlands. 

183. There are also other cases where there is suspicion that an EU country code has been used on the 
customs  declaration  in  error,  and  where  the  customs  declaration  should  be  subjected  to  further  checks. 
This will include, for example, where the customs declaration has a Country of Origin of a third country 
and the Country of Dispatch/Destination of an EU country for no apparent reason. 
184. National  Customs  are  required  to  provide  NSAs  with  any  information  related  to  intra-EU  trade 
but declared on customs declarations at least once a month. NSAs can usually identify such movements 
by the CPC(s), cross-referred to other relevant data elements. 
185. NSAs  should  consider  adopting  a  national  process  linked  to  the  CPCs  to  identify  intra-EU 
movements covered by customs declarations to ensure that they are correctly recorded in intra-EU trade, 
rather than extra-EU, once the data is received from the customs authority. 
186.  As an exception to the above, some customs simplifications (e.g. Single Authorisation) permit the 
intra-EU  movement  of  non-Community  goods  without  the  need  for  a  customs  declaration.  These 
simplifications  are  restricted  to  ‘approved’  operators  only.  Unfortunately,  the  lack  of  a  customs 
declaration  prevents the  usual identification by  NSAs of  such  intra-EU movements.  In  order to  capture 
this  trade,  NSAs  are  required  to  ensure  that  these  movements  are  reported  on  Intrastat  declarations; 
otherwise missing data on intra-EU movements of non-Community goods between Member States shall 
be estimated.  
187. National  Customs  are  required  to  provide  NSAs  with  any  available  information  to  identify  the 
person  who  carries  out  dispatches  and  arrivals  of  goods  under  inward  processing  or  processing  under 
customs  control.  This  may  be  information  on  operators  to  whom  national  Customs  has  issued  Single 
Authorisation, on consignees/consignors from notifications exchanged between customs offices involved 
etc. In case of Single Authorisation for inward processing or processing under customs control, the 
Customs authority in the participating Member State holds the information of the authorisation which was 
issued  in  the  supervising  Member  State  and  has  therefore  at  its  disposal  the  information  on  the  parties 
involved  in  the  intra-EU  movements  of  non-Community  goods.  NSAs  may  also  have  to  issue  special 
guidance through their customs authority to ensure that the operators understand the requirement to report 
such dispatches and arrivals on their Intrastat declaration. 

2.5.2  Extra-EU trade statistics 

Customs declaration 

Regulation (EC) No 471/2009 of the European Parliament and of the Council, Articles 4 and 7 
Commission Regulation (EU) No 92/2010, Article 1 
188. Customs declaration and format. If not stated otherwise, the customs declaration is the standard 
data  source  from  which  the  statistical  data  shall  be  obtained  for  the  compilation  of  EU  extra-EU  trade 

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The framework  2 

statistics. This provision explicitly gives no leeway to collect the data directly from traders or operators. 
Under the present Community Customs Code(1), the customs declaration may be available in paper form 
Single Administrative Document or alternatively and most commonly, in electronic format. Under the 
UCC(2), the electronic declaration will become the default type.  
189. Types of declarations. On the full declaration, all relevant customs and statistical data have to be 
declared at the time of importation or exportation. Under certain simplifications granted by Customs to 
operators  (e.g.  simplified  customs  declaration),  only  a  limited  dataset  needs  to  be  declared.  The  full 
dataset  will  be  delivered  later  by  means  of  a  supplementary  declaration  containing  the  data  for  all 
imports/exports of a previous period (usually the previous month). 
190. Customs decisions. It is important to underline that ‘amendments or changes to statistical data 
resulting from decisions by Customs(3) pertaining to them’ are an integral part of the statistical data 
source. This means that once Customs has accepted the declaration but has assessed the data differently 
than  declared (e.g.  a  different  product  code)  this  new  assessment  ‘replaces’  the  initial data.  The  aim  of 
this provision is not simply to collect the declared data but also to include customs control based findings, 
request  information  on  the  import  preferences  actually  granted  by  Customs(4)  and  identify  declarations 
which were cancelled or invalidated, thus enhancing the relevance of the statistical data. Therefore, in the 
case  of  transaction  based  customs  controls  (= at  the  moment  of  the  goods’  movement),  Customs  are 
obliged  to feed  the  ‘changed’  data  into  the  data  transmission to  the NSA  chain. In  the  case of  customs 
decisions following post clearance controls (e.g. audits) Customs must ensure that the ‘changed’ data are 
sent to the NSA as corrections of the initially transmitted data. 
191. Member States may arrange that only those corrections which have an effect on the relevance of the 
revisions  of  the  statistical  data  are  transmitted  by  Customs  e.g.  Customs  would  not  need  to  send 
corrections  in  2015  for  audited  imports  relating  to  2011.  If  the  transmission  of  ‘changed’  data  would 
entail a disproportionate burden on national administrations, a threshold linked to the nationally applied 
statistical threshold could be applied.  

Data sources in case of simplifications applied by Customs 
192. Customs  declaration  and  location  of  the  goods.  As  a  general  rule  and  notwithstanding  specific 
simplifications  or  waivers  to  present  the  goods,  a  customs  declaration  has  to  be  lodged  to  the  same 
customs  office  as  the  one  to  which  the  goods  have  been  presented.  As  a  consequence,  the  data 
transmission  for  such  declarations  from  the  national  Customs  to  the  national  NSA  concerns  goods 
presented on this Member State's territory. 
193. Use of other data sources for the compilation of  national statistics. The customs simplification 
SASP  allows  the  Member  State  where  the  goods  are  presented  to  be  different  from  the  one  where  the 
customs declaration is lodged. As a consequence of such dissociation, the Member State where the goods 
are presented/located does not have available the customs declaration with the relevant statistical dataset. 
194. It  poses  a  problem  for  the  compilation  of  the  national  trade  statistics  of  this  Member  State,  as  a 
default  data  source  is  missing.  To  compensate  for  this  lack  it  may  use  other  data  sources  it  considers 
appropriate. However,  as  soon  as  a general customs  data  exchange  system  between  Member  States has 
been implemented, the possibility to use such other data sources will cease to apply. In the meantime and 
considering technical, administrative and language aspects there are two basic possibilities: 

  Direct collection from the trader. For a direct reporting system, it is already necessary for the 
customs authorities concerned to cooperate in the authorisation process(5) with the NSAs of the 
Member  States  where  the  goods  will  be  located  at  the  time  of  the  release  into  the  customs 
procedure.  Customs  administrations  are  encouraged  to  grant  the  SASP  authorisation  for 
traders only when the NSAs concerned have agreed. 

(1)  Council Regulation (EEC) No 2913/92. 
(2)  Regulation (EU) No 952/2013 of the European Parliament and of the Council. 
(3)  Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 2(f). 
(4)  Commission Regulation (EU) No 92/2010, Article 2(2)(p). 
(5)   Commission Regulation (EEC) No 2454/93, Article 253(h). 

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  Bilateral agreement on a statistical data transfer between the Member States involved. As 
direct reporting obviously entails additional administrative burden on the enterprises involved, a 
more favourable solution would be to obtain the statistical data directly from the other Member 
State's  administration.  For  such  statistical  data  transfer,  it  is  necessary  for  the  Member  States 
involved  to  agree  beforehand  on  such  data  exchange,  either  between  the  national  customs 
authorities  with  subsequent  forwarding  of  the  data  to  the  respective  NSA  or  a  transmission  of 
data directly between the NSAs involved. 

195. When  using  ‘other  data  sources’.  In  order  to  avoid  duplication  of  data  at  EU  level,  the  Member 
State  must  pay  utmost  attention  to  exclude  the  data  collected  directly  from  traders  from  the  EU  trade 
statistics  data  to  be  submitted  to  Eurostat.  Extra-EU  trade  data  should  be  transmitted  to  Eurostat 
exclusively  based  on  the  information  collected  from  genuine  customs  declarations  actually  logged  at 
national Customs. 
196. Data sources for specific goods or movements. In the case of recording trade in specific goods or 
movements,  such  as  trade  in  vessels,  aircraft,  gas,  electricity  etc.  other  data  sources  may  be  used 
whenever  information  on  customs  declarations  is  not  complete  or  the  transaction  is  not  recorded  by 
Customs. All existing administrative data sources should be analysed and used for statistical purposes. 

2.5.3  Data sources for specific goods or movements 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 5 

Commission Regulation (EC) No 1982/2004, Articles 15 — 24 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Articles 4(1) and 4(4) 

Commission Regulation (EU) No 113/2010, Articles 17 — 25 

197. Specific  goods  or  movements  are  goods  or  transactions  which  by  their  nature  call  for  specific 
provisions. Therefore ITGS legislation foresees a possibility for NSAs to use additional data sources for 
all  specific  goods  or  movements  alongside  the  traditional  ones  —  Intrastat  and  customs  declarations. 
Specific  movements  (e.g.  industrial  plants,  staggered  consignments,  etc.)  for  which  special  provisions 
were introduced in the legislation with the goal to simplify reporting procedures for the traders, normally 
do  not  require  additional  data  sources  to  be  used.  However  specific  goods  or  movements,  for  which 
special provisions were introduced due to the methodological difficulties  in collecting information (e.g. 
vessels  and  aircraft,  sea  products,  electricity  and  gas,  etc.)  need  to  use  additional  data  sources.  This  is 
inevitable in order to ensure good coverage of the information collected. 

Industrial plants 
198. Intrastat  and  customs  declarations  are  the  data  source  from  which  statistical  information  for 
industrial  plants  shall  be  obtained  for  the  compilation  of  trade  statistics.  According  to  the  national 
provisions,  PSIs  may  ask  NSAs  to  allow  them  to  apply  the  simplified  procedure  for  the  declaration  of 
industrial plant. If the NSA agrees, the PSI should use the standard Intrastat and customs declaration and 
complete it in line with the national requirements for the recording of industrial plants. 

Staggered consignment 
199. The  Intrastat  and  customs  declaration  (if  national  Customs  apply  this  simplification)  is  the  data 
source  from  which  statistical  information  for  staggered  consignments  should  be  obtained  for  the 
compilation of trade statistics. Data on staggered consignments may be collected from PSIs only once, in 
the month when last consignment took place. 

Vessels and aircraft 
200. Intrastat and customs declarations may be a data source for statistical data on  trade in vessels and 
aircraft. However due to the difficulties in collecting information on trade in these specific goods, other 
data  sources  which  allow  economic  operators  to  be  identified  and  contacted  are  needed.  All  available 
information  e.g.  ships  and  aircraft  registers,  information  from  classification  companies,  etc.  should  be 
used in order to ensure completeness of information. Moreover, NSAs in Member States involved are 
encouraged to cooperate and to share information about this type of transaction. 

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201. Access  to  international  databases  on  vessels  and  aircraft  may  provide  very  useful  information. 
However, the Member States must be aware of the limitations of these databases, so they may simply act 
as another trigger for further investigation into transactions. 
202. National authorities which are responsible for maintaining vessels and aircraft registers at the 
request of the national statistical authorities are required to provide NSAs with all information available 
in  the  registers.  The  frequency  and  other  modalities  of  data  exchange  between  national  authorities  are 
decided individually by each Member State. 

Example 20  (from the practice of Poland) 
Vessels 
Data  are  provided  from  the  Polish  Permanent  Vessel  Register  maintained  by  Maritime  Chambers  under  the  District 
Courts in Gdansk and Szczecin. 

Aircraft 
Data are provided from the Civil Aircraft Register of Poland maintained by the Civil Aviation Office. 
Information supplied from registers contains the following data elements: 

—  Description of the goods and their CN code; 
—  Partner country; 
—  Carrying capacity in tones (ct/l) for vessels; 
—  Maximum take-off weight (MTOW) for aircraft; 
—  The month of transfer of economic ownership; 
—  Information on address of the providers and their ID (tax number and National Official Business Register Number 

        called REGON); 

—  The date of registration in the vessels/aircraft registers. 

Data elements are received from registers quarterly. 

Sea products 
203. The data sources which may be used to compile statistics on the trade in sea products are Intrastat 
declarations,  if  requested  according  to  the  national  instructions,  customs  declarations  and  all  kinds  of 
alternative data sources. The ITGS regulations allow the NSAs to request any type of information from 
other national administrations which would allow arrivals/imports and dispatches/exports of sea products 
to be correctly recorded. 

Example 21  (from the practice of Poland) 
The  data  source  for  the  sea  products  (e.g.  fish  acquired  by  the  national  vessels  on  the  high  seas)  is  the  information 
provided by the agency which monitors fishing. The Polish NSI is supplied with the data by the Fishery Division of the 
Ministry of Agriculture and Rural Development. Data elements are transmitted to the statistics in electronic form. 
Information supplied by the Ministry of Agriculture and Rural Development contains the following data elements: 

—  Description of the goods and their CN 8-digit code; 
—  Partner country; 
—  Net mass (kg); 
—  Statistical value; 

   — The data from the Ministry are received monthly. 

Electricity and gas 
204. The  data  on  trade  in  electricity  and  gas  may  be  collected  from  different  data  sources:  Intrastat  or 
customs declarations, information provided from grid operators, energy statistics etc. The trade statistics 
should record only physical cross-border movements; however this may differ from the commercial trade 
flows.  The  ITGS  regulations  allow  NSAs  to  request  any  type  of  information  from  other  national 
administrations  or  companies  (e.g.  grid  operators)  which  would  allow  them  to  correctly  record 
arrivals/imports and dispatches/exports of electricity and gas. 

Example 22  (from the practice of Poland) 
The  data  on  electricity  are  obtained  from  the  statistics  of  the  Ministry  of  Economy  under  which  the  Energy  Market 
Agency  S.A.  (ARE  S.A.),  which  collects  the  data  from  grid  operators,  is  established.  The  administrations  responsible 
register trade flows with neighbouring countries only. 
The  data  on  supplementary  units  in  1 000  kWh  are  provided  monthly  and  are  broken  down  by  partner  countries. 
Information  on  electricity  prices  in  foreign  trade  is  supplied  quarterly.  The  monthly  data  on  turnover  of  electricity  are 
estimated. 
The data on gas are obtained from two data sources: the data on supplementary units in gross calorific value TJ from 
ARE S.A., the data on quantity in m3 broken down by partner countries directly from trading companies. 
The data are received monthly. 

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Military goods 
205. The basic data sources for military goods in Member States are the standard Intrastat and customs 
declarations.  However,  in  the  case  of  trade  which  constitutes  military  secrecy  and  consequently  due  to 
security measures, the data  may be supplied  through special channel or using specific procedure which 
are defined by the national administrations of each individual Member State. 

Goods delivered to vessels and aircraft 
206. For this type of goods, information is collected on customs declarations or Intrastat declarations if 
requested according to the national instructions. 

Motor vehicle and aircraft parts 
207. These  specific  goods  are  related  to  the  simplification  of  the  procedures  which  traders  may  use  to 
provide Intrastat information and does not require additional data sources. 

Waste products 
208. Waste  products  are  included  in  trade  statistics  on  the  basis  of  the  records  of  customs  or  Intrastat 
declarations. 

Goods to or from offshore installations 
209. Goods to or from offshore installations are normally included in trade in goods statistics on the basis 
of the records of customs or Intrastat declarations if requested according to the national instructions. In 
practice, Member States have not as yet defined additional data sources. 

Spacecraft 
210. For  the  recording  of  trade  in  spacecraft,  the  primary  data  source  remains  Intrastat  declaration  if 
requested  according  to  the  national  instructions  and  customs  declarations.  However  the  implementing 
provisions  foresee  the  possibility  of  using  additional  data  sources  which  may  be  available  at  national 
administrations or even at international organisations. These could be international registers of satellites 
or  any  other  data  sources  which  would  allow  the  transfer  of  the  economic  ownership  of  the  finished 
spacecraft from a person in the Member State/country of construction to the new economic owner of the 
spacecraft to be identified.  
211. It is necessary to distinguish between movements of the spacecraft and its launcher. As the launchers 
(e.g. Soyouz, Vega or Ariane rocket) should be treated as means of transport, their launching into space 
shall  be  excluded  from  ITGS(1)  while  all  transactions  (imports  and  exports,  whether  final  or  for 
processing)  linked  to  the  construction  of  the  launcher  shall  follow  standard  ITGS  rules.  Therefore 
Intrastat and customs declarations are the source of information for these transactions. 

2.6  Data collection process 

2.6.1 

Intra-EU trade statistics 

Direct data collection from economic operators 

Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 5(1) 

212. Member States collect monthly data from parties responsible for providing the information. This is 
the principle data source for intra-EU trade statistics. The data collection system is called Intrastat. Often 
the term ‘Intrastat’ is used for the entire system of EU statistics relating to the trading of goods between 
Member States. However, this is not correct as the ‘Intrastat system’ is only applicable to data collected 
from PSIs. Article 5(1) of Regulation (EC) No 638/2004 defines the ‘Intrastat system’ and should be read 
in  conjunction  with  the  scope  of  trade  defined  in  Article  3(2)(a)  and  3(3)(a)  of  the  same  regulation.  In 
general, trade information collected from PSIs corresponds to the trade defined in those paragraphs. 

(1)  Commission Regulation (EC) No 1982/2004, Annex I, point (i). 
Commission Regulation (EU) No 113/2010, Annex I, point (i). 

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213. Some  movements  of  non-Community  goods  between  Member  States  (such  as  goods  placed  under 
the inward processing customs procedure or moving between Member States under Single Authorisation) 
have to be recorded in intra-EU trade statistics although these goods have not entered free circulation (in 
the cases of Article 3(2)(b) and 3(3)(b). These movements may not be recorded using the standard data 
source — the Intrastat or custom declaration. In these cases NSAs are required to estimate missing data. 

Parties responsible for providing Intrastat information 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 7 

214. Intrastat  data  are  to  be  collected  from  all  taxable  persons  (defined  in  Title  III  of  Directive 
2006/112/EC)  who  carry  out  intra-EU  trade  operations  and  exceed  Intrastat  exemption  thresholds  (see 
chapter  6. Thresholds  within  Intrastat  system).  The  regulation  on  intra-EU  trade  statistics  establishes  a 
close  link  between  the  PSI  and  the  taxable  person,  which  is  very  important  to  ensure  statistical  data 
quality  and  completeness.  The  regulation  indicates  that  the  party  responsible  for  providing  Intrastat 
declarations  is  a  taxable  person  as  defined  in  Title  III  of  the  Council  Directive  2006/112/EC  (VAT 
Directive). 
215. Definition  of  taxable  person.  According  to  Article  9  of  the  VAT  Directive  the  ‘Taxable  person’ 
shall mean any person who, independently, carries out in any place any economic activity, whatever the 
purpose or results of that activity. However employed persons are excluded from VAT. 
216. In  addition,  any  person  who,  on  an  occasional  basis,  supplies  a  new  means  of  transport,  which  is 
dispatched or transported to the customer by the vendor or the customer, or on behalf of the vendor or the 
customer,  to  a  destination  outside  the  territory  of  a  Member  State  but  within  the  territory  of  the 
Community, shall be regarded as a taxable person. 
217. Definition of ‘economic activity’. Any activity of producers, traders or persons supplying services, 
including  mining  and  agricultural  activities  and  activities  of  the  professions,  shall  be  regarded  as 
‘economic  activity’.  The  exploitation  of  tangible  or  intangible  property  for  the  purposes  of  obtaining 
income therefrom on a continuing basis shall in particular be regarded as an economic activity. 
218. Liability for Intrastat. In the case of dispatches or arrivals a taxable person, i.e. PSI has to provide 
an Intrastat declaration if he: 

  has  concluded  the  contract,  with  the  exception  of  transport  contracts,  giving  rise  to  the 

dispatch/arrival of goods or, failing that; 

  dispatches, takes delivery or provides for dispatch or delivery of the goods or, failing that; 
 

is in possession of the goods which are the subject of the dispatch or delivery. 

219. The PSI who fails to submit his Intrastat declaration or provides incorrect information shall be liable 
to penalties under the penalty system which the NSAs are required to establish. As every Member State 
may organise  the way Intrastat data is supplied, according to their national administrative arrangement, 
the penalty system will depend on the arrangement, particularly if the statistical  system is merged with 
other administrative systems. 
220. Third parties. According to Article 7(2) of Regulation (EC) No 638/2004 the PSI may transfer to a 
third party (e.g. external accounting offices, forwarding agents, other specialised fiscal service companies 
etc.) the task of providing his Intrastat declarations to the NSA. However this transfer does not remove 
the responsibility of the PSI for providing accurate and timely data. Moreover the PSI is responsible for 
proving the correctness of the provided statistical information, at the request of the NSA.(1) 
221. Due to the complex trading schemes it is sometimes difficult to define the PSI responsible for  the 
provision of Intrastat declarations. If the legal owner of the goods is not present in the Member State of 
arrival  or  dispatch  then  other  taxable  persons  responsible  for  the  physical  presence  of  the  goods  in  the 
Member State are obliged to provide the Intrastat declarations instead. 

(1)  Commission Regulation (EC) No 1982/2004, Article 4. 

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Example 23  
A)  Processing  under  contract  involving  several  processing  companies:  There  is  a  risk  of  double  counting. 
Moreover, it is difficult to trace these transactions as they are not reported on VAT returns for supply or acquisition of 
goods. 
B) Warehouses carrying out stocking and distribution services for a number of clients: The warehouse-keeper is 
responsible for reporting arrivals and dispatches if the legal owner (trader) of the goods is not established in the Member 
State. It creates the danger of double counting, i.e. the warehouse-keeper and the trader might both report. 
C) Financial institutions (e.g. a bank or finance house) buying goods for clients (e.g. cars, large machinery): In 
cases where the bank concludes the contract giving rise to the supply of goods on behalf of its client, it may be difficult 
to establish who is responsible for the Intrastat report.  There is a danger of double counting or misreporting, i.e. both 
bank and client provide Intrastat declarations or no one provides them. 

222. VAT registration. In practice nearly all taxable persons are registered for VAT and they make up 
the  basic  population  for  the  Intrastat  survey.  However VAT  registration is not the  only  criterion which 
obliges traders to report for Intrastat.  
223. In general the rules for VAT registration are very strict. The entity shall register for VAT if he is in 
business  (and  therefore  is  considered  as  ‘taxable’  person)  and  the  business  activities  are  above  VAT 
registration threshold in the Member State where activity takes place. Anyone can be registered for VAT 
purposes: 

  an individual; 
  a partnership; 
  a company; 
  a club; 
  a farmer; 
  an association; 
  a charity; 
  any  other  organisation  or  group  of  people  acting  together  under  a  particular  name,  such  as  an 

educational or health institution, exhibition, conference, etc.; 

  a trust; 
  a local authority. 

224. There are two exceptions when the business may not need to register for VAT: 

 
 

if his sales of goods and services are exempt from VAT; 
if his sales of VAT-liable goods/services fall below a certain annual limit.  

These limits (‘thresholds’) vary from country to country. In some countries (e.g. the Netherlands, Spain, 
Sweden), there is no limit and businesses must register as soon as they make any taxable transaction. 
225. Where there is a registration limit and the total value of taxable sales in the year falls below it, the 
business  may  be  exempt  from  VAT  and  do  not  charge  VAT.  However  the  business  can  register 
voluntarily, in which case he must charge VAT. The limit applies only to businesses established in that 
country and not to businesses based abroad. 
226. There are special VAT schemas, whose applications imply registration or non registration for VAT 
purposes.  Only  distance  sales,  sales  of  new  means  of  transport  and  flat  rate  farmers  are  not  obliged  to 
register for VAT if they comply with certain conditions. However, in practice, the very low thresholds for 
obligatory VAT registration in the latter cases and other restrictions ensure that there is no missing data in 
Intrastat  reporting.  Intrastat  thresholds  in  all  Member  States  (except  Malta)  are  always  higher  than  any 
VAT threshold.   
227. Non-taxable legal persons. States, regional and local government authorities, health boards, public 
hospitals, educational establishments and other similar bodies governed by public law shall be regarded as 
non-taxable persons in respect of the activities or transactions in which they engage as public authorities, 
even  where  they  collect  dues,  fees,  contributions  or  payments  in  connection  with  those  activities  or 
transactions.  However,  they  shall  be  considered  as  taxable  persons  in  respect  of  those  activities  or 
transactions  where  their  treatment  as  non-taxable  persons  would  lead  to  significant  distortions  of 
competition (e.g. a hospital running a canteen for staff and visitors). 
228. Non-taxable legal persons are obliged to register for VAT in two cases: 1) when they are regarded as 
taxable  persons  and  2)  when  the  total  value  of  their  intra-EU  acquisitions  exceeds  the  fiscal  threshold 

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defined by national tax administrations in Members States of arrival (the threshold may not be less than 
EUR 10 000)(1). 
229. In the second case, as they are registered for VAT, they are included in the population of Intrastat 
operators. However, if these persons only buy goods from another Member State and thus they are not 
considered taxable, they may refuse to report Intrastat information. Then NSAs are required to estimate 
their intra-EU trade. 
230. Private individuals, in general, are not considered to be taxable persons and are not registered for 
VAT. However a private individual who supplies or acquires(2), on an occasional basis, a new means of 
transport to/from another Member State, in line with the VAT Directive, is regarded as a taxable person 
and  is  obliged  to  provide  an  Intrastat  declaration  when  the  exemption  threshold  is  exceeded.  In  other 
words,  all  taxable  persons,  regardless  of  being  VAT  registered  or  not,  are  obliged  to  provide  Intrastat 
declarations whenever the exemption threshold for dispatches or arrivals defined by the national statistical 
authorities is exceeded. 
231. When a taxable person supplies goods to a non-taxable person in another Member State, the supplier 
of goods, being a PSI, should fill in an Intrastat declaration on dispatch. However his counterpart in the 
Member State of arrival as a non-taxable person does not need to report arrivals. As only one side of the 
transaction  may  be  reported,  there  may  be  an  asymmetry  in  the  intra-EU  trade  of  the  Member  States 
involved if an arrival is not estimated. 
232. Therefore there are three conditions for Intrastat reporting: 

  Physical movement of goods from one Member State to another: 

○  the majority of which is caused by intra-EU trade operations related to supply and acquisition 
of goods. In order to raise awareness among intra-EU operators of their statistical obligation, 
the  national  tax  administration  is  required  to  inform  those  VAT  registered  of  their 
possible obligation to provide Intrastat information; 

○  humanitarian help and other transfers of goods without financial compensation; 
○  dispatch and arrival of goods for processing; 
○  dispatch or arrival of goods on leasing conditions; 
○  dispatch  or  arrival  of  the  following  goods  defined  by  legislation  as  specific  goods  or 
movements:  industrial  plant,  staggered  consignments,  motor  vehicle  and  aircraft  parts, 
electricity  and  gas,  military  goods  (the  criterion  of  physical  movement  of  goods  from  one 
Member  State  to  another  for  these  goods  is  applicable  as  there  are  not  specific  provisions 
defining the arrival/dispatch of such goods). 

  The person responsible for the movement of the goods can be considered as a ‘taxable person’ in 

line with the VAT Directive’s definition; 

  The PSI exceeds exemption thresholds for Intrastat reporting. 

233. Cases  when  a  taxable  person  related  to  the  supply  and  acquisition  of  goods  does  not  need  to  be 
registered for VAT: 

  When  the  annual  value  of  supply  or  acquisition  of  goods  does  not  exceed  the  exemption 
threshold, which normally is very low (EUR 10 000). The VAT Directive allows each Member 
State  to  apply  exemptions  or  graduated  relief  for  very  small  enterprises.  These  small  taxable 
persons have no VAT ID number (See also paragraph 225); 

  States,  regional  and  local  government  authorities,  health  boards,  public  hospitals,  educational 
establishments and other similar bodies governed by public law when they act as a non-taxable 
person; 

  When he/she appoints a tax representative; 
  Private individuals occasionally supplying new means of transport; 

(1)  Council Directive No 2006/112/EC, Article 3(2)(a). For more information see: 

http://ec.europa.eu/taxation_customs/resources/documents/taxation/vat/traders/vat_community/vat_in_EC_annexI.pdf 

(2)  Directive 2006/112/EC, Article 9(2). 

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  Farmers under the special VAT scheme. 

234. Who in practice is out of scope of Intrastat reporting? 

  Small and medium traders with annual trade values below exemption thresholds; 
  Private  individuals,  farmers,  as  their  trade  in  most  cases  never  exceeds  Intrastat  exemption 

thresholds; 

  Non-taxable legal persons acting as public authorities; 
  Distance seller below Intrastat exemption thresholds. 

235. Non-established trader is a trader who makes taxable supplies or acquisitions in a Member State 
but he is not resident in that Member State, does not have a place of business there, is not registered in the 
statistical business register of that Member State, is not incorporated under that Member State law and. 
236. Normally all traders supplying or selling goods in Member States other than the one in which they 
are established have to register for VAT purposes in that Member State. However they do not need to be 
registered  in  the  statistical  business  register.  Non-established  traders  have  the  same  obligations  as 
established traders concerning the Intrastat system. In the case of intra-EU supplies or acquisitions, they 
have to provide national tax administrations with VAT returns and to submit Intrastat declarations. 
237. In practice to collect information from non-established traders is more complicated as they do not 
have  a  physical  presence  in  the  reporting  Member  State.  However  in  most  cases  such  non-established 
traders appoint tax representatives who are legally responsible for furnishing Intrastat declarations. NSAs 
are  required  to  estimate  the  trade  of  foreign  established  PSIs  on  the  basis  of  their  fiscal  VAT 
declarations if they do not declare for Intrastat in spite of all the efforts of the national authorities. 
238. Tax  representatives,  depending  on  the  rules  of  national  legislation,  normally  are  liable  together 
with the non-established taxable person for rendering returns and paying taxes. They may be personally 
liable in respect of any failure to secure their principal’s compliance with obligations or liability, which is 
imposed jointly and severally on both of them. A non-established trader may opt to appoint an agent to 
act on his behalf, who normally is not liable for debts incurred by the taxable person. 
239. Tax  groups.  Two  or  more  companies  or  limited  liability  partnerships  may  register  as  a  single 
taxable person — or VAT group — if they meet the following criteria: 

  each body has its principal or registered office in the reporting Member State; 
 

they are closely bound to one another by financial, economic and organisational links. 
240. A VAT group is treated in the same way as a single taxable person registered for VAT on its own. 
The  registration  is  made  in  the  name  of  the  'representative  member'.  The  representative  member  is 
responsible for completing and submitting a single VAT Return and making VAT payments or receiving 
VAT refunds on behalf of the group. However, all the members of the group remain jointly and severally 
liable for any VAT debts. 
241. In  this  case  the  representative  member  should  be  responsible  for  providing  the  complete  Intrastat 
information for all subordinated entities. The representative member may transfer the task of reporting for 
Intrastat to the subordinated units according to Article 7(2) of  Regulation (EC) No 638/2004. However, 
such  transfer  in no  way reduces  the  representative  member’s  responsibility  for  the  correct overall  trade 
declaration of all members of the tax group. 
242. Monitoring of tax groups brings additional problems to NSAs, especially when producing statistics 
on trade by enterprise characteristics, as one tax group might include enterprises with different economic 
activities, thus distorting the quality of these statistics. Therefore the NSA could agree with the tax group 
that the Intrastat declarations would be provided by group members if they have separate VAT numbers. 
However the NSA should take into account, that only one VAT return will be provided for all tax group 
members and this will impact Intrastat and VAT data comparisons. 
243. As legally all members of the tax group are jointly liable for VAT payments and debts, therefore in 
Intrastat  the  tax  group  representative  member  should  be  considered  as  the  responsible  PSI  for  Intrastat 
reporting in spite of the fact that Intrastat declarations, in line with prior agreement of the NSA, may be 
furnished by individual members, i.e. tax group data will be used in order to determine if the tax group is 
above  or  below  exemption  thresholds  and  the  tax  group  will  be  liable  for  penalties  in  the  case  of  non-
response. 

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Role and functioning of the Intrastat register 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 8 

Commission Regulation (EC) No 1982/2004, Articles 5 and 6 

244. The essential function of the Intrastat register which NSAs are required to set up and manage is the 
maintenance  of  an  up-to-date  list  of  intra-EU  operators  with  their  company  identification  data.  This 
information is used: 

 
 
 
 

to identify companies who may be required to provide Intrastat declarations; 
to ensure the timely collection of statistical information; 
for quality checks and data analysis; 
for estimates of below threshold trade and partial and non-response. 

245. National Statistical Institutes are required to link the statistical business register to the register of 
intra-  and  extra-Community  operators.  Therefore  an  adequate  structure  should  be  implemented  that 
allows ease and fast linkage. 
246. The content of the register is therefore much wider than simply a list of PSIs with their identification 
data  and  data  on  their  intra-EU  trade.  The  register  should  make  available  information  on  all  natural  or 
legal persons who trade with other Member States and information retrieved from the statistical business 
register and other data needed for the operation of Intrastat. Moreover the information on companies who 
are not liable to report for Intrastat and companies who trade only with non-member countries should be 
made available. 
247. Each Member State must decide how to organise the PSI register, however it is advisable that the 
following information should be easily available for the good functioning of the register: 

 

identification  data  about  the  company:  ID  numbers  (VAT  ID  number,  ID  number  used  for 
statistical purposes, other ID numbers), name, address, phone, fax, e-mail, etc.; 

  status  and  demography  of  the  company:  operating  or  not  operating,  liquidated,  bankrupted, 
information on reorganisations, groups, mergers, take-overs and other information important for 
monitoring a business; 

  date of entry into the register (once an entry for a PSI has been made, it should not be deleted), 

other relevant dates; 

  main  and  secondary  activities  of  the  company  (according  to  the  statistical  classification  of 
economic activities), organisational set up, size of the company, number of employees, etc.; 
  other indicators describing the profile of the company: only intra-EU, only extra-EU, intra- and 
extra-EU  operator,  main  activity  based  on  value  of  trade,  involved  or  not  in  processing, 
problematic or not problematic as PSI, etc.; 

information about contact person(s): name, address, phone, fax, e-mail, etc.; 
liability of the company to report for Intrastat (for each flow separately); 
reporting media (paper, EDI, web, other); 
full or simplified reporting, reporting of statistical value; 

  monthly values of intra-EU trade and monthly VAT data; 
 
 
 
 
  status of declarant, i.e. whether third party; 
  complete information on third party declarant, i.e. company, contact persons; 
 
  other  information  for  contact  and  monitoring  purposes,  e.g.  the  most  frequently  traded 

technical information needed for EDI and/or web reporting; 

commodities of a company. 

248. The quality of the register should be constantly checked and maintained because the coverage and 
quality of intra-EU trade data depend directly on the quality of the register. Various sources can be used 
for updating and maintaining the register, but the most important are: 

  VAT register and VAT returns — for the identification of companies who may be liable to report 

for Intrastat and calculation of thresholds; 

  The  data  related  to  the  Value  Added  Tax  Information  Exchange  System,  i.e.  VIES  data.  Any 
VAT  registered  trader  is  obliged  to  submit  periodic  recapitulative  statements  to  their  fiscal 

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authority  about  the  value  of  the  supply  and  the  VAT  ID  number  of  the  trader  in  the  partner 
Member  State  where  VAT  exempt  intra-EU  supplies  are  made.  For  Member  States  collecting 
acquisitions in addition to supplies on VAT recapitulative statements, this information could be 
used instead of VAT returns; 
Intrastat declarations: for the update of administrative information, for global checks at company 
level and for estimations of missing intra-EU trade; 

 

  Customs  data:  information  on  companies  who  trade  with  non-member  countries  and  in  cases 

where a customs declaration covers an intra-EU movements; 

  Other  registers,  databases  or  directories,  statistical  or  administrative,  e.g.  statistical  business 

registers; 

  Direct contacts with businesses. 

249. NSAs are encouraged to regularly assess the quality of the administrative data — VAT and VIES 
data — in terms of accuracy, timeliness and, where possible, comparability with Intrastat data — in view 
of: 

a)  identifying  the  most  appropriate  estimation  methods  for  trade  below  threshold  and  non/late 

response; 

b)  measuring how far VIES data can be used to allocate the estimates for missing intra-EU trade by 

partner Member State; 

c)  measuring how far the administrative data can be used to control the quality of Intrastat data. 

Use of VAT data 

Commission Regulation (EC) No 1982/2004, Article 5 

250. VAT  data  are  essential  for  the  operation  of  the  existing  Intrastat  system.  The  information  to  be 
provided by the tax administration to the statistical authority is the following: 

 

 
 

identification  of  the  trader  who  has  declared  intra-EU  acquisitions  and  supplies  of  goods  for 
fiscal  purposes  (name  of  the  taxable  person;  address,  including  postal  code;  identification 
number); 
the taxable amount of intra-EU acquisitions and supplies; 
the tax period. 

251. The EU legislation defines only the main requirements for VAT returns. Therefore implementation 
measures  are  the  responsibility  of  the  Member  States  which  means  that  VAT  returns  are  not  EU 
harmonised. 
252. The  most  useful  data  of  the  VAT  returns  for  Intrastat  purposes  are  the  two  boxes  which  contain 
information  on  the  value  of  intra-EU  acquisitions  and  supplies.  Time  of  availability  of  VAT  data  at 
statistical authorities of Member States varies from less than 30 days after the end of the reference month 
to  several  months.  Therefore  the  use  of  the  VAT  data  for  Intrastat  purposes  highly  depends  on  the 
situation in the individual Member State. Each Member State must decide how to use available VAT data 
in order to gain the maximum benefit. 
253. Cooperation  of  statistical  authorities  with  the  tax  administrations  is  essential  and  should  be 
established so as to fully support the operation of Intrastat. MSs are encouraged to establish a service 
level agreement between statistical and tax  administrations, which would define the obligations of both 
parties, e.g.: 

  definition of tax data that should be transmitted to the statistical authority; 
  periodicity and deadlines for data transmission; 
 
 

the record format and other technical specifications and protocols for exchange of data; 
the obligation on the statistical authority to respect the confidentiality of the VAT data. 
254. Taking into account timeliness, periodicity and other factors, the main uses of VAT data for Intrastat 
purposes are Intrastat register management, estimations of missing intra-EU trade and data quality checks. 
255. Updates  of  Intrastat  register.  Updating  and  maintaining  the  Intrastat  register  is  one  of  the  areas 
where the use of VAT data is most substantial. It is the main data source for obtaining and updating the 
following information: 

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  Identification information. According to the legislation, the tax administration is required to 
provide  the  national  statistical  authority  with  contact  and  identification  information  about 
persons  who  have  declared  intra-EU  acquisitions  and  supplies  of  goods:  name  of  the  taxable 
person,  address  including  post  code  and  an  identification  number.  This  information  might  be 
obtained  from  the  VAT  register.  In  addition  to  VAT  returns  data  statistical  authorities  might 
request  access  to  the  VAT  register  as  well;  this  can  be  very  useful,  not  only  for  the 
implementation of the Intrastat register but also for its maintenance. 

  Identification of parties responsible for providing statistical information. Information from 
the  VAT  register  and  on  VAT  returns  on  acquisitions  and  supplies  (two  boxes  on  the  VAT 
return), is essential for the identification of companies who may be liable to report for Intrastat. 
The  VAT  register  provides  information  on  all  persons  registered  for  VAT  purposes.  However 
not  all  VAT  registered  persons  must  report  Intrastat  data.  The  taxable  amount  of  intra-EU 
acquisitions  and  supplies  of  goods  collected  from  VAT  returns  is  the  key  indicator  for  the 
identification  of  new  traders  who  have  exceeded  the  exemption  threshold  and  are  liable  to 
provide Intrastat information. 

  Some  traders, (e.g.  involved in  processing activities)  cannot be  identified  on  the  mere  basis  of 
VAT data. Therefore the use of other data sources is necessary. As the scope of traders liable to 
provide  Intrastat  declarations  is  changing  every  day  (new  traders  exceed  the  exemption 
threshold,  others  cease  their  activities)  it  is  important  that  the  Intrastat  register  is  constantly 
updated.  It  is  recommended  that  NSAs  update  as  frequently  as  possible,  at  least  once  per 
month, the information about the liability of the companies to report for Intrastat. 

  Identification of parties authorised to provide simplified statistical information. Information 
on intra-EU acquisitions and supplies is also very important for the identification and updates of 
traders who are authorised to report simplified statistical information. According to the national 
legislation, relevant variables should be included and constantly updated in the Intrastat register, 
such as exemption from providing statistical value, nature of transaction, information about the 
quantity  of  the  goods,  possibility  of  regrouping  products  according  to  the  simplified  rules  of 
Article 10(4)(c) of Regulation (EC) No 638/2004. 

in  particular 

256. Estimation  of  full  trade  coverage.  NSAs  are  required  to  transmit  to  Eurostat  monthly  results 
which cover their total trade with Member States. The Intrastat regulation sets the minimum requirements 
for  the  estimates  of  missing  intra-EU  trade  which  have  to  be  included  in  the  data  sets  transmitted  to 
Eurostat. Trade coverage should be ensured by using estimates which compensate all missing data, and in 
particular  the  trade  below  the  exemption  threshold  and  the  non-response.  VAT  data,  whenever 
available  for  a  given  release  of  information,  are  a  very  useful  data  source  to  carry  out  estimations  of 
missing  arrivals  and  dispatches, 
intra-EU 
acquisition/supply(1).  However  it  is recommended that, to  the  extent possible,  NSAs avoid  estimating 
the main PSIs’ trade by taking any necessary measures to get their Intrastat declarations in due time. 
257. The sum of values reported in VAT returns (intra-EU acquisition/supply) of the operators not liable 
to  report  for  Intrastat  makes  up  the  total  estimated  value  of  arrivals/dispatches  of  trade  below  the 
exemption  threshold.  However  it  is  recommended  that  NSAs  estimate  the  total  trade  below  the 
exemption  threshold  by  using  the  most  reliable  data  sources  —  current  month’s  or  historical 
administrative data (VIES or VAT) — available at the time the estimation process should be launched. 
258. Even though VAT data are used the most frequently for estimation of non-response trade more data 
sources might be needed dependently on the time of data release and consequently on the availability of 
the  data  sources.  Therefore  it  is  recommended  that  NSAs  estimate  the  total  trade  of  PSIs  late  in 
submitting  their  Intrastat  declarations  by  using  the  most  reliable  data  sources  —  current  month’s  or 

those  which  are  considered  as 

(1)  When using VAT data, in particular data on intra-EU acquisition/supply, for estimation of missing intra-EU trade conceptual differences between 
VAT and Intrastat such as processing, triangular trade etc. should be taken into consideration. The estimates should cover all missing arrivals 
and dispatches as defined by  the scope  provisions including  goods for and after  processing, returned  goods, goods delivered  with assembly 
and installation etc. 

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historical administrative data (VAT or VIES), current month’s or historical Intrastat data — available at 
the time the estimation process should be launched.  
259. Since  VAT  data  do  not  contain  information  on  partner  countries  and  commodities,  other  data 
sources and methods for commodity/partner country distribution should be applied. It is recommended 
that  NSAs  allocate  the  estimated  total  trade  below  the  exemption  threshold  by  product  and  partner 
Member State by using data collected from the most similar traders above the exemption threshold. ‘Most 
similar traders’ should be understood as traders with a most similar activity or/and of most similar size. 
‘Traders with a most similar activity’ means ‘traders with the same NACE activity code or with a NACE 
activity code as similar as possible’. ‘Traders of most similar size’ means ‘just-above-threshold traders’. 
As regards the allocation by partner Member State, an alternative to the use of most similar traders’ data 
would consist in applying the pattern captured from VIES data.  
260. As  regards  the  PSIs  late  in  submitting  their  Intrastat  declarations,  it  is  recommended  that  NSAs 
allocate the estimated total trade by product and partner Member State by using their historical Intrastat 
data  or,  if  not  available  or  not  relevant,  by  using  Intrastat  data  collected  from  the  most  similar  traders. 
‘Most similar traders’ should be understood as traders with a most similar activity or/and of most similar 
size. ‘Traders with a most similar activity’ means ‘traders with the same NACE activity code or with a 
NACE  activity  code  as  similar  as  possible’.  ‘Traders  of  most  similar  size’  means  ‘traders  with  most 
similar trade value or turnover’. As regards the allocation by partner Member State, an alternative to the 
use of the PSI’s historical Intrastat data or of similar traders’ data would consist in applying the pattern 
captured from VIES data.  
261. NSAs  are  encouraged  to  monitor  the  accuracy  of  the  non/late  response  estimates  at  product  and 
partner  level  by  comparison  with  real  data  when  Intrastat  declarations  are  submitted.  They  should 
improve their estimation method in the case this monitoring reveals quality issues. 
262. Data  quality  checks.  VAT  data  is  one  out  of  many  auxiliary  data  sources  which  can  be  used  to 
improve  the quality of  Intrastat data.  The  comparison of  the  total  taxable  amount  of  arrivals/dispatches 
reported  for  Intrastat  and  the  taxable  amount  indicated  in  the  two  boxes  of  VAT  returns  at  PSI  level, 
provides information on possible errors. The most important traders with highest discrepancies between 
Intrastat and VAT figures can be contacted and data corrected if needed.  
263. A PSI is also responsible for proving the correctness of the statistical information provided on the 
VAT return, at the request of the NSA. The obligation to prove the correctness is limited to data which 
the  provider  of  statistical  information  has  to  deliver  to  the  competent  tax  administration  in  connection 
with his intra-EU movements of goods. Therefore the NSAs can require trade descriptions of the goods, 
copies of invoices or delivery notes. 
264. Several  issues  should  be  taken  into  account  when  preparing  algorithms  for  Intrastat  data  quality 
checks based on VAT data: 

  Methodological  differences  between  VAT  and  Intrastat  system.  The 

influence  of 
methodological  differences  should  be  eliminated  as  much  as  possible  from  both  VAT  and 
Intrastat data in order to achieve the highest comparability of data. 

  Period to be compared. Although in most cases the period of reference for both systems is the 
calendar month, it is advisable to compare data at PSI level over a longer period, for example a 
quarter,  6  months  or  a  cumulative  value  since  the  beginning  of  the  year.  The  total  values  of 
longer periods are less influenced by possible differences of the reference period in both systems, 
by revisions or other factors. Consequently the quality control procedure becomes more efficient. 
  Criteria  for  selecting  cases  to  be  clarified.  It  is  highly  important  to  define  efficient  criteria 
according  to  which  traders  may  be  contacted  to  clarify  causes  for  discrepancies.  Usually  the 
differences  in  value  and  in  percentage  are  taken  into  account.  Analysis  of  differences  and 
contacts with PSIs concerned may result in corrections of Intrastat or VAT data. 

Example 24  
Erroneous cases that cause discrepancies in VAT and Intrastat data of the same trader 
—  incorrect use of the VAT boxes, sometimes services are included in the boxes for intra-EU acquisition and supply of 

goods; 

—  triangular trade is included in the boxes for acquisition and supply, even if it should be reported in the separate box 

or otherwise identified; 

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—  two  PSIs  report  the  same  transaction  for  Intrastat:  when  more  than  one  PSI  is  involved  in  a  processing  activity 

sometimes both can report; financial leasing transaction can be reported by the bank and the lessee; 

—  wrong nature of transaction code is indicated on the Intrastat declaration; 
—  inconsistent reporting of VAT and Intrastat (e.g. a trader may declare arrivals in Intrastat, but not acquisitions on the 

VAT declaration). 

Possible use of VIES data 
Commission Regulation (EC) No 1982/2004, Article 6 

265. The VIES information to be provided by the tax administration to the national statistical authority is 
at least the following: 

  on intra-EU supplies: 

○  the VAT ID number of each national supplier; 
○  the VAT ID number of the partner Member State acquirer; 
○  the taxable amount between each national supplier and partner Member State acquirer, 

  on intra-EU acquisitions: 

○  the VAT ID number of each national acquirer; 
○  the total taxable amount by national acquirer aggregated by partner Member State. 
266. According  to  Article  263  of  Directive  2006/112/EC,  the  VAT  recapitulative  statements  (VIES 
declarations) shall be drawn up for each calendar month within a period not exceeding one month and in 
accordance with a procedure to be determined by the Member States. In some cases Member States may 
allow  taxable  persons  to  submit  the  VIES  declaration  quarterly.  The  possible  use  of  VIES  data  thus 
depends on practices applied in the Member States. Differences between the reference periods in Intrastat 
and VIES data should be taken into account. 
267. Data reported on VIES declarations are linked to the data declared on VAT returns. However, VIES 
declarations contain an additional piece of information which can be very useful for Intrastat purposes: 
the partner country and the taxable value for each acquirer of goods.  It is very important to take into 
account that the concept of the partner Member State used in the VIES system differs from the one 
applied in Intrastat. In the VIES system the partner Member State is defined on the basis of the fiscal 
flow (invoice) while in Intrastat, the partner country is connected with a physical flow of goods. The VAT 
ID  number  (including  the  code  of  the  Member  State)  of  the  person  acquiring  the  goods  in  the  other 
Member State is reported on the VIES declaration and does not necessarily indicate the country where the 
goods physically move. 
268. VIES declarations contain information on intra-EU supplies of goods (since 2010 the information on 
supply  of  services  is  collected  as  well)  and  can,  consequently  be  used  for  analysis  and  quality 
improvements  of  Intrastat  data  on  dispatches  of  goods.  According  to  Council  Regulation  (EC) 
No 1798/2003  the  national  tax  administration  receives  from  tax  administrations  of  all  other  Member 
States  relevant  VIES  information.  Consequently,  information  on  intra-EU  acquisitions  is  available  and 
can be used for the improvement of statistics on arrivals of goods. 
269. Taking into account available data elements, timeliness, periodicity and other factors, the VIES data 
for Intrastat purposes may be used in data quality checks, for estimations of trade below the exemption 
thresholds, non-response and updates of the Intrastat register. 
270. Estimates of missing intra-EU trade. As it was mentioned above, VIES data are only an auxiliary 
data source for information on the partner country. This information may be used for the distribution of 
estimated trade below the exemption thresholds or non-response. Furthermore, it is available at PSI level 
and the  estimates based on VIES information may give quite accurate estimates of the partner country. 
Before  deciding  to  use  VIES  data,  NSAs  are  encouraged  to  analyse  the  differences  between  data  on 
partner country in Intrastat and VIES at PSI level. 
271. Data  quality  checks.  VIES  data  can  be  very  useful  for  reconciling  intra-EU  trade  asymmetries. 
They  provide  not  only  information  on  the  partner  country  but  also  the  VAT  ID  number  of  the  partner 
Member  State  acquirer  (trader).  This  information  is  very  important  and  useful  when  the  national 
legislation allows exchange of confidential data. 

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Methodological differences between data on Intrastat declarations and VAT data 
272. There  are  no  major  methodological  differences  between  VAT  and  VIES  data.  If  according  to  the 
national VAT rules the triangular trade should not be included in the box for intra-EU supplies of goods 
on  the  VAT  return,  the  value  declared  in  the  mentioned  box  at  individual  trader  level  should  usually 
match  with  the  total  taxable  amount  of  goods  declared  on  the  VIES  declaration.  Therefore  the 
methodological Intrastat and VAT differences discussed below apply to the VIES data as well. 
273. For the majority of cases the totals of the values declared on Intrastat declarations for dispatches and 
arrivals  at  individual  trader  level  should  match  the  figures  declared  on  the  VAT  return  for  intra-EU 
supplies and acquisitions, provided that some conditions are met: 

  data from both sources refer to the same reference period; 
  data are methodologically comparable (transactions of a certain nature should thus be excluded 
from comparison or treated differently and other methodological aspects should be considered, 
e.g. triangular trade, exchange rates, etc.); 
the  VAT  data  are  correct  (in  practice  this  is  not  always  the  case,  therefore  the  analysis  of 
Intrastat — VAT data may also result in better quality of VAT data if a PSI himself corrects the 
VAT return after being contacted by the NSA; however, the statistical confidentiality requires a 
strict  separation  of  statistics  from  other  administrations,  therefore  it  is  not  allowed  to 
communicate errors even in addresses of PSIs back to the fiscal authorities). 

 

274. However,  there  are  a  number  of  legitimate  reasons  for  the  figures  to  be  different.  The  following 
table illustrates cases where the figures declared on Intrastat declarations may be different from respective 
data on VAT and VIES returns because of methodological reasons. The list is not exhaustive and does not 
take into account any CIF/FOB adjustments if necessary. 

Some methodological reasons that cause discrepancies in Intrastat and VAT/VIES data 
1.  Goods  sent  for  or  returned  after  processing  (for  more  details  see  sub-chapter  Processing  trade). 
For VAT purposes, processing is regarded  as a service  and the value of processing costs should be 
reported 
intra-EU 
acquisitions/supplies  of  goods.  In  the  Intrastat  system  the  total  value  of  goods  (including  processing 
costs) sent for processing or returning after processing should be reported. Intrastat > VAT. 

for  services  and  should  not  be  entered 

the  boxes  dedicated 

to 

in 

2.  Financial leasing (for more details see paragraphs 152 — 156). Financial leases are generally paid in 
instalments and are calculated in such a way as to cover the total value of the goods. At the end of the 
contract the lessee usually becomes the legal owner of the goods.  For Intrastat the total value of the 
goods  must  be  declared  at  the  moment  of  dispatch/arrival  of  the  goods  under  the  financial  leasing 
contract. However on VAT returns only the amounts paid as instalments or nil (depending on national 
practice) are reported. Intrastat > VAT (at the month of dispatch or arrival of the goods) or Intrastat < 
= VAT (when no movement of the goods takes place). 

3.  Credit notes (for more details see paragraphs 408 and 409). Credit notes reduce the taxable amount 
that  should  be  declared  on  VAT  returns.  However  credit  notes  in  Intrastat  will  not  be  considered  if 
granted for several deliveries of goods. 

4.  Returned goods. Goods that are returned in exchange are not recorded as acquisitions on the VAT 

return but must be recorded as arrivals in Intrastat. Intrastat > VAT. 

5.  Triangular  trade  (for  more  details  see  chapter  Triangular  trade).  Reporting  obligations  for  fiscal 
purposes  and  for  Intrastat  differ  in  the  case  of  triangular  trade:  in  Intrastat  triangular  trade  should  be 
excluded in an intermediary Member State, whereas for VAT it should be reported 

  —  When only Member States are involved in triangular trade, an intermediary (i.e. goods do not enter 
or leave the country of intermediary) does not report for Intrastat but declares a taxable value of the 
goods or nil (depending on national practice) for VAT. Intrastat < = VAT. 

  —  As  far  as  VIES  is  concerned,  the  seller  of  the  goods  (see  Figure  43)  reports  an  intra-EU  supply, 
indicating the intermediary country as partner country. The same trader should report a dispatch of 
goods  for  Intrastat,  indicating  the  Member  State  of  destination  as  partner  country.  Therefore 
different partner Member States are declared for Intrastat and VIES. 

  —  When the intermediary is from a non-member country (invoice from the non-member country) and 
not registered for VAT purposes in the EU, but goods move between two Member States, no value 

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is reported in the boxes for intra-EU acquisitions and intra-EU supplies of the VAT return. However 
the value of the goods should be reported in the Intrastat system. Intrastat > VAT. 

6.  Distance  sales  (for  more  details  see  subchapter  Distance  sale).  The  distance  sales  above  the 
distance sales threshold (defined by national tax administrations in the Member State of destination of 
goods)  in  some  Member  States  are  reported  on  VAT  returns  as  intra-EU  supplies  and  acquisitions. 
However  the  reporting  obligation  is  defined  by  national  rules  and  therefore  the  data  may  not  be 
available on VAT returns in all Member States. Distance sales below the distance sales threshold will 
not usually be reported on VAT returns, as there is no obligation (but a possibility) to register for VAT in 
the Member State of supply of goods. In Intrastat, distance sales are treated as normal sales of goods 
and should be reported when exceeding Intrastat exemption thresholds. Intrastat > VAT. 

7.  Sales to and purchases from private individuals.  If a PSI purchases goods from or sells goods to a 
private individual who is not registered for VAT purposes in another Member State, this trade should be 
reported in the Intrastat system. However, this transaction is not declared in the two boxes of the VAT 
return. Intrastat > VAT. 

8.  Goods  delivered  with  installation  or  assembly.  When  goods  are  supplied  as  an  integral  part  of  a 
supply of services, no values are declared in the boxes for intra-EU acquisitions and supplies on VAT 
returns.  However  the  value  of  the  goods  should  be  recorded  in  Intrastat  declarations.  If  the  invoice 
contains the total value of both goods and services, the value of the goods should be adjusted from the 
total invoice value. Intrastat > VAT. 

9.  Goods subject  to  excise  and  other  duties.  Provided that  the  tax  base  also  includes excise duties, 
the data from tax returns will be higher than the statistical value of the traded goods. VAT > Intrastat. 
10. Electricity and gas. For tax purposes the supply of electricity and gas is not considered an intra-EU 
acquisition  and  supply  and  thus  the  transactions  are  not  reported  in  the  boxes  relevant  for  Intrastat. 
Intrastat > VAT. 

Correction of the Intrastat declaration 
275. At  the  time  when  the  PSIs  complete  their  Intrastat  declaration  they  do  not  always  have  all  the 
information  necessary  to  make  a  full  and  accurate  data  return.  Consequently  there  will  be  a  need  to 
correct data contained in the first submission.  
276. Reasons for PSI data errors include 

  Data validity errors: incorrect or missing codes, missing values in the declarations, character data 

in numeric fields and vice versa; 

  Data credibility errors: The data can be valid according to the previous criterion of validity but 
can  still  be  incorrect.  For  example,  the  declaration  might  be  inconsistent  internally  in  the 
comparison of the different variables, or it might not be consistent with what was submitted in 
previous months;  

  Data completeness errors: This refers to whether the reported trade data represents the complete 

trade of the given PSI in intra-EU data. 

277. Where possible data errors should be corrected, preferably by the PSI, for example  

  Replacing estimates with collected data; 
  Correcting inaccurate and incorrectly reported data; 
  Deletion of incorrectly reported movements of goods that never took place.  

278. In some cases correction of errors can be automated at the data editing stage or even before. With 
the use of electronic reporting systems and data entry control the NSAs often detect and correct erroneous 
declarations at an early stage. NSAs are required to create the conditions enabling PSIs to use automatic 
data processing and electronic data transmission systems so such kind of checks should already be carried 
out by the PSIs themselves. 
279. In  other  cases it  might  be  necessary  to  contact  the  PSI,  particularly  in  the  case  of  data  credibility 
errors to ascertain if ‘inconsistent data’ is actually incorrect data. Ideally all such inconsistencies would 
be  checked  with  PSIs  however  resource  constraints  will  often  mean  some  prioritisation  will  be  needed 
and  only  a  relatively  small  number  of  PSIs  will  be  contacted.  PSIs  have  a  legal  obligation  to  provide 
complete and accurate data.  

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280. Changes in reporting because of a subsequent alteration of contracts (e.g. price reduction because of 
market  difficulties)  are  not  to  be  considered  correction,  if  the  declaration  corresponds  to  the  terms  of 
contract  in  the  relevant  reporting  time  (for  more  details  see  Credit  notes  and  their  impact  on  statistical 
value). 
281. Corrections  will  usually  only  be  relevant  for  the  data  users,  if  the  published  data  are  going  to  be 
revised subsequently. In most cases, revisions of ITGS are done by the NSAs for the current and for the 
previous year (the ‘non-finalised data’). However it is recommended that NSAs revise data, which are 
considered  final,  where  the  revision  is  significant  for  the  interpretation  of  the  data.  However  the 
obligation for corrections by the party responsible for providing information should therefore be restricted 
as far as possible to the reporting periods, of which the results are not irrevocable yet. 
282. Corrections have to be transmitted by the PSI — preferably by electronic means — in due time after 
detecting the mistake. NSAs are encouraged to define rules how PSIs should submit corrective Intrastat 
declaration.  Otherwise  NSAs  should  coordinate  bilaterally  with  the  party  responsible  for  providing 
information. 
283. For pragmatic reasons, the extent of the corrections should be limited to essential cases. NSAs are 
encouraged to define correction thresholds. In case of value corrections they may refer to value changes, 
in  cases  of  changes  of  other  statistical  characteristics  to  the  total  value  of  the  respective  indicator. 
However, a percentage correction requirement (such as correction of quantity by more than 10%) is also 
possible. 

2.6.2  Extra-EU trade statistics 
284. Obligation  to  provide  a  customs  declaration.  The  legal  requirement  and  specifications  for 
providing  a  customs  declaration  are  laid  down  in  the  European  customs  provisions.  The  customs 
declaration  has  to  be  provided  by  the  declarant  being  the  person  liable  for  respecting  the  customs 
formalities and rules. This operator does not necessarily need to be involved in the trading of the goods, 
e.g. as importer/exporter or owner of the goods. 
285. Statistical declaration and statistical data. The statistical declaration is not foreseen under Union 
legislation on extra-EU trade statistics nor is there any obligation for traders to provide such a declaration. 
The statistical data are collected through the relevant data on the customs declaration: ‘… the [statistical] 
data shall be contained in the customs declaration’(1). On this declaration, the statistical data can be of 
common interest for customs and statistics (e.g. goods code according to the CN) or of purely statistical 
relevance (e.g. nature of transaction). All data elements on the customs declaration can only be collected 
if explicitly required by European customs provisions or national instruction (note: the monthly reference 
period(2) must be deduced from the timestamp of acceptance of the customs declaration). 
286. Data  collection  process  — standard  customs  declaration. Where  the  customs  declaration  is  the 
source of the statistical data, these data have to be transmitted from Customs to NSAs. National Customs 
are required to provide NSAs customs declarations lodged with them at the latest the month following 
the month of acceptance. The transmission has to take place in line with the agreement between Customs 
and national statistical authorities: daily, weekly, monthly or any other agreed periodicity. 
287. Data  collection  process  —  simplified  declaration.  In  cases  where  a  simplified  declaration  is 
lodged  and  completed  by  a  supplementary  declaration,  the  data  need  to  be  transmitted  or  lodged  to 
Customs at the latest the month after the acceptance of the simplified declaration. NSAs should consult 
the national deadlines applied by Customs and ensure that these deadlines do not go beyond the statistical 
deadline. 

Impact of simplifications applied by Customs on statistical data availability 
288. Simplified customs declaration. The most widespread simplified procedure granted to operators is 
the use of the ‘simplified plus supplementary declaration’ for clearance processes within a Member State. 
Except  for  a  short  delay  in  the  data  transmission  to  NSAs,  there  are  no  further  consequences  on  the 

(1)  Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(3). 
(2)  Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(b). 

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availability  of  data.  As  the  time  lag  for  providing  supplementary  declarations  is  set  by  the  national 
customs  provisions NSAs are  encouraged to  ensure  that the  time  lag  will not  be  in  contradiction with 
statistical requirements (see paragraph 823). 

Example 25  
Simplified declaration procedure/ Local clearance procedure 
Step 1: in  the  case  of  the  ‘Simplified  declaration  procedure’:  Lodging  of  a  simplified  (incomplete)  customs 
declaration  at  the  local  customs  office  responsible  for  customs  clearance  at  the  place  where  the  goods  are 
located. 
in  the  case  of  the  ‘Local  clearance  procedure’:  Notice  to  the  local  customs  office  responsible  for  customs 
clearance on the arrival of the goods (because of release of goods) by entering the goods in the book keeping 
accounts. 

Step 2: Lodging  of  a  supplementary  (complete)  customs  declaration  at  the  so-called  payments  customs  office 
(normally  the  customs  office  responsible  for  the  authorisation);  generally  summarised  at  the  beginning  of  the 
following month. 

289. Single  Authorisation  for  simplified  procedures  (SASP)(1).  Recently  adopted  EU  customs 
provisions on SASP and future provisions of the UCC require an appropriate statistical reaction to assure 
data  availability.  Customs  may  authorise  an  operator  to  carry  out  a  customs  clearance  involving  more 
than one Member State if the respective national Customs have come to a common agreement beforehand 
in  the  framework  of  the  consultation  procedure(2).  NSAs  are  encouraged  to  look  for  a  close 
cooperation with their national Customs in order to be a part of the consultation procedure and agree on 
statistical data requirements in advance. 
290. The  clearance  may  be  carried  out  under  a  simplified  clearance  procedure  (e.g.  Simplified  plus 
supplementary  declaration)(3).  Consequently,  under  SASP,  the  goods  are  located  in  one  Member  State 
and the statistical data source is available in another Member State.  Until a structured and standardised 
exchange of customs data between Member States is implemented, NSAs have to establish an additional 
data collection for their national trade statistics. 
291. The usual supplementary declaration serves as data source for EU trade statistics. However, in order 
to be able to allocate the goods movement to the relevant Member State (Member State of destination on 
imports or Member State of actual export on exports)(4), further information is necessary. Therefore the 
declaration should contain the respective information. Although these elements are still optional customs 
data elements, NSAs are encouraged to request their national Customs to include the indication of these 
data elements in the authorisation. 

(1)  DG TAXUD has made available the guidelines for granting SASP on:   

http://ec.europa.eu/taxation_customs/resources/documents/customs/policy_issues/conference_events/budapest2008/sasp_guideline
s_rev4.pdf 

(2)  Commission Regulation (EEC) No 2454/93, Article 253j. 
(3)  Note:  The  customs  provisions  on  declaration  proceedings  might  be  subject  to  changes.  Therefore  an  explicit  distinction  between  ‘simplified 

declaration’ and ‘local clearance’ seems unnecessary. Under the UCC, the two procedures are expected to be merged anyway. 

(4)  Commission Regulation (EU) No 113/2010, Articles 6(3) and 6(4). 

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Figure 10: Import under SASP 

The framework  2 

Figure 11: Export under SASP 

292. Centralised clearance. The UCC will reorganise the system of the ‘Single Authorisation’ based on 
individual  agreements  (‘consultation  procedure’)  between  the  customs  authorities  involved.  The  new 
procedure  will  be  based  on  generally  accepted  standardised  proceedings  agreed  upon  by  the  Member 
in  advance.  The  standardised  proceedings  are  defined  by  Union  Customs  Code 
States 
delegated/implementing  acts.  However, 
full 

realisation  of  centralised  clearance(1) 

requires 

(1)   Regulation (EU) No 952/2013 of the European Parliament and of the Council, Article 179.  

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66 

 DE  MS where customs declaration is lodged Customs data USA Non-member country      Country of origin Goods EU border  FR MS of destination Goods Goods NSA Customs AEO EUROSTAT e.g. direct reporting by the authorised economic operator  Statistical data NSA  DE  MS where customs declaration is lodged Customs data USA Non-member country      Country of destination  Goods EU border  FR MS of actual export Goods Goods NSA Customs AEO EUROSTAT e.g. direct reporting by the authorised economic operator  Statistical data NSA  
 
 
 
 
                                                           
The framework  2 

implementation  of  the  mutual  electronic  data  exchange  system  between  the  national  customs 
authorities(1). 
293. Within centralised clearance Customs may authorise an operator to lodge a customs declaration at 
the  customs  office  responsible  for  the  place  where  he  is  established  while  the  goods  declared  can  be 
presented to Customs in another Member State. In order to allocate the goods’ movement to the Member 
State where the goods are physically located it is necessary, as under SASP, to have information on the 
Member State of destination on imports or Member State of actual export on exports. These data elements 
will be mandatory under the future Union Customs Code delegated/implementing acts. 
294. Mutual electronic data exchange under centralised clearance. Unlike under SASP, the system of 
centralised  clearance  requires  as  a  prerequisite  the  availability  of  a  mutual  electronic  data  exchange 
system between the national customs authorities. As soon as such a system is operational, it is also to be 
used  for  the  trans-national  transmission  of  statistical  data  of  customs  declarations  under  centralised 
clearance.  For  this  purpose,  the  customs  administration  of  the  Member  State  where  the  customs 
declaration has  been  lodged has  to  send  the  statistical  dataset  to  the  customs  authorities  of  the relevant 
Member State where the goods are located. The respective information is available through the (in future) 
mandatory  data  elements  of  Member  State  of  destination  or  Member  State  of  actual  export(2).  The 
receiving customs office is then obliged to transmit the information to its national NSA. 
295. Although  the  mutual  electronic  data  exchange  system  is  not  yet  implemented,  it  is  advisable  to 
prepare for it, i.e. lay down national concepts on the handling of the statistical data, either as sending or as 
receiving  Member  State.  It  is  important  to  consider  the  needs  or  availability  of  optional  data  and  the 
changes to data resulting from customs decisions (see paragraph 191). 
296. Need for NSAs to contact operators (data verification). The legal provisions on extra-EU trade 
statistics  do  not  foresee  an  explicit  statistical  reporting  obligation  for  importers  or  exporters.  These 
operators  are  therefore  not  obliged  to  answer  enquiries  from  any  NSA.  The  only  legal  possibility  to 
enforce information verifications is under the empowerment given to the NSA to ask Customs (national 
or  of  another  Member  State)  to  verify  the  correctness  and  completeness  of  the  data(3).  Therefore  it  is 
advisable for NSAs to establish data correction procedures with their national Customs and in line with 
their  national  provisions,  which  would  clearly  define  how  and  with  which  frequency  the  NSAs  inform 
Customs  on  incorrect  transactions  and  set  the  deadlines  for  clearing  errors  for  their  customs 
administration. 
297. While  not  explicitly  mentioned  in  the  regulation,  the  possibility  to  directly  contact  the  traders  to 
verify the data should not be excluded, as it is much more efficient and practical than the verification of 
data via Customs. Therefore, it should remain as an option irrespective of the fact that traders could refuse 
to answer questions by NSAs 
298. If Customs and NSA of the same Member State are involved, the Member State is free to organise 
such enquiry procedures under national provisions. However, as soon as two Member States are involved 
(in the case of centralised clearance) the administrations of the two Member States (NSA, Customs) need 
to establish operational procedures. Future practice will show how and if such trans-national verification 
procedures can be successfully established. 
299. Self-assessment.  Article  185  of  the  UCC  (former  Article  116  of  the  MCC)  allows  operators  to 
perform certain formalities and controls normally carried out by Customs. This authorisation may include 
a complete waiver of the obligation to present a customs declaration. Customs control would then only be 
assured  through  post clearance  system  based  audits.  The  lack  of  a  customs  declaration  would  lead  to  a 
loss of the default data source for extra-EU trade statistics. 
300. Final  legal  customs  provisions  on  self-assessment  do  not exist  yet,  therefore  a  concrete  statistical 
remedy  to  the  future  unavailability  of  customs  data  has  not  yet  been  implemented  in  the  legislation  on 

(1)   Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 7;  

Commission Regulation (EU) No 92/2010, Article 1(2);  
Regulation (EU) No 952/2013 of the European Parliament and of the Council, Article 6. 
(2)  Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 7(2). 
(3)  Commission Regulation (EU) No 92/2010, Article 1(4). 

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extra-EU  trade  statistics.  However,  the  legislation  requires  authorised  operators  to  provide  statistical 
data(1). Concrete measures on how the data should be provided are not yet developed. However any such 
solution  should  be  compatible  with  the  data  transmission  structures  implemented  for  normal  customs 
declarations,  to  allow  also  trans-national  data  transmission  in  cases  of  self-assessment  combined  with 
centralised clearance. MSs are encouraged to establish a close cooperation between NSAs and national 
Customs in order to include statistical requirements in the authorisation granted to traders. 
301. Centralised  clearance  and  quasi-transit.  The  introduction  of  additional  data  elements  such  as  
Member State where the customs declaration is lodged, Member State of destination and Member State of 
actual  export  should  reduce  quasi-transit  trade  also  known  as  the  ‘Rotterdam-effect’.  The  mandatory 
collection of additional information will allow goods to be correctly allocated to the Member State of real 
export  or  real import  and  avoid  the  recording of  intra-EU  trade  flows,  thus reducing  the  administrative 
burden on traders (for more information on quasi-transit please refer to chapter 5.3 Quasi-transit). 

Extrastat Register (EORI) — accessibility and use by NSAs 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(e) and Article 
6(2) 

Commission Regulation (EU) No 113/2010, Articles 13, 15(3) and 15(4) 

302. The  identification  of  traders  has  become  very  important  for  ITGS,  although  information  about 
traders  is not disseminated.  The  majority of NSAs  traditionally  have had  access  to  the  identification of 
traders.  However  specific  obligations  for  customs  authorities  to  provide  traders’  identification  numbers 
(trader-ID) to NSAs was introduced by Regulation (EC) No 471/2009 in 2010. 
303. Trader  identification  in  extra-EU  trade  has  been  extremely  useful  for  analytical,  validation  and 
estimation purposes. For those Member States where data quality control — or part of it — is assigned to 
the compiling institution, maintaining a register of extra-EU trade operators has already been essential to 
be able to contact traders directly. 
304. With  the  evolution  of  ITGS,  more  emphasis  has  been  put  on  the  enterprise  characteristics  of  the 
trade.  Additional  statistics  have  been  introduced,  called  Trade  by  Enterprise  Characteristics,  which  are 
based on linking trade information at trader level with the statistical business register. In order to enable 
linkage and facilitate quality work, access to trader-ID of Customs has been granted by the legislation to 
the statistical authority compiling ITGS. 
305. In parallel with the developments in statistics, the identification of traders for customs purposes has 
been  harmonised  at  EU  level  and  a  new  ID  system,  namely  the  Economic  Operators  Registration  and 
Identification (EORI) system was introduced in mid-2009. 
306. EORI  registration  covers  data  elements  that  are  listed  in  Annex  38d  of  the  Community  Customs 
Code implementing provisions. Data elements include EORI number, name, contact information, address 
and all VAT ID numbers that the entity has registered within the EU. These data elements provide a solid 
basis for maintaining a register for statistical purposes. Legislation grants full access to the EORI register 
to  compilers  of  ITGS.  The  competent  national  authorities  are  required  to  provide  access  to  data  in 
EORI  database  at  the  request  of  NSA.  However,  NSAs  are  encouraged  to  acquire  the  EORI  register 
along with trade data from Customs on a regular basis and include this agreement in the Memorandum of 
Understanding between Customs and NSA.  
307. ITGS practically considers the entity mentioned in SAD-Box 2 Consignor/Exporter for exports and 
SAD-Box 8  Consignee  for  imports  as  the  trader  relevant  for  statistical  purposes.  Additionally,  SAD-
Box 14  Declarant/Representative  provides  information  about  the  entity  to  be  contacted  for  data 
checking/correction purposes. Using the EORI code in these boxes is obligatory; therefore theoretically 
Customs  provides  a  full  coverage  of  trader  information  to  ITGS  identified  via  EORI  with  insignificant 
exceptions, when the trader has no EORI number. 
308. However,  the  data  quality  of  EORI  numbers  on  these  SAD-Boxes  can  be  negatively  affected  by 
human error, lack of quality checks and limitations of IT-systems. Missing EORI numbers for example, 

(1)  Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 4(3). 

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should  normally not occur unless  the  trader is  a  private  individual. Instead  of  an EORI  number  private 
individuals may provide another type of identification, e.g. their name and address, according to national 
practice. In these cases Customs IT-systems offer at least two types of trader identification, leaving it up 
to the trader which one to choose. 
309. Data quality can also be negatively affected when the EORI number entered into the declaration is 
not (immediately) validated against the central EU EORI database maintained by  DG TAXUD. Traders 
using  look-alike  EORI  numbers  that  do  not  exist  in  the  EORI  database  might  therefore  be  difficult  to 
match with the statistical business register. 
310. Even when valid EORI numbers are used errors can occur. For example, when the declarant enters 
an  EORI  number  in  SAD-Box 2  that  identifies  an  economic  operator  other  than  the  actual 
consignor/exporter.  Such  errors  might  occur  more  often  when  traders  use  services  of  customs  agents. 
Agents with a lot of customers might mix up their EORI numbers more easily. 
311. In order to produce trade statistics according to enterprise characteristics, traders identified via EORI 
should  be  matched  with  the  statistical  business  register.  The  key  variable  for  matching  is  the  VAT  ID 
number.  If  the  statistical  business  register  uses  the  VAT  identification  number  as  the  key  identifier, 
matching  can  be  done  in  one  step,  otherwise  there  is  another  phase  needed  for  matching  the  VAT  ID 
number with the statistical business register identification number. 
312. Depending  on  the  quality  of  EORI  information  received  from  Customs  and  the  national  rules, 
content and quality of the statistical business register, the success rate of matching traders identified via 
EORI  with  the  statistical  business  register  may  highly  vary  in  Member  States.  However,  complete 
matching is not possible due to the rules of obtaining an EORI registration and non-resident companies. 
313. According  to  the  list  of  entities  subject  to  EORI  registration,  the  population  that  can  be  matched 
with the statistical business register covers legal persons, natural persons and associations of persons (if 
according to national rules they are VAT registered) of the resident economy. Based on national practice, 
legal  persons,  natural  persons  and  associations  of  persons  established  in  another  Member  State  or  non-
member country, but due to their local activity registered in the national VAT system, may be contained 
within the statistical business register, and thus can be matched with EORI. However, non-resident legal 
persons,  natural  persons  and  associations  of  persons  without VAT  registration  in  the  national  economy 
are generally not possible to be matched with the statistical business register. 
314. The table below summarises the different types of trader with EORI registration, and their potential 
to be matched with the statistical business register: 

Figure 12: Scheme of type of traders with EORI registration 

315. EORI might have additional uses in national systems for the compilation of extra-EU trade statistics. 
For example, traders obtaining SASP licences but lacking VAT registration in the resident economy, can 
only be identified via an EORI number. 

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69 

 Legal person Resident EU resident 3rd country resident Natural person Resident EU resident 3rd country resident Association of persons Resident EU resident 3rd country resident    Trader (resident) can generally be matched with statistical business register Trader (resident) that can be matched with the statistical business register if registered for local VAT Trader (non-resident) can only be matched if registered for local VAT and included in the statistical business register based on national practice  
 
 
 
The data  3 

3   The data 

3.1 

Identification number of the PSI/operator 

Intra-EU trade statistics 

3.1.1 
Regulation (EC) No 638/2004 of the Council and Parliament, Article 9(1)(a) 

316. Providers  of  statistical  information  carrying  out  intra-EU  acquisitions  and  supplies  are  identified 
through  the  value  added  tax  identification  number.  A  harmonised  European  VAT  ID  number  does  not 
exist  and  the  number  is  issued  by  national  tax  administrations  according  to  national  legislation.  The 
number contains a prefix according to ISO International Standard No 3166-alpha 2 except Greece which 
uses the prefix ‘EL’. The prefix allows the related Member State to be identified. Whether the prefix is 
also requested for Intrastat declarations depends on national requirements. 
317. In addition to the VAT ID number, national authorities may require supplementary information to 
identify the declarant on Intrastat declarations such as the full name and address of PSIs and of any agents 
(third  parties)  appointed  by  PSIs  to  submit  Intrastat  declarations  on  their  behalf.  The  addresses  might 
correspond  either  with  the  address  indicated  in  the  tax  registers  or  with  the  address  of  the  person  who 
carries out the trade activity and may differ from the official address. 
318. PSIs  may  submit  Intrastat  declarations  separately  for  their  individual  branches.  NSAs  are 
encouraged to make these submissions the subject of prior approval by the national authorities. For these 
cases special Intrastat identification numbers should be issued which, together with the VAT ID number 
of the company, allow an unambiguous identification of the branches. Identification numbers of branches 
could be based for instance on numbers of local units already applied in the statistical business register. 
319. Traders who are predominantly engaged in intra-EU processing operations do not declare intra-EU 
acquisitions  and  supplies  on  the  VAT  return  (or  the  value  of  their  trade  may  be  below  the  exemption 
threshold) and it might be difficult to identify these traders. Although the control and monitoring of these 
traders is further complicated by data provided from tax administrations, it is advisable that the VAT ID 
number for these traders is also made available to statistical authorities. 
320. An  identification  number  should  also  be  assigned  to  an  economic  operator  when  using  additional 
data sources for specific goods or movements. It is recommended that NSAs assign this identification 
number in such a way that it is linked to the VAT ID number system, if possible. 

3.1.2  Extra-EU trade statistics 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 6(2) 

321. The EORI number is a unique identifier assigned to entities which are in the course of their business 
involved in activities covered by customs legislation. Unlike VAT registration, a single entity shall have 
only one EORI number within the EU, which is to be used in all Member States, where it is carrying out 
customs  activities.  The  EORI  number  should  normally  be  issued  to  traders  resident  in  the  EU  in  the 
Member State where they are established. For traders resident in non-member countries, the place (i.e. the 
Member State) of registration is where they first get contact with EU Customs. 
322. There are three types of entities subject to EORI registration according to the Community Customs 
Code implementing provisions: natural persons, legal persons and associations of persons recognised as 
having  the  capacity  to  perform  legal  acts  but  lacking  the  legal  status  of  a  legal  person  (further  on: 
association of persons). However, the obligation for registration of natural persons to EORI is decided at 
Member State level. 
323. The structure of the EORI number contains the 2-digit Member State country code according to the 
Geonomenclature  and  a  maximum  15-digit  alphanumeric  code  often  based  on  the  VAT  number  or 
another  national  identification  number  assigned  by  the  national  authority  issuing  the  EORI-code. 
DG TAXUD on its internet page provides a facility to validate EORI numbers(1). 

(1)  http://ec.europa.eu/taxation_customs/dds2/eos/eori_validation.jsp?Lang=en 

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3.2  Reference period 

Intra-EU trade statistics 

3.2.1 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 6 

Commission Regulation (EC) No 1982/2004, Articles 3, 16(2) and 17(3) 

324. The intra-EU trade statistics regulation provides two definitions of the reference period to be used in 
the Intrastat system. The reference period for the information to be collected shall be the calendar month 
of the dispatch or arrival of goods. However, the reference period may be adapted by Member States to 
take into account the linkage with VAT obligations. Member States  may define the reference period to 
which the monthly trade flows should be allocated as the calendar month when the chargeable event for 
VAT  purposes  occurs.  Furthermore,  specific  provisions  on  the  reference  period  are  applied  for  the 
collection of some specific goods or movements. 
325. Thus,  the  legislation  defines  several  reference  periods  to  which  monthly  trade  flows  could  be 
allocated: 

  The calendar month within which dispatches or arrivals of goods take place. This is the month in 
which the goods physically enter or leave the statistical territory of the reporting Member State; 

  The calendar month when the chargeable event for VAT purposes occurs; 
  The calendar month during which the declaration is accepted by Customs. This is important for 
certain customs inward processing transactions and goods belonging to the statistical but not to 
the fiscal territory of the Community. The information is provided by Customs;. 

  The  calendar  month  during  which  the  transfer  of  economic  ownership  takes  place  for  vessels, 

aircraft. 

  The  calendar  month  during  which  the  last  consignment  arrives  or  is  dispatched  for  staggered 

consignments. 

326. The  Intrastat  system  is  closely  linked  to  the  system  of  VAT.  However,  sometimes  the  calendar 
month  within  which  the  dispatch  or  arrival  of  goods  takes  place  may  differ  from  the  one  when  the 
chargeable event for VAT purposes occurs. VAT shall become chargeable on issue of the invoice, and no 
later  than  on  the  fifteenth  day  of  the  month  following  that  in  which  the  chargeable  event  occurs.  As  a 
consequence, for some trade transactions, the reference period according to VAT obligations may differ 
by about one calendar month from the reference period determined according to the physical movement 
of  goods.  To  ensure  comparability  with  fiscal  data,  it  is  advisable  that  the  reference  period  is  also 
determined as the calendar month in which the same trade transaction is recorded for fiscal purposes in 
the  so-called  ‘two  VAT  boxes’  (intra-EU  acquisitions  and  supplies).  In  all  cases  where  the  calendar 
month within which the dispatch or arrival of the goods takes place differs significantly from the month 
recorded for fiscal purposes, the date of dispatch should be used as the reference period. 
327. For  other  goods  not  reported  on  a  VAT  return  as  intra-EU  acquisitions  or  supplies  (for  example 
processing, returned goods, trade in electricity and gas  and other), the reference period shall be defined 
as the calendar month during which the dispatch or arrival of the goods takes place. 
328. Specific provisions on the reference period shall be applied to some specific goods  or movements 
e.g.  vessels  and  aircraft  or  spacecraft.  For  instance,  the  reference  period  for  arrivals  and  dispatches  of 
vessels and aircraft shall be the month when the transfer of economic ownership takes place  (For more 
details see chapters 4.3 Vessels and aircraft). 
329. When one of the conditions for movements of goods previously exempted because of temporary use 
is  not  met  (e.g.  they  stay  longer  than  two  years)  the  goods  must be  included  in  intra-EU  and  extra-EU 
trade statistics. The reference period shall be defined as the calendar month when the event breaking the 
conditions of the provisions took place. 

3.2.2  Extra-EU trade statistics 
Regulation (EC) No 471/2009 of the European Parliament and Council, Article 5(1)(b) 

Commission Regulation (EU) No 113/2010, Article 3, 18(2) and 19(3) 

Commission Regulation (EU) No 92/2010, Article 2(2)(b) 

330. The  legislation  provides  only  very  general  provisions  regarding  the  reference  period.  It  states  that 
the  reference  period  shall  indicate  the  calendar  year  and  month  in  which  the  goods  are  imported  or 

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exported.  Only  cases  where  the  data  source  is  the  customs  declaration  are  specified  more  precisely. 
According  to  the  regulation,  when  the  customs  declaration  is  the  source  for  records  on  imports  and 
exports,  the  reference  period shall  be  the  calendar  year  and  month when  the  declaration  is  accepted  by 
customs authorities. 
331. As in the intra-EU trade statistics, specific provisions on the reference period are applied to the trade 
in  vessels,  aircraft.  For  such  goods  the  reference  period  is  the  month  when  the  transfer  of  economic 
ownership takes place. 

3.3  Commodity Code 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(1)(d) and Article 
9(2)(a) 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(h) 

Commission Regulation (EU) No 113/2010, Article 8 

Combined Nomenclature 
Council Regulation (EEC) No 2658/87, Article 1 

3.3.1  Combined Nomenclature 
332. One  of  the  key  requirements  for  trade  in  goods  statistics  is  that  they  are  classified  by  commodity 
code as set out in the EU Combined Nomenclature. In the CN the full commodity code for a particular 
product can be broken down as follows: 

 

the first six digits are taken from the Harmonised Commodity  Description and Coding System 
(known  as  the  Harmonised  System,  or  HS),  developed  and  maintained  by  the  World  Customs 
Organisation. The HS is used worldwide by the majority of trading nations; it is reviewed and 
updated in 5-year cycles (although exceptionally the time between updates may differ). The last 
revision is from 2012; 

  The eight digits form the EU Combined Nomenclature which is a further detailed breakdown to 

reflect EU industry in terms of trade statistics, customs tariffs and other EU policies. 

Example 26  
CN structure 
HS Chapter 
HS Heading 
HS Subheading 1806 10  Cocoa powder, containing added sugar or other sweetening matter 
CN Subheading 1806 10 15 Containing  no  sucrose  or  containing  less  than  5%  by  weight  of  sucrose  (including  invert 
sugar expressed as sucrose) or isoglucose expressed as sucrose 

Cocoa and Cocoa Preparations 
Chocolate and other food preparations containing cocoa 

18 
1806 

333. An optional breakdown beyond the 8th digit is available, for intra-EU trade only, to Member States 
wishing to collect statistical data of national interest. 
334. To  help  in  classifying  commodities,  CN  Explanatory  Notes  are  produced  on  an  ad-hoc  basis, 
although they are not legally binding. The application ‘CN Search Tools’ is also available from Eurostat. 
Harmonised System Explanatory Notes, published by the World Customs Organisation, provide guidance 
at HS level. 
335. Revision of CN. The CN is revised on an annual basis. Changes may be made: 

  as a result of requests from 

○  EU  Trade  Federations  (sometimes  representing  Member  States  at  national  level)  to  reflect 

industry developments; or 

○  Commission  Departments/Directorates,  for  example  Agriculture,  Fisheries  —  to  meet  EU 

policy etc. 

 

 

to accommodate international requirements; or 

for legal reasons. 

336. As a result of revisions, the CN codes are created, deleted or merged each year. A new version is 
usually  published  in  October  as  a  Commission  Regulation.  Changes  take  effect  from  1  January  of  the 

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following year. Around the same time Eurostat distributes the publication ‘Update of CN codes’ which 
describes the CN structure and its historic evolution of codes from 1988. It is recommended that NSAs 
inform  PSIs  about  the  modifications  in  good  time  in  order  to  allow  traders  to  prepare  and  make  any 
changes to their systems. 
337. NSAs are required to transmit collected data to Eurostat for publication at eight digit level of the 
commodity code. The CN in force for a given year is always applied to the reference periods of that year. 
This means, for example, that data referring to the period of ‘Year N’ must contain the codes which are 
valid  in  ‘Year  N’.  This  applies  even  when  they  are  transmitted  to  Eurostat  the  following  year  (‘Year 
N+1’) when the Year N codes are no longer valid. In other words, the transmission of revised data must 
contain the CN codes applicable at the time when the original transaction occurred. 

3.3.2  TARIC 
Council Regulation (EEC) No 2658/87, Article 2 

338. The  Integrated  Tariff  of  the  European  Communities  (TARIC)  identifies  additional  provisions 
specified in the EU legislation to monitor tariff requirements such as suspensions, quotas and preferences 
—  for  imports  from  outside  the  EU.  The  TARIC  code  comprises  the  eight  digit  CN  code  with  an 
additional two digits to identify tariff requirements. For example, chapter 46 CN codes are dedicated to 
‘basketwork and similar products’. When these goods are ‘hand-made’, a tariff quota is available to allow 
lower duty rates. 10-digit TARIC codes allow this distinction to be made: 

Example 27  
TARIC subdivision 
CN Subheading  4602 11 00  
TARIC code 

 4602 11 00 10    Hand made 
 4602 11 00 90    Other 

  Basketwork and similar products of bamboo 

339. EU  statistical  legislation  requires  Member  States  to  send  import  data  at  TARIC  subheading  level 
(10  digit  code  level)  to  Eurostat  in  order  to enable  other  areas  of  the  Commission  to  monitor  the  tariff 
conditions described. Since TARIC codes may change during the year, NSAs are encouraged to closely 
monitor the changes and when necessary modify data validation procedures. 

3.3.3  Special Combined Nomenclature codes 
Regulation (EC) No 1186/2009 of the European Parliament and of the Council, Article 2 

Commission Implementing Regulation (EU) No 927/2012 amending Annex I to Council Regulation (EEC) 
No 2658/87 

340. There are a number of areas where simplification exists to allow operators to group various goods 
together within one or more commodity codes. 
341. Chapter  98  contains  codes  to  simplify  the  classification  of  individual  parts  of  an  industrial  plant 
(see chapter 4.1 Industrial plant). 
342. Chapter  99  contains  a  number  of  special  commodity  codes  for  collection  and  transmission  to 
Eurostat. Application of some codes is defined by the ITGS legislation (codes for deliveries to ships and 
aircraft and offshore installations as well as a code allocated for the coding of goods if the simplification 
threshold is applied). These codes are mandatory in intra-EU trade, as they are part of the simplifications 
provided to traders. However the use of these codes in extra-EU trade depends on national customs rules; 
Customs may choose not to apply them. 
343. There are other codes in chapter 99, which are not defined by the legislation, but are based  on the 
rules of Doc MET 400. This document is a gentlemen’s agreement between Member States and Eurostat 
which describes the rules for data transmission to Eurostat. Although the document is not legally binding, 
the application of codes defined by this document must be respected by all Member States. 
344. CN codes applicable to intra-EU and extra-EU trade: 

  Goods delivered to vessels and aircraft (see chapter 4.5 Goods delivered to vessels and aircraft): 

9930 24 00; 9930 27 00; 9930 99 00 

  Goods delivered to offshore installations (see chapter 4.6 Goods delivered to and from offshore 

installations): 
9931 24 00; 9931 27 00; 9931 99 00 

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  Trade under military secrecy (see chapter 4.10 Military goods): 

9999 99 99, 9999 xx 99 (xx is the CN chapter); 9999 xx xx (xxxx is the HS4 code). These codes 
should be used only in exceptional cases. The real CN code is preferred. 

345. Codes applicable to intra-EU trade only 

  Low  value  transactions  (see  chapter  6.3 Individual  transaction  threshold)  and  trade  under  the 
simplification threshold (for residual products only) (see chapter 6.2 Simplification threshold): 
9950 00 00 

  Parts for motor vehicles (see chapter 4.4 Motor vehicle and aircraft parts):  

9990 87 zz (zz according to national purposes) 

  Parts for aircraft: 

9990 88 zz (zz according to national purposes) 

346. Codes applicable to extra-EU trade: 

  Certain goods, which are not subject to duties or other prohibitions or restrictions: 

○  9905 00 00 for personal property belonging to natural persons transferring their normal place 

of residence 

○  9919 00 00 for the following goods, other than those mentioned in 9905 00 00: 

—  trousseaux  and  household  effects  belonging  to  a  person  transferring  his  or  her  normal 
place of residence on the occasion of his or her marriage; personal property acquired by 
inheritance, 

—  school outfits, educational materials and related household effects, 
—  coffins  containing  bodies,  funerary  urns  containing  the  ashes  of  deceased  persons  and 

ornamental funerary articles, 

—  goods for charitable or philanthropic organisations and goods for the benefit of disaster 

victims. 

347. These codes are foreseen to be used in extra-EU trade only, as in Intrastat such movement of goods 
in practice will never be recorded due to the application of the exemption threshold. Nevertheless these 
codes  might  appear  in  intra-EU  trade  statistics  as  well  when  the  transaction  is  recorded  on  customs 
declarations (e.g. transactions with French overseas departments). 

3.4  Partner Member State/partner country 

Customs territory 
Council Regulation (EEC) No 2913/92, Article 3 

Geonomenclature 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(2) 

Commission Regulation (EU) No 1106/2012 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(1)(e) and Annex 
Commission Regulation (EC) No 1982/2004, Article 7 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(g) 

Commission Regulation (EU) No 113/2010, Article 7 

3.4.1  Geonomenclature 
348. The nomenclature of countries and territories for the international trade in goods statistics of the EU 
— known as the ‘Geonomenclature’, abbreviated to GEONOM  — is an essential element in compiling 
intra- and extra-EU trade in goods statistics. In particular, it makes it possible to identify those countries 
involved in trade, i.e. inter alia the reporting country, the partner Member State/country. 

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349. The  Geonomenclature  is  subject  to  revisions  in  order  to  incorporate  the  adjustments  needed  for 
statistical  and  customs  purposes  and  to  take  into  account  any  geopolitical  changes  that  may  have 
occurred. 
350. The  alphabetical  coding  of  countries  and  territories  is  based  on  the  ISO  3166  alpha  standard 2  in 
force as far as it is compatible with the requirements of the EU legislation. The description of countries 
and territories in the Geonomenclature specifies more precisely which territories are covered by the code. 
351. The  Geonomenclature  also  contains  codes  which  enable  Member  States  to  apply  simplified 
reporting of a partner Member State/country for specific goods or movements (e.g. codes QQ, QR, QS), 
to record a specific territory (code QP) or to report not specified territories (e.g. QU, QV, QW etc.). Even 
though the codes are set as optional headings, they may be used where provided for in legal provisions, 
customs or statistical ones, requiring a country code. Codes QQ, QU and QX are used when non-member 
countries  transmit  ITGS  data  to  Eurostat.  As  Member  States  shall  compile  and  transmit  intra-EU  and 
extra-EU trade data separately, codes QQ, QU and QX are not allowed to indicate partner countries (See 
also Doc MET 400) 
352. Miscellaneous codes defined in the Geonomenclature: 

  Stores and provisions 

○  QQ 
○  QR (in the framework of intra-EU trade) 
○  QS (in the framework of extra-EU trade) 

  Countries and territories not specified 

○  QU 
○  QV (in the framework of intra-EU trade) 
○  QW (in the framework of extra-EU trade) 

  Countries and territories not specified for commercial or military reasons 

○  QX 
○  QY (in the framework of intra-EU trade) 
○  QZ (in the framework of extra-EU trade) 
  Maritime domain outside of territorial waters 

○  QP 

Example 28  
A)  Transatlantic  cables  are  laid  at  the  bottom  of  the  Atlantic  Ocean.  The  construction  company  submits  the  export 
customs declaration in a Member State, as the cables leave the customs territory. The QP code will be used to indicate 
the country of last known destination in SAD-box 17a. 
B) A wind turbine is delivered from Germany (mainland) to an offshore installation situated in the sector, according to 
information indicated in SAD-box 8 Consignee-address, where Denmark has exclusive right to exploit the seabed. As 
the  installation  is  located  outside  the  customs  territory,  the  exporter  will  lodge  the  customs  declaration  in  Germany. 
Code QP could be used to indicate the country of last known destination in SAD-box 17a. However when transmitting 
data to Eurostat either code DK or QV shall be reported. 

Intra-EU trade statistics 

3.4.2 
353. Within  intra-EU  trade  statistics  the  partner  Member  State  for  dispatches  is  the  Member  State  of 
destination, and for arrivals the Member State of consignment. In addition, for national purposes Member 
States may collect the country of origin for arrivals. EU trade statistics are not recorded in Member States 
where goods are passing through in simple circulation (see chapter 5.1 Goods in transit). 

Member State of destination 
354. Member  State  of  destination.  In  the  case  of  dispatch,  the  Member  State  of  destination  is  the 
Member  State  to  which  goods  are  dispatched  by  the  reporting  Member  State,  without  —  as  far  as  it  is 
known at the time of dispatch — being subject to any halts or legal operations which are not inherent in 
their transport. 
355. If it is known at the time of dispatch that goods are to be delivered to a Member State ‘A’ but will 
first enter a third Member State ‘B’ where they are subject to any halts or legal operations which are not 
inherent in their transport, the Member State ‘B’ is the Member State of destination and Member State 
‘A’ should not be reported as part of this transaction. 

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Member State of consignment 
356. Member  State  of  consignment.  In  the  case  of  arrivals,  the  Member  State  of  consignment  is  the 
Member  State  from  which  goods  were  dispatched  to  the  reporting  Member  State,  without  any  halts  or 
legal operations which are not inherent in their transport taking place in any intermediate Member State. 
357. If, before arriving in the reporting Member State, goods enter a third Member State and are subject 
to  halts  or  operations  not  inherent  in  their  transport,  that  third  Member  State  should  be  taken  as  the 
country of consignment. 
358. A halt is any temporary interruption of the physical movement of the goods before continuing the 
movement to the final destination. A legal operation can be any commercial transaction or comparable 
operation having legal consequences (e.g. sale or processing under contract). Halts or operations related 
to transport of the goods include, for instance, a change of means of transport, preserving operations to 
keep the goods in good condition during transport, breaking-up and assembly of packages. 
359. The Member State of purchase, i.e. the Member State  in which the invoice was issued, should be 
recorded if the Member State of consignment is unknown. 

Country of origin 
360. Country of origin. On arrival, the country of origin means the country where the goods originate. 
The origin of goods wholly obtained or produced in a country is attributed to that country. 
361. Goods whose production involved more than one country shall be deemed to originate in the country 
where they underwent their last, substantial, economically justified processing or working in a company 
equipped  for  that  purpose,  resulting  in  the  manufacture  of  a  new  product  or  representing  an  important 
stage of manufacture. 
362. The  origin  of  goods  can  be  changed  only  by  processing  or  working;  any  other  operations  (e.g. 
sale/purchase, return of goods etc.) preserve the origin. Also using the goods in a country for many years 
does not change their origin, even if their commodity code might change (e.g. used cars). Therefore the 
code of a non-member country is also allowable in intra-EU trade for this statistical data. If the country of 
origin  is  not  known,  it  may  be  substituted  by  the  country  of  consignment;  codes  QW/QV  provided  by 
Geonomenclature may also be used. 

3.4.3  Extra-EU trade 
363. Within  extra-EU  trade  statistics  the  partner  country  for  exports  is  the  country  of  last  known 
destination. For imports the partner countries are the country of consignment/dispatch and the country of 
origin. EU trade statistics are not recorded in the Member States where the goods are passing through in 
transit (see chapter 5.1 Goods in transit). 

Country of last known destination 
364. Country of last known destination. The partner country on export is the last non-member country 
to which it is known at the time of release into the customs procedure or customs approved treatment that 
the goods are to be delivered, which refers to SAD-box 17a on export resp. D.E. 5/8(1). 

Country of consignment 
365. On the import side one of the two partner countries is the country of consignment, which reflects the 
country  from  which  the  goods  were  dispatched  to  the  Member  State  of  destination,  without  any 
commercial transaction or other operation which changed the legal status of the goods, taking place in any 
intermediate country and refers to SAD-box 15a on import resp. D.E. 15/3. 
366. An  operation  changing  the  legal  status  of  the  goods  can  be  any  commercial  transaction  or 
comparable  operation  having  legal  consequences  (e.g.  sale  or  processing  under  contract).  Neither  halts 
nor operations related to transport of the goods taking place in an intermediary country will change the 
country  of  consignment.  Such  halts  include,  for  instance,  a  change  of  means  of  transport,  preserving 
operations to keep the goods in good condition during transport, breaking-up and assembly of packages 
and temporary storage. 

(1)  The new customs provisions do not refer to the number of the SAD boxes but to the Data Element Number. 

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Country of origin 
367. On  the  import  side,  there  is  also  the  country  of  origin.  as  a  partner  country,  which  refers  to  the 
country  in  which  the  goods  are  wholly  produced  or  the  last  substantial  transformation  took  place  in 
accordance with the provisions of the CCC laying down the rules on non-preferential origin and refers to 
SAD-box 34a on import resp. D.E. 15/5. Generally, rules of origin consist of two basic criteria: 

  The criterion of goods ‘wholly produced’ (obtained) in a given country, where only one country 

is involved in attributing origin; 

  The criterion of ‘substantial transformation’, where two or more countries have taken part in the 

production of the goods. 

Difficulties arising in defining correct partner Member State/country 
368. As  regards  Intrastat,  difficulties  for  respondents  in  assigning  the  correct  partner  Member  State  on 
arrival  and  dispatch  side  can  be  found  in  wrong  partner  country  allocations  due  to  triangular  trade 
transactions (see sub-chapter Triangular trade within the context of VIES). 
369. In the case of difficulties to correctly assign country of origin within intra-EU trade, if collected, the 
Member State of consignment could be used for: 

  goods classified in chapter 97 of the Combined Nomenclature; 
  goods delivered after outward processing; 
 
  goods of which the origin is not known; 
  goods of origin in the reporting Member State. 

returned goods; 

370. As  regards  specific  goods  or  movements  —  especially  vessels  and  aircraft  or  goods  delivered  to 
vessels  and  aircraft  —  special  rules  regarding  the  partner  Member  State/country  exist  (see  chapter 
4. Specific goods or movements). 

Importing or exporting Member State (extra-EU trade) 

3.5 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(f) 

Commission Regulation (EU) No 113/2010, Article 6 

Commission Regulation (EU) No 92/2010, Articles 2(2)(i) and (j) 

371. New conceptual approach: Under the extra-EU trade statistics legislation applicable until the end 
of 2009 the importing or exporting Member States were defined in relation to the place where the customs 
formalities were fulfilled, as under a traditional customs approach, the place of location of the goods was 
equal  to  the  place  of  declaration.  However,  changes  of  clearance  patterns  of  traders  and  especially  the 
liberalisation  of  customs  clearance  procedures  made  allocation  of  the  respective  trade  flows  to  a  given 
Member  State  very  complicated.  This  is  why  the  concept  introduced  in  the  new  legislation  applicable 
from  January  2010  considers  both  the  customs  clearance  and  the  physical  movement  of  the  goods. 
Information on Member State of destination/actual export is not yet available on the customs declaration 
in all Member States. Specific provisions have been introduced to handle these cases (see paragraph 379). 
372. Member  State  where  the  customs  declaration  is  lodged.  Traditionally  this  data  element 
designates the Member State of the national Customs where the declaration was lodged. If, under customs 
simplifications, a supplementary declaration is submitted in a given Member State this data element refers 
to  that  Member  State.  Such  explicit  distinction  is  necessary,  as  under  SASP  (see  paragraph  290),  the 
customs  clearance  proceedings  concern  two  Member  States.  This  new  data  element  was  introduced  for 
the provisions of centralised clearance under the UCC (see paragraph 293) allowing a customs declaration 
to be lodged in one Member State, but referring to goods physically located in another one. 

Example 29  
Under SASP, the simplified customs declaration is lodged to Customs in AT, the supplementary declaration is submitted 
to DE Customs. In this case the MS where the customs declaration is logged is DE. 

373. The information on this data element is to be derived in an appropriate way from the content of the 
declaration. On the SAD, the data should be indicated through the ‘acceptance’ information to be entered 
by Customs in SAD box ‘A’ (=‘office of export’/‘office of destination’). 

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3.5.1  Member State of destination 
374. Member State of destination on release for free circulation (imports) (SAD-box 17a). The trader 
can use the possibility to declare the goods for free circulation at the time and place where the goods cross 
the EU border in order to avoid any inner-EU movement of the goods under customs control. This means 
that the goods released in Member State A are destined for Member State B and the clearance in Member 
State A is only a purely technical or logistic aspect. 

Example 30  
A) An Austrian-resident company imports shoes from China to sell them in Austria. The shoes arrive in the Netherlands 
where they are released for free circulation. The goods move as Community goods directly to Austria and are subject to 
an  Intrastat  dispatch  declaration  in  the  Netherlands  and  an  Intrastat  arrival  declaration  in  Austria.  Austria  is  the 
Member State of destination.  
B) An Austrian-resident company imports shoes from China to be distributed on the Slovenian market. The shoes arrive 
in the Netherlands where they are released for free circulation. However, the Austrian company has already resold the 
goods to a Slovenian company. 

the  Netherlands  are  the  Member  State  of  destination.  The  sales  transaction  is  considered  to  change  the 
legal  status  of  the  goods,  so  that  the  Netherlands  are  the  Member  State  of  destination  and  not  Slovenia 
(Explanation:  the  (valuation)  details  on  the  customs  import  declaration  would  only  refer  to  the  contractual 
relation China — Austria and not reflect the sale/purchase Austria — Slovenia). 
Note:  The  movement  from  the  Netherlands  to  Slovenia  would  then  be  subject  to  an  Intrastat  dispatch 
declaration in the Netherlands and an Intrastat arrival declaration in Slovenia as the goods move as Community 
goods directly to Slovenia.. 

375. Member State of destination in case of processing under customs supervision (imports) (SAD-
box 17a).  This  provision  relates  solely  to  the  customs  procedures  of  inward  processing  or  processing 
under  customs  control.  It  does  not  govern  ‘economic  processing’  (with  pure  VAT  aspects)  or  the 
statistical  concept  of  ‘processing  under  contract’.  Under  the  UCC  the  newly  introduced  customs 
procedure  of  end  use  will  have  to  be  considered  too.  Processing  activities  are  increasingly  carried  out 
under the customs provisions of Single Authorisations. This means that the goods will be released in one 
Member State, however the processing activity will take place in another. In such cases imports should be 
statistically attributed to the Member State where the first processing activity is carried out. This Member 
State is then identified as Member State of destination. 

Example 31  
A German-resident company has a Single Authorisation for inward processing covering Germany, France, Poland and 
the  Netherlands.  It  buys  raw  materials  in  the  USA  to  produce  final  products  for  exports  to  Russia.  The  raw  products 
arrive  in  the  Netherlands  where  they  are  released  into  the  inward  processing  procedure.  The  goods  move  as  non-
Community goods to France for processing. Further processing is then carried out in Poland. 
  France is Member State of destination as the first processing activity is carried out there. 

3.5.2  Member State of actual export 
376. Member  State  of  actual  export  with  view  to  customs  procedure  of  export  (SAD-box 15a). 
Under the customs procedure of export, Community goods may permanently leave the EU. The customs 
declaration, as a general rule, should be lodged to the customs office responsible for the exporter, with the 
goods being presented there too. However, simplifications of customs rules make it possible that: 

 

 

the  place  of  lodging  the  declaration  and  the  place  of  the  goods  presentation  are  in  different 
Member States; 
in  exceptional  cases  the  goods  may  be  presented  and  the  declaration  lodged  directly  at  the 
customs office of exit (at the EU border), which is located in a Member State other than where 
the exporter is established. 

Example 32  
A)  The  customs  declaration  is  lodged  in  Germany  where  the  exporter  is  resident,  with  the  goods  located  at  the 
exporter's premises in  Germany. The goods leave the EU  (custom office of exit) in  Germany or in any  other Member 
State 

  Germany is Member State of actual export. 

B)  The  customs  declaration  is  lodged  in  Germany  where  the  exporter  is  resident,  while  the  goods  are  located  in 
Austria. The goods leave the EU (custom office of exit) in Austria or in another Member State 

  Austria is Member State of actual export. 

C)  The  exporter  transports  the  goods  from  his  premises  in  France  to  the  customs  office  of  exit  at  the  EU  border  in 
Lithuania. There he presents the goods and lodges the export declaration. After release into the customs procedure, the 
goods cross the EU border. 

  France is Member State of actual export. 

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377. Member  State  of  actual  export  in  case  of  processing  under  customs  supervision  (SAD-
box 15a). The provision relates only to the customs procedures of inward processing or processing under 
customs  control.  It  does  not  govern  ‘economic  processing’  (with  pure  VAT  aspects)  or  the  statistical 
concept of ‘processing under contract’. Under the UCC the newly introduced customs procedure of end 
use will have to be considered, too. Being aware that such processing activities are  increasingly carried 
out under the customs provisions of Single Authorisations, a re-exportation of goods does not necessarily 
imply  that  a  processing  activity  took  place.  Therefore  the  re-exports  covered  by  customs  processing 
procedures are statistically attributed to the Member State where the last processing activity was carried 
out. This Member State is identified as Member State of actual export. 

Example 33  
A  DE-resident  company  has  a  Single  Authorisation  for  inward  processing  covering  DE,  FR,  PL,  and  NL.  It  buys  raw 
materials in USA to produce final products for exports to Russia. The last processing activity was carried out in FR and 
the goods were then dispatched to PL where the re-export notification is provided to Customs. 
  FR is MS of actual export as the last processing activity was carried out there.  

378. Reporting to Eurostat. The data submission rules to Eurostat request that the data on Member State 
of destination/actual export are indicated. However, as these data elements will only become mandatory 
on the customs declaration under the UCC, NSAs may not receive the respective data from Customs. In 
these  cases  the  NSAs  shall  transmit  information  on  Member  State  of  destination  or  Member  State  of 
actual export to Eurostat according to the following rules: 

  Where  the  information  is  not  applicable  because  a  data  source  other  than  the  customs 
declaration is used (e.g. certain specific movements), this section in the data transmission must 
remain BLANK. 

  For any other imports/exports, NSAs must transmit the information as follows: 

○  a MS-code where it is indicated on the customs declaration (SAD-box 17a/15a); 
○  a MS-code where it not indicated on the customs declaration (SAD-box 17a/15a), but where 

the NSA could derive the information from other relevant content/information; 

○  code QV (as ‘fall back possibility’) where the NSA cannot clearly identify the Member State 
of destination/actual export but can suppose with a high degree of probability that it is not the 
Member State where the customs declaration was lodged; 

○  Where  the  NSA  can  neither  derive  the  missing  relevant  data  from  any  information  at  its 
disposal nor can it decide to use code QV, the code of the Member State where the customs 
declaration was lodged shall be provided to Eurostat. 

3.6  Value 

3.6.1 

Intra-EU trade statistics 

Taxable amount and invoice value 
Regulation (EC) No 638/2004 of the European Parliament and the Council, Article 9(1)(f) and Annex 

Commission Regulation (EC) No 1982/2004, Article 8(1) 

Council Directive 2006/112/EC on the common system of value added tax, Title VII 

379. Whether or not the statistical value is collected, NSAs are required to collect the taxable amount 
from all PSIs. The taxable amount is the value to be determined for taxation purposes in accordance with 
Article 83 of Directive 2006/112/EC for trade which is declared for VAT. 
380. The value must specify the amount which would have been paid in the event of sale or purchase of 
the total commodity at the time and place when it crossed the border of the reporting Member State. 
The value in case of sale or purchase is derived on the basis of the invoiced amount of the goods. In all 
other cases it should be estimated on the basis of the amount which would have been invoiced in the case 
of  sale  or  purchase  of  identical  or  similar  goods,  preferably  under  similar  conditions  (produced  in  the 
same country, at the same time, sale at the same trade level, same quantity). 

Example 34  
In the case of free of charge dispatch, processing or returns, the value of goods is not always known. However, total 
estimated value should be declared in Intrastat. 
In the case of movement of goods after processing, declared value should include the initial value + manufacturing price 
+ the price of additional parts or materials. 

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In the case of financial leasing, total value of goods at the moment of crossing the national border should be declared 
for Intrastat. The statistical value of goods for renting or leasing should be the value of the goods at the national border 
at the time of delivery, not the rent or other compensation to be paid. 

381. The taxable amount shall not include the VAT or other duties (e.g. excise). 
382. Whenever  the  taxable  amount  does  not  have  to  be  established  for  taxation  purposes,  the  invoice 
value shall be collected instead, or failing this, the value shall be estimated. Invoice value is the value of 
the  goods  indicated  on  the  invoice,  which  might  contain  incidental  expenses  according  to  the  delivery 
terms but not VAT or excise duties (e.g. on alcohol, tobacco and mineral oils). 
383. The invoice value may include incidental expenses if they represent payments made by the buyer to 
the seller and are simultaneously incorporated into the base for VAT. The incidental expenses may be the 
expenses related to packaging, transport, insurance or commissions. Transport costs are not only the costs 
directly linked to the means of transport but also include costs for necessary treatment of the transported 
goods  during  the  transport (e.g.  refrigeration  of  perishable  goods,  feeding  of  live  animals  or  temporary 
storage).  The  invoice  may  show  the  incidental  expenses  separately  or  they  may  be  included  in  the 
invoiced price of the goods. 

Example 35  
A)  When  dispatching  goods  the  value  of  which  alone  is  100,  and  under  EXW  delivery  term,  where  costs  related  to 
transport of goods are paid by the purchasers themselves, the invoice value shall be 100 too. 
B) With the same goods and DDU — place of consignee delivery term, where the direct costs related to transport are 
50, and the invoice shows total price of 150 (the seller logically increased the price of goods = 100, by the value of direct 
costs spent by him = 50, which means that he included direct costs in the price of the goods) and the invoice value will 
be 150. 
C) With the same goods and DDU — place of consignee delivery term, where the direct costs related to transport are 
50, and where the invoice shows separately the price of goods amounting to 100 and direct costs 50, the invoice value 
shall also be 150. 

384. For the declaration of value, the following points must be taken into consideration: 

 
 

the value is always the value of the goods; 
it is important to always include the total value of the goods in the declaration, for the following 
trade although it is not declared for VAT as an intra-EU acquisition/supply: 
○  if there is no invoice the value declared the estimated amount shall be the value which would 

have been invoiced in the event of a purchase or sale under normal market conditions; 

○  the amount which would have been invoiced in the event of a sale or purchase, in the case of 

free delivery, processing or returns, the value of the goods is not always known; 

○  in  the  case  of  movements  of  goods  ‘after’  processing,  the  value  declared  must  include  the 

value of the product initially dispatched in addition to the processing fee; 

○  in  the  case  of  financial  leasing,  at  the  end  of  a  financial  leasing,  only  the  residual  value  is 
invoiced. However, for the Intrastat declaration, the total value of the goods must be declared 
at the start of the leasing contract. 

385. When  qualified  estimation  of  the  taxable  amount  is  necessary,  PSIs  when  estimating  the  taxable 
amount should follow the same principles applied for determining the customs value according to Article 
29 (et seq) of the Council Regulation (EEC) No 2913/92. 
386. Where  an  invoice  includes  services  as  well  as  goods,  PSIs  should  separate  the  values.  Only  the 
value of the goods should be declared (as an estimate, if necessary). If no retail price is stated for each 
type of goods and just one invoice total is given, the total price must be estimated for each commodity 
code. 
387. Currency.    The  taxable  amount  (or  failing  that  invoice  value)  shall  be  expressed  in  the  national 
currency units.  

Statistical value 

Regulation  (EC)  No  638/2004  of  the  European  Parliament  and  the  Council,  Article  9(1)(f),  Article  12(1) 
and Annex 

Commission Regulation (EC) No 1982/2004, Article 8(2) 

388. A  statistical  value  has  to  be  established  for  all  transactions  that  are  included  in  intra-EU  trade 
statistics,  irrespective  of  whether  or  not  the  goods  were  sold,  exchanged  or  provided  without  payment. 
Statistical value  must include only  incidental expenses, such as transport and insurance, relating to that 
part of the journey which takes place: 

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 

in the statistical territory, from the delivery point to the border of the dispatching Member State, 
for dispatch; 

  outside the statistical territory, up to the border of the importing Member State, for arrival. 
389. If transport and/or insurance costs are not known, they may be assessed on the basis of costs usually 
payable for such services (considering especially, if known different modes of transport). The statistical 
values  are  to be  derived  from  the  taxable  amount  as  defined  in Article 8(1)  of  Commission  Regulation 
(EC) No 1982/2004 and adjusted as follows: 

  The  statistical  value  for  dispatch  shall  be  a  FOB-type  value  (free  on  board)  which  means  the 
value  of  the  goods  as  they  leave  the  territory  of  the  Member  State  reporting  the  dispatch. 
Incidental  expenses  (e.g.  transport,  insurance)  incurred  from  the  place  of  dispatch  in  the 
reporting Member State to the port, airport or other frontier-crossing point at its national border 
shall be taken into account.  

  The statistical value for arrival shall be a CIF-type value (cost, insurance, freight). This means 
that  incidental  expenses  (e.g.  transport,  insurance)  incurred  from  the  place  of  dispatch  in  the 
partner  Member  State  to  the  national  border  of  the  Member  State  reporting  the  arrival  are 
included in the value. 
If  the  dispatch  or  arrival  takes  place  near  to  the  national  border,  the  statistical  value  could  be 
declared as equal with the invoice value of the respective goods. 

 

Figure 13: Calculation of statistical value for one item with delivery term EXW 

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81 

 MS of dispatch Place of dispatch  A Freight cost € 100 MS of arrival Freight cost € 500 Place of arrival  D Border  MS of dispatch B Note: If delivery term EXW – Place of dispatch is applied, invoiced value will not include any freight cost (ancillary charges such as transport and insurance). As Freight cost from A to B are not known in MS of dispatch they need to be estimated.  Value of goods € 2 000 Value of goods € 2 000 Freight cost from A to B € 100 Freight cost from A to B € 100 Statistical value in MS of dispatch€ 2 100 Freight cost from B to C € 500   Statistical value in MS of arrival € 2 600 Freight cost € 100 Border MS of arrival  C  
 
 
 
 
 
 
Figure 14: Calculation of  statistical value for two items with delivery term CIF 

The data  3 

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82 

 MS of dispatch Place of dispatch  A Distance: 100 km MS of arrival Border MS of dispatch B Border MS of arrival D 10kg 100kg Distance: 500 km Distance: 800 km CIF Place C Distance: 50 km Place of arrival  E      km     km       km      €       €       kg    kg       kg  Alternative B for item II:  Note: Place "C" is outside the dispatching Member State, so costs from border “B” until C shall be excluded from the statistical value reported in Member State of dispatch. Where freight costs are invoiced for as TOTAL (= no disaggregation by journey and/or item): — for the distance, costs need to be split on a pro rata basis (kilometers) — for the two items, the freight costs need to be allocated on a pro rata basis according to net mass to each item (unless not reasonable due to the very nature of the items e.g. 10 kg Chinese Ming vase plus 100 kg steel coil).  Alternative A: Freight costs are invoiced separately Invoice value of item I (10 kg) € 2 000 Invoice value of item I (10 kg) € 2 000 Invoice value of item II (100 kg) € 1 000 Invoice value of item II (100 kg) € 1 000 Invoiced freight cost from A to C € 600 Invoiced freight cost from A to C € 600 ∟Freight cost from A to B  € 100 ∟Freight cost from A to C for item I € 54  ∟Freight cost from A to B for item I € 9 ∟Freight cost from A to C for item II € 546  ∟Freight cost from A to B for item II € 91 Freight cost from C to D  € 800   ∟Freight cost from C to D for item I € 74    ∟Freight cost from C to D for item II € 726 Statistical value in MS of dispatch of item I  € 2 009 Stat. value in MS of arrival of item I € 2 128 Statistical value in MS of dispatch of item II  € 1 091 Stat. value in MS of arrival of item II € 2 272   Alternative B: Freight costs are included in the invoice value of goods Invoice value of item I (10 kg) € 2 054 Invoice value of item I (10 kg) € 2 054 Invoice value of item II (100 kg) € 1 546 Invoice value of item II (100 kg) € 1 546 Freight cost from A to C € 600 Freight cost from C to D  € 800 ∟Freight cost from B to C  € -500 ∟Freight cost from C to D for item I € 74  ∟Freight cost from B to C for item I € -45 ∟Freight cost from C to D for item II € 726  ∟Freight cost from B to C for item II € -455  Statistical value in MS of dispatch of item I  € 2 009 Stat. value in MS of arrival of item I € 2 128 Statistical value in MS of dispatch of item II  € 1 091 Stat. value in MS of arrival of item II € 2 272     kg    kg      kg      €     kg    kg      kg      € For item II: +  10kg 100kg     km     km        km      €     kg    kg      kg      €  Alternative A for item II:   
 
 
 
 
 
 
 
 
 
 
Figure 15: Calculation of statistical value for two items with delivery term DDU 

The data  3 

390. The  statistical  value  shall  be  expressed  in  the  national  currency  units  and  without  decimals  when 
transmitted to Eurostat.  

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83 

 MS of dispatch Place of dispatch  A Distance: 100 km MS of arrival Border of MS of dispatch B Border MS of arrival C 10m3 50m3 Distance: 1 300 km Distance: 50 km Place of arrival  D Note: Place "D" inside receiving Member State of arrival so costs from border “C” until D shall be excluded from the statistical value reported in Member State of arrival. As there are  two items on the invoice, the freight costs shall be allocated on a pro rata basis according to quantity in supplementary units to each item.  Alternative A: Freight costs are invoiced separately Invoice value of item I (10 m3) ₤ 2 000 Invoice value of item I (10 m3) € 2 353 Invoice value of item II (50 m3) ₤ 1 000 Invoice value of item II (50 m3) € 1 176 Invoiced freight cost from A to D ₤ 1 450 Invoiced freight cost from A to D € 1 706 Freight cost from A to B  ₤ 100 ∟Freight cost from A to C € 1 647  ∟Freight cost from A to B for item I ₤ 17 ∟Freight cost from A to C for item I € 274  ∟Freight cost from A to B for item II ₤ 83 ∟Freight cost from A to C for item II € 1 373 Statistical value in MS of dispatch of item I  ₤ 2 017 Stat. value in MS of arrival of item I € 2 627 Statistical value in MS of dispatch of item II  ₤ 1 083 Stat. value in MS of arrival of item II € 2 549  Alternative B: Freight costs are included in the invoice value of goods Invoice value of item I (10 m3) ₤ 2 243 Invoice value of item I (10 m3) € 2 638 Invoice value of item II (50 m3) ₤ 2 207 Invoice value of item II (50 m3) € 2 597 Freight cost from A to D ₤ 1 450 Freight cost from A to D  € 1 706 ∟Freight cost from B to D  ₤ -1 300 ∟Freight cost from C to D € -59  ∟Freight cost from B to D for item I ₤ -216 ∟Freight cost from C to D for item II € -11  ∟Freight cost from B to D for item II ₤ -1 084 ∟Freight cost from C to D for item II € -48 Statistical value in MS of dispatch of item I  ₤ 2 017 Stat. value in MS of arrival of item I € 2 629 Statistical value in MS of dispatch of item II  ₤ 1 083 Stat. value in MS of arrival of item II € 2 549     km     km         km      km        ₤    m     m       m       ₤        km     km         km      km               ₤     m     m       m   Alternative A: Alternative B: 10m3 50m3     km         km     km         km      km      m     m       m         €     km     km         km      km     €     m     m       m   Alternative A: Alternative B:   
 
 
 
 
 
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Currency to be used 
Commission Regulation (EC) No 1982/2004, Article 8(3) 

391. Currency  conversion  shall  be  made  if  the  invoice  value  is  stated  in  a  foreign  currency.  The 
exchange rate to be applied shall be: 

 

 

the rate of exchange applicable for determining the taxable amount for taxation purposes, when 
this is established or 
the  official  rate  of  exchange  at  the  time  of  completing  the  declaration  or  that  applicable  to 
calculate the value for customs purposes, in the absence of any special provisions decided by the 
Member States. 

Valuation of specific trade transactions 
392. Statistical  value  of  the  goods  under  leasing  contracts.  The  value  of  the  leased  goods  is  their 
market  value  and  not  the  sum  of  the  periodic  payments  and  the  residual  value  fixed  in  the  leasing 
contract.  In  the  case  of  financial  leasing,  this  is  the  value  of  the  goods  at  the  beginning  of  the  leasing 
contract. 
393. In the case of operational leasing, a declaration has to be made if the duration of the leasing contract 
exceeds 24 months. If the original contract foresees the duration of the leasing period as more than two 
years, the commodity has to be declared for Intrastat at the beginning of the leasing period, indicating the 
market  value  of  the  commodity.  If  the  duration  of  24  months  is  reached  by  the  prolongation  of  the 
original contract, the commodity has to be declared at the time of the change of conditions of the contract. 
394. The  value  of  the  goods,  which  have  not  been  returned  within  the  two-year  period,  should  be  the 
estimated value at the time the goods are reported for Intrastat. This will normally allow for depreciation 
due to use, or any other factor, which has affected the value of the commodity. It should be the market 
value of the commodity at the time of the reference period. 
395. Goods  dispatched/arrived  free  of  charge  (non-temporary  transactions  without  financial  or  other 
compensation involving a transfer of ownership). Although the delivery is free of charge and no invoice 
may  be  issued,  the  goods  have  a  value  which  must  be  declared.  When  goods  are  delivered  without  an 
invoice  or  with  a  pro-forma  invoice  (e.g.  donations,  consignments  of  goods  under  assistance  programs 
partly or fully managed or financed by the European Union, other government support, other assistance 
(private  sector,  non-governmental  organisations)  and  other  deliveries/replacements  free  of  charge),  the 
open market value of the goods shall be indicated. 
396. It happens that sometimes companies invoice a very low only symbolic value for the goods, which 
are delivered as a bonus. In such cases companies should be advised to record in value the value of the 
goods, which would have been invoiced for a normal trade transaction. 

Example 36  
Company  X  (a  resident  in  MS  A)  buys  pharmaceutical  products  from  company  Y  (a  resident  in  MS  B).  Company  Y 
sends an extra amount of goods as a bonus. This extra amount is sent free of charge or invoiced with a very low value. 

397. In  this  case  the  value  should  be  estimated  and  the  full  value  of  the  goods  declared  for  statistical 
purposes. 
398. Supply and assembly of goods (delivery of goods and services for assembly or installation work). 
The value to be declared for intra-EU trade statistics should cover only the value of the goods. Whenever 
possible, the value of the goods as part of a contract which does not show the value of the goods and their 
assembly  separately  should  be  estimated.  The  estimation  could  be  made  considering  the  proportion 
represented by the goods. 
399. Electricity and gas. Estimations of the value are allowed by the legislation. The estimations can be 
based on historical data, information from traders, stock markets, spot prices or small surveys from price 
statistics.  However  NSAs  are  required  to  communicate  to  Eurostat  the  estimation  methodology  of  the 
value before application. 
400. Waste. Whenever possible the value of waste should reflect only the value of the goods. Services 
relating to the disposal of the waste should be excluded. Therefore, it might be necessary to estimate  a 
residual value for the goods element. If the goods element has no residual value (or even a negative value) 
the value should be adjusted near to zero, because only positive values are permitted. 
401. Processing.  The total value of the goods in their unprocessed state shall be reported for transactions 
involving  goods  sent  for  processing.  This  may  be  based  on  a  qualified  estimation  in  cases  where  the 
invoice  does  not  show  this  amount.  Regarding  transactions  following  processing,  the  total  value  of  the 

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processed goods shall be reported. This should be the value initially reported for the unprocessed goods 
plus the processing costs (for more information on processing, refer to chapter Processing trade). 

Example 37  
Inward processing in Member State X 
Value of goods to be reported for statistical purposes: 
—  For  arrivals  of  goods  with  a  view  to  processing  under  contract  (nature  of  transaction  code  41/42)  the  value  to  be 

reported is the estimated market value of the goods for processing; 

—  For  goods  dispatched  following  processing  under  contract  (nature  of  transaction  code  51/52)  the  value  to  be 

reported is only the value added which contains: 
- 
- 

the price of the material and parts added in Member State X and 
the processing cost; 

Statistical value: 
—  For arrivals of goods with a view to processing under contract (nature of transaction code 41/42) statistical value is 
the estimated market value of the goods for processing plus costs of transport and insurance incurred outside the 
territory of Member State X (up to the border of Member State X); 

—  For goods dispatched following processing under contract (nature of transaction code 51/52) statistical value is the 

total value of the goods at the border of Member State X, which contains: 
- 
- 
- 
- 

the original value of the goods arrived for processing 
the price of the materials and parts added in Member State X, 
the processing cost, and 
transport and insurance costs incurred in Member State X; 

For  dispatches  of  left-over,  waste  and  by-products  following  processing  under  contract  the  estimated  value  of  these 
products plus transport and insurance costs incurred in Member State X (up to the border of Member State X); 

402. Software.  Software is to be recorded in intra-EU trade if a physical exchange of goods takes place. 
The  total  value  of  the  goods  (hardware  +  support  +  licences)  should  be  declared.  However,  license 
agreements on the usage of software (e.g. subsequent purchase of additional usage rights) which are not 
directly connected with a transfer of relevant media are excluded. 

Example 38  
Software stored on a data carrier (e.g. CD-ROM, disk etc.) crossing the national border 
Following situations may occur: 
—  Hardware sold together with software and licences: The total value of the package should be declared. The package 
must  be  classified  by  the  commodity  code  of  the  hardware  (e.g.  commodity  codes  8471....).  If  license  fees  are 
included in the package, these should also be reported as a part of the package. 

—  Standard software 

a)  Arrival/dispatch  of  the  software  stored  on  a  data  carrier,  including  instruction  manual:  This  kind  of  software  is 
regarded  as  a  commodity  and  is  to  be  recorded  for  Intrastat.  The  software  must  be  classified  by  its  correct 
commodity code (heading 8523....). The total value of the software-package should be declared. If license fees 
are included in the software-package, these should also be reported as a part of the software-package 

b)  Updates for standard software (see above item a) stored on a data carrier: If an invoice is separately raised for 
the  updates  an  Intrastat  declaration  is  required  —  as  mentioned  under  item  a).  If  no  invoice  is  raised  for  the 
updates no Intrastat declaration is required. 

403. Rebates and discounts. Rebates and discounts which are known at the moment of declaring goods 
to  Intrastat  and  can  be  related  to  each  delivery  of  concrete  goods  should  be  taken  into  account  when 
defining the statistical value. However, discounts granted at a later point in time (e.g. not foreseeable at 
the time of transaction, granted as a total amount for all previous transactions) and subsequent changes of 
the underlying contract do not require an adjustment of the statistical value. 
404. Low value transactions. Transactions in the same reference period with a value below  individual 
transaction  threshold  EUR 200  may  be  added  together  and  declared  under  CN  code  9950 00 00,  if  the 
NSA allows PSIs to use this simplification. The total declared value might therefore exceed EUR 200. 
405. Returned goods. The value of the returned goods or the replacement value shall be given. When the 
returned  goods  are  broken  or  defective,  the  value  reported  should  be  the  value  of  the  original  sale  or 
purchase of the goods. 

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Credit notes and their impact on statistical value 
406. A credit note is a form or letter sent by a seller to a buyer, stating that a certain amount has been 
credited to the buyer's account. It is issued, generally, in a different period than the initial invoice which 
the credit note refers to. Also called a credit memo, it is issued in various situations to correct a mistake, 
such as when (1) an invoice amount is overstated, (2) the correct discount rate is not applied, (3) goods 
break  down  while  still  under  guarantee,  or  (4)  they  do  not  meet  the  buyer's  specifications  and  are 
returned. 
407. If a credit note is issued for an error in declaring the value and the discount was granted during the 
same reference period as when the trade transaction took place, an Intrastat declaration with the corrected 
taxable amount and statistical value should be provided within the normal correction procedures applied 
by Member States. 
408. If a credit note is issued relating to bonuses, discounts granted at the end of a certain period or good 
results, then the credit note will not be reflected in the Intrastat declaration because the goods value has to 
be established at the moment of crossing the border. 
409. NSAs are encouraged to set thresholds which determine when corrections should be transmitted to 
them. PSIs should be obliged to send a correction of their Intrastat declaration if the value is of statistical 
relevance. 

Estimations of statistical value 
410. Estimation  of  statistical  value.  For  burden  reduction  purposes,  NSAs  are  encouraged  to  collect 
the statistical value within Intrastat, only from the biggest and most important traders. Hence NSAs are 
required to estimate the statistical value of transactions for which it is not collected. A correction factor 
has  to  be  used  to  adjust  the  taxable  amount  or  invoice  value.  For  deriving  correction  factors  several 
methods  can  be  used:  conversion  factors  can  be  derived  from  data  that  are  collected  or  based  on  the 
results of specialised surveys.  
411. As it is very complicated for traders to correctly calculate the statistical value, it is recommended 
that NSAs provide guidelines to the traders concerned in order to make sure that they adjust the taxable 
amount or invoice value in such a way that they transmit the value of their trade as CIF-type for arrivals 
and FOB-type for dispatches. 

3.6.2  Extra-EU trade statistics 

Statistical value 

Statistical value 
Regulation (EC) No 471/2009 of the European Parliament and Council, Article 5(1)(c) 
Commission Regulation (EU) No 113/2010, Article 4 
Commission Regulation (EU) No 92/2010, Article 2(2)(d) 
IMTS: Concept and Definitions 2010, Chapter IV 

Customs value 
Council Regulation (EEC) No 2913/92, Articles 28 — 36 
Commission Regulation (EEC) No 2454/93, Articles 141  — 181 
Agreement on the application of the article VII of GATT 

412. Data element ‘Statistical value’ as a core element (SAD-box 46). NSAs have to compile extra-EU 
trade  statistics  based  on  statistical  value.  The  data  are  obtained  from  the  customs  declaration.  For  this 
purpose, the importer or exporter is obliged by customs provisions to  indicate the information in  SAD-
box 46. However, in some Member States the calculation of statistical value is done by national customs 
clearance systems, thus exempting the trader from providing it. 
413. Nature of the statistical value. The statistical value is a theoretically assessed value attributed to 
the goods at a place where and moment when they cross the border. 

  On  imports,  at  the  border  of  the  Member  State  of  destination  (see  paragraphs  375  and  376  ), 

where the statistical value is referred to as ‘CIF-type’; 

  On  exports,  at  the  border  of  the  Member  State  of  actual  export  (see  paragraphs  377  and  378), 

where the statistical value is referred to as ‘FOB-type. 

414. Elements of the statistical value. The statistical value consists of the value of the goods plus or 
minus those (pro-rata) transport and insurance costs (theoretically) accruing to reach the border of the 

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Member  State  of  destination/actual  export  (For  more  information  on  statistical  value  please  refer  to 
statistical value in Intrastat). 
415. Value  of  the  goods  —  based  on  the  customs  value.  EU  customs  provisions  request  the 
determination of a customs value wherever the goods are subject to a %-duty rate (ad valorem duty). The 
applicable rules are quite complex and are based on the WTO customs valuation agreement. If for extra-
EU imports for free circulation a customs value has been determined it shall be considered as the value of 
the  goods.  The  major  difference  between  customs  value  and  statistical  value  is  that  the  customs 
value is measured at the EU border, whereas the statistical value is measured at the border of the 
Member State of destination/actual export. 
416. The determination of the customs value is based on the price actually paid or payable. It may well 
contain a number of different direct and indirect cost components. The customs value can under certain 
conditions also be estimated by Customs; some peculiarities exist as to the determination of the customs 
value for certain fruit and vegetables (customs assessed ‘unit prices’ or average ‘standard import values’). 
417. Value of the goods — not based on the customs value. This relates especially to exported goods 
and goods imported for processing under customs control (for re-importation after outward processing see 
paragraph 420). Where no customs value is determined the general statistical principles for assessing the 
value  apply:  in  the  case  of  sale  or  purchase  the  price  actually  paid  or  payable;  under  non-sale 
circumstances, the price that would be paid in the event of a sale/purchase. 

Example 39  
Valuation (only) 
A company resident in Germany sends goods free of charge to a company in the US; the goods are accompanied by a 
‘pro-forma invoice’ stating the value at EUR 5 000. This value is acceptable on condition that it comes close to the one 
agreed under a formal sale. EUR 5 000 should be reported on the customs declaration. 

418. Under  the  customs  valuation  principles,  only  those  pricing  elements  which  refer  to  the  actual 
movement of the goods shall be considered. 

Example 40  
Pricing element not referring to the actual movement 
A  company  resident  in  Germany  imports  goods,  invoiced  at  EUR 10 000  from  a  company  in  the  US.  The  invoice 
contains  a  discount  of  EUR 1 000  relating  to  a  previous  sales  transaction.  However,  as  EUR 1 000  relate  to  that 
previous  transaction,  the  value  of  the  goods  of  the  current  shipment  is  to  be  assessed,  for  statistical  purposes,  as 
EUR 11 000. 

419. Value of the goods — processing. In the case of activities for processing, the value of the goods 
shall be that of the unprocessed goods. In case of activities after processing, the value of the goods shall 
be  that  of  the  unprocessed  goods  plus  the  added  value  of  the  processing  activity.  In  this  context, 
processing covers not only the customs procedures of inward and outward processing but also economic 
processing (VAT aspects); processing is not limited to the statistical concept of processing under contract. 

Example 41  
A  company  resident  in  DE  temporarily  exports  goods  with  a  value  of  EUR 10 000  under  the  customs  outward 
processing  procedure  to  Russia.  On  re-importation  of  the  processed  goods  the  valued  added  is  EUR 2 000. 
Notwithstanding the provisions on the discharge of the customs procedure or the calculation of the duties, the value of 
the imported goods for statistical purposes amounts to EUR 12 000. 

420. Currency conversion. The statistical value and customs value shall be indicated in the currency of 
the Member State where the customs declaration is lodged (see paragraphs 373 and 374). Where elements 
on  which  the  statistical  value  is  based  (value  of  the  goods,  freight/insurance  costs)  are  expressed  in 
another  currency,  they  have  to  be  converted  as  laid  down  in  EU  customs  provisions(1).  Under  those 
provisions,  Member  States  (national  Customs)  need  to  make  the  relevant  conversion  factors  publicly 
available, e.g. on the Internet. 

(1)   Commission Regulation (EC) No 2454/93, Articles 169-171. 

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Credit notes and their impact on statistical value 
421. The  use  of  credit  and  debit  notes  for  the  adjustment  of  the  statistical  value  in  extra-EU  trade 
statistics is defined by customs legislation. Basically, it is possible to modify the statistical value on the 
customs declaration if the change occurs: 

 

 

 

in  case of  imports, before  entry  of  goods  into  the  territory of  Member  State  of  destination  (no 
later than the goods cross the border of Member State of destination); 
in case of exports, before exit of goods from the territory of Member State of actual export (no 
later than the goods cross the border of Member state of actual export). 
If the credit note is issued after export or import customs procedures have been carried out, no 
changes  in  the  customs  declaration  will  be  made  and  these  changes  will  not  impact  statistical 
data. 

422. NSAs are required not to make any adjustments of  extra-EU trade data for credit notes issued in 
relation to bonuses, discounts granted at the end of a certain period or for good results. The corrections of 
data should take place only due to erroneous data; in this case standard data correction procedures should 
be followed. 

Invoicing currency (extra-EU trade) 

3.7 
Regulation (EC) No 471/2009 of the European Parliament and the Council, Article 5(1)(l), Articles 6(3) and 
8(2) 

Commission Regulation (EU) No 113/2010, Articles 14 and 16 

423. The  invoicing  currency  (SAD-box 22)  is  mandatory  information  to  be  collected  by  Customs  for 
imported goods in all Member States. On exports, this data element is optional; therefore some Member 
States  Customs  may  decide  not  to  collect  the  invoicing  currency.  If  this  is  the  case,  NSAs  of  such 
Member  States  need  to  introduce  a  survey  in  order  to  collect  invoicing  currency  for  exported goods  as 
well. 
424. Definition. The invoicing currency is the currency in which the commercial invoice is drawn up. It 
is to be entered by means of the ISO alpha-3 currency code (ISO 4217). Data collected by Customs is a 
primary source for the invoicing currency. 
425. Statistics on trade broken down by invoicing currency shall be compiled only every two years. The 
first  reference  year  for  which  annual  statistics  had  to  be  compiled  was  2010.  This  means  that  statistics 
should be produced and transmitted to Eurostat for the reference years 2012, 2014, 2016, etc. 
426. Deadlines  for  the  transmission.  The  information  on  invoicing  currency  for  the  reference  year  T 
should be prepared and transmitted to Eurostat by the end of March of the year T+1. 
427. For the compilation of the statistics on  trade by invoicing currency Member States do not need to 
use full data sets; the legislation stipulates that a representative sample of records on imports and exports 
from customs declarations which contain the data on invoicing currency should be used. 
428. Member States do not need to provide information on all currencies broken down by all products. 
For  simplification  purposes  a  system  of  codes  has  been  introduced  by  the  legislation  which  requires 
Member  States  to  provide  only  aggregated  information  by  currencies  and  aggregated  information  by 
products separately for exports and imports. 

Table 4: Currency codes for Trade by Invoicing Currency 

Code 

Title of the code 

0 

1 

2 

3 

Where the currency is indicated in the national currency of Member States not belonging 
to the euro area (e.g. litas, forint, lats etc.).  

Where the currency is indicated in euro 

Where the currency is indicated in US dollars 

Where the currency is indicated in a currency other than the national currency not 
belonging to the euro area, euro or US dollars (e.g. rouble, juan, jen etc.) 

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Table 5: Product codes based on SITC for Trade by Invoicing Currency 

Code 

Title of the code 

Total value 
1 
2 
3 

Statistical value 
Raw materials without oil (sections 0 — 4, excluding division 33)  
Oil (division 33) 
Manufactured products (sections 5 — 8) 

429. Whenever  the  data  on  invoicing  currency  for  exports  is  not  available  at  Customs,  the  NSAs  are 
required  to  carry  out  a  survey  and  collect  information  directly  from  traders.  The  regulation  does  not 
provide  further  requirements  or  concrete  quality  indicators  related  to  the  organisation  of  the  survey. 
Member States are free to decide on sampling methods, coverage rates and other methodological aspects, 
however NSAs are required to organise a survey in such a way as to provide accurate results. 

3.8  Quantity 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(1)(g) and Annex 
Commission Regulation (EU) No 1982/2004, Article 9 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(d) and Article 
6(1) 
Commission Regulation (EU) 113/2010, Article 5 
Commission Regulation (EU) 92/2010, Articles 2(2)(e) and (f) 

430. Quantity refers to physical characteristics of goods, and in some cases it serves as a more reliable 
indicator than the value. Under ITGS legislation, the quantity of goods can be expressed in two ways: 

 
 

the net mass, which means the actual mass of goods excluding all packaging; 
the supplementary units , which mean the possible units measuring quantity other than net mass 
as detailed in the Combined Nomenclature in force. 

431. Net mass. The net mass is the mass of goods without any packaging. 

Example 42  
A  company  exports  100  bottles  of  mineral  water.  Each  bottle  of  mineral  water  weighs  2.05  kg  and  the  water  in  each 
bottle weighs 2 kg. The net mass to be reported is 200 kg. 

432. For  extra-EU  trade  statistics,  information  about  the  net  mass  of  goods  is  to  be  derived  from  the 
customs declaration (SAD-box 38). 
433. In  the  Intrastat  system,  the  collection  of  data  on  net  mass  is  not  always  required.  The  following 
exceptions exist: 

  Under the provisions on intra-EU trade statistics, where there is a supplementary unit laid down 
for  a  specific  code  of  the  Combined  Nomenclature,  it  is  not  mandatory  to  request  the 
specification of net mass from the PSIs. Member States can define whether the information about 
net mass is collected for all CN codes or only for part of them. However, for those CN codes for 
which information is not collected, the net mass has to be estimated.  It is recommended that 
NSAs estimate the net mass at CN subheading level and transmit to Eurostat. 
In Member States which apply a simplification threshold, PSIs may be exempted from providing 
information on net mass if they belong to the group which benefits from the simplified reporting 
obligation. 
In Member States which apply the simplification for low value transactions,  PSIs which report 
transactions below individual transaction threshold (less than EUR 200) do not have to report net 
mass. 

 

 

434. Estimations of the net mass in Intrastat. Under the legislation on intra-EU trade statistics, since 
1 January 2010, NSAs are required to estimate the net mass when it is not collected from PSIs due to 
simplification  of  reporting.  The  Member  States  apply  different  practices  in  collection  of  the  net  mass. 
More than half of the Member States fully collect the net  mass. The remaining Member States need to 
make  estimations  of  the  net  mass.  In  order  to  facilitate  the  task  of  the  Member  States,  Eurostat  has 

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established  European  conversion  factors  for  all  the  CN  codes  with  a  supplementary  unit.  These 
conversion factors were established on the basis of EU historical trade data after the filtering of outliers. 
Member  States  are  free  either  to  use  the  Eurostat  provided  list  of  conversion  factors  or  any  other 
estimation method.  
435. Net mass is collected in kilograms. Regulations on intra-EU trade statistics do not include provisions 
regarding the level of accuracy in decimals for data on the net mass to be collected from PSIs. However, 
data  on  the  net  mass  transmitted  to  Eurostat  must  be  expressed  in  kilograms  without  decimals.  The 
following rounding rules should be applied: 

 

 

If the remainder beyond the last digit to be reported is less than 5, drop the last digit (i.e. round 
down). 
If the remainder is 5 or greater, increase the final digit by 1 (i.e. round up). 

436. Supplementary  units.  Supplementary  units  measure  quantity  other  than  net  mass  (e.g.  metres, 
terajoules  etc.).  They  are  expressed  in  the  units  laid  down  in  the  Combined  Nomenclature.  If  a 
supplementary unit is not given in the Combined Nomenclature, the quantity of goods is expressed only 
in the net mass. 
437. For extra-EU trade statistics, the information about a supplementary unit is to be derived from the 
customs declaration (SAD-box 41). 
438. In Intrastat, the data collection of a supplementary unit is not required in the Member States which 
apply  a  simplification  threshold;  the  PSIs  below  this  threshold  may  be  exempted  from  providing 
information  on  the  quantity  in  the  supplementary  units.  Besides,  the  PSIs  which  report  individual 
transactions  below  individual  transaction  threshold  (less  than  EUR 200)  do  not  have  to  report  quantity 
expressed in the supplementary units. 
439. The  information  on  a  supplementary  unit  transmitted  to  Eurostat  must  be  expressed  in  integers 
without decimals. 
440. It  should  be  noted  that  the  provisions  for  compilation  of  quantity  for  some  specific  goods  or 
movements differ from those which fall under the normal rules for compiling trade statistics. Namely, the 
quantity  is  optional  for  industrial  plant,  goods  delivered  to  vessels  and  aircraft  (except  for  net  mass  of 
goods  belonging  to  CN  chapter  27)  and  goods  delivered  to  and  from  offshore  installations  (except  for 
goods belonging to CN chapter 27). As far as vessels and aircraft are concerned, the quantity is expressed 
in  net  mass  and  supplementary  units  for  aircraft  and  in  supplementary  units  (pieces)  for  vessels.  The 
provisions for specific goods or movements mentioned here are identical for compilation of intra-EU and 
extra-EU statistics. 

3.9  Customs procedure 

Intra-EU trade statistics 

3.9.1 
441. In a limited number of cases, movements of certain Community and non-Community goods within 
the EU covered by a customs procedure have to be allocated to intra-EU trade statistics. In these cases, 
the data of the customs declaration serve as data source for intra-EU trade statistics, as the Intrastat data 
collection  system  must  not  be  applied  to  movements  of  goods  subject  of  a  customs  declaration  for 
customs  or  VAT  purposes(1).  In  a  similar  way,  decisions  made  by  national  customs  authorities,  which 
may lead to the use of customs declarations for recording of certain Community goods movements (e.g. 
for payment of excise duties on arrivals) should also be excluded from Intrastat reporting. 
442. Community goods moving between parts of the EU's customs territory where at least one of those 
parts does not belong to the EU's VAT territory. By means of the relevant customs procedure codes plus 
the indication of the information ‘CO’ in the 1st subdivision of SAD-box 1 Declaration, the trade flow can 
be accounted for under intra-EU trade by the NSAs of the Member State of dispatch and arrival. 

(1)  Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 5(1). 

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Example 43  
Community  goods  are  dispatched  from  the  Canary  Islands  to  Portugal.  The  Canary  Islands  are  part  of  the  Spanish 
territory but are excluded from the EU's VAT territory. The movement is covered by a customs declaration for dispatch 
from Spain and the customs declaration for the arrival in Portugal. 

443. Non-Community  goods  released  for  free  circulation  having  arrived  from  another  Member  State 
covered  under  the  customs  inward  processing  procedure  or  the  procedure  processing  under  customs 
control. In principle, the goods are covered by the respective customs procedures (CPC xx54 or xx92). 
When released for free circulation, they must not be accounted for  in extra-EU trade statistics, to avoid 
double counting, but have to be registered under intra-EU trade(1). The goods cannot be included in the 
collection  process  of  Intrastat  as  this  system  only  refers  to  Community  goods.  Therefore  NSAs  are 
required  to  include  such  customs  declarations  in  the  intra-EU  data  file  when  transmitting  data  to 
Eurostat. 

3.9.2  Extra-EU trade statistics 
Commission Regulation (EEC) No 2454/93, Annex 38 

444. Customs  procedure.  EU  customs  provisions  govern  the  various  customs  procedures,  not  all  of 
which, however, are of relevance for EU trade statistics. By means of the customs procedure the declarant 
requests for exports or imports the customs (and/or VAT and/or excise) regimes to which goods are being 
entered  or  from  which  they  have  been  removed.  The  choice  of  the  customs  procedure  on  the  customs 
declaration has a significant impact on the duty due and on how the consignment is treated by Customs. 
445. The UCC has set up the procedures for release for free circulation, export, end-use and inward and 
outward  processing.  Not  within  the  scope  of  EU  trade  statistics  are  transit,  temporary  storage,  customs 
warehousing, free zones and temporary admission. 
446. Customs Procedure Code (CPC). On the written or electronic customs declaration CPC stands for 
the procedure and customs treatment which the declarant requests. The 4-digit customs procedure code is 
a statistical data element. It serves to derive the statistical procedure(2). On the SAD the CPC has to be 
entered  in  box  37.  NSAs  must  be  familiar  with  this  coding  system  in  order  to  understand  which  trade 
covered by customs declarations falls within or outside the scope of extra-EU trade statistics and to avoid 
double  recording  of  goods  flows.  NSAs  must  be  able  to  conceptually  link  customs  procedures  to  the 
relevant statistical procedures. 
447. Structure. The CPC consists of a first plus a second subdivision. The first subdivision contains a 
compulsory  European  4-digit  code,  where  the  1st  and  2nd  digits  represent  the  requested  customs 
procedure, the 3rd and 4th digits represent the previous procedure. Only the codes of the first subdivision 
are legally relevant for the compilation of extra-EU trade statistics. The second subdivision may contain, 
where  applicable,  a  European  3-digit  code  which  further  specifies  the  customs  regime.  Also  the  use  of 
national codes is possible. The code of the second subdivision is not legally binding for the compilation 
of extra-EU trade statistics. 
448. The EU codes of the second subdivision are composed of an alphabetic character followed by two 
alpha-numeric characters, where the first identifies a category of measures in the following manner: 

Inward processing  
Outward processing  
Relief  
Temporary import  
Agricultural products  
Other  

Axx 
Bxx 
Cxx 
Dxx 
Exx 
Fxx 

(1)  The 

previous 

trade. 
Note: As a general rule, goods released into free circulation after being subject to a customs processing procedure are excluded from extra-EU 
trade statistics (Commission Regulation (EU) No 113/2010, Annex I, point (k). 

processing 

accounted 

procedure 

extra-EU 

release 

already 

under 

was 

into 

the 

for 

(2)   Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(i); 

Commission Regulation (EU) No 113/2010, Article 9(2). 

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Example 44  

The data  3 

The importer requests the entry into free circulation (=payment of customs duties and VAT) of goods coming out of a 
customs warehouse; he requests that the customs value is determined according to the ‘unit price provisions’. 
4000 C07:  Imports  (40)  without  previous  procedure  (00)  of  goods  of  negligible  value,  which  is  relieved  from  import 
duties (C07) 
4071 000: 

Imports (40) of goods previously placed under the customs warehousing procedure (71). 

449. The customs procedure codes are used to define the scope of extra-EU trade statistics, i.e. to decide 
which flows of goods to include, exclude or to avoid double counting of goods. The NSAs are required 
to  use  the  first  subdivision  of  the  customs  procedure  code  for  defining  the  correct  coverage  of  ITGS. 
NSAs are encouraged to use the second subdivision of the customs procedure code when it allows them 
to better identify trade flows for exclusion. The table in ANNEX 3: Allocation of customs procedure to 
type  of  trade  and  statistical  procedure  allocates  the  customs  procedure  codes  to  the  trade  concepts  and 
provides a link with the statistical procedure. 
450. NSAs must be aware that national Customs might in certain cases use a given CPC different from 
the  meaning  as  laid  down  in  Annex  38  of  the  Community  Customs  Code  implementing  provisions. 
Before any transposition, NSAs are encouraged to contact the national Customs in order to gain a clear 
understanding of the meaning of the use of a CPC in the context of national clearance specificities. 
451. As  a  further  prerequisite  for  the  allocation  of  trade  covered  by  a  given  CPC  to  the  respective 
statistical  procedure,  NSAs  need  to  assess  beforehand  if  a  given  trade  transaction  is  to  be  covered  by 
extra- or intra-EU trade statistics. This implies that CPCs referring to trade not under the scope of extra- 
or intra-EU trade statistics or excluded trade (see sub-chapter List of exclusions and inclusions) must not 
be included in the compilation process and therefore must not be transposed to a statistical procedure. 

Example 45  
Although  a  given  CPC  (e.g.  '1000'  —  permanent  export)  would  basically  be  within  the  scope  of  trade  statistics,  the 
transaction is excluded if it refers to ‘repair’. 
Although a given CPC (e.g. '4000' — import into free circulation) would basically be within the scope of trade statistics, 
the transaction is excluded if it refers to imports by an embassy. 

3.10  Statistical procedure 
452. General  nature  of  the  statistical  procedure.  A  statistical  procedure  identifies  the  characteristics 
which  may  be  useful  for  statistical  purposes  by  distinguishing  different  types  of  imports/exports  or 
arrivals/dispatches. Their notion and relevance for EU trade statistics, however, is different under intra-
EU or extra-EU trade. 

3.10.1  Intra-EU trade statistics 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(2)(f) 

453. Under the European provisions on intra-EU trade statistics, statistical procedure is an optional data 
element that Member States may collect on the Intrastat declaration(1) (in 2009, only six Member States 
collected this data element from traders). Any additional clarifications or specifications on the codes to be 
used  remain  under  the  competence  of  Member  States.  The  information  is  not  a  part  of  their  data 
transmissions to Eurostat. 
454. For  national  purposes  and  requirements,  the  statistical  procedure  codes  might  be  used  to  identify 
certain transactions useful for statistics:  

  Trade in ‘quasi-transit’: trade which is released for free circulation in the reporting Member State 
but  dispatched  further  on  to  another  Member  State  or  vice  versa  on  arrivals  (see  chapter 
5.3 Quasi-transit); 

(1)  Regulation (EC) No 638/2004 of the European Parliament and Council, Article 9(2)(f). 

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4071E0140:import for free circulation71:customs warehoueseE01:use of the unit price for determination of the customs value1st subdivision2nd subdivision 
 
 
 
                                                           
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  Temporary relocation of stocks; 
  Trade based on e-commerce; 
  Fish landed for the first time by seagoing vessels; 
  Triangular trade; 
  Trade reported also as acquisitions and supplies according to VAT provisions. 

3.10.2  Extra-EU trade statistics 
Regulation (EC) No 471/2009 of the European Parliament and Council, Article 5(1)(i) and Article 6(1)(d) 

Commission Regulation (EU) No 113/2010, Article 9 

455. Under extra-EU trade statistics it is important to identify for trade policy reasons the movements of 
goods  to  which  trade  measures  were  actually  applied  or  which  were  actually  exported  as  Community 
goods.  Although  the  mere  temporary  imports  and  exports  are  not  within  the  scope  of  extra-EU  trade, 
some temporary extra-EU trade flow categories of imports and exports relating to the customs inward or 
outward  processing  procedures  still  need  to  be  further  identified  for  the  above  mentioned  purposes.  To 
achieve this aim a system of 1-digit statistical procedure codes has been implemented. 
456. Statistical procedure codes: 

1 ― normal imports or exports;  
2 ― imports or exports covered by the customs inward processing procedure;   
3 ― imports or exports covered by the customs outward processing procedure;    
9 ― imports or exports not recorded from customs declarations. 

457. The statistical procedure codes 1, 2, and 3 are derived from customs procedure codes indicated in 
SAD-box 37. However Code 9 was newly introduced from 1 January 2010 and relates uniquely to trade 
for which the customs declaration is not the data source. Code 9 is especially relevant under the ‘specific 
goods or movements’ provisions on vessels and aircraft, where the flows relate to the change of economic 
owner and therefore the data  can be obtained or complemented with the information  from data sources 
other than customs declarations. 
Table 6: Conceptual overview of the relation between statistical and customs 
procedures 

Statistical procedure 

Customs procedures under the 

Community Customs Code 

Union Customs Code 

1 ― normal imports or exports 

— release for free circulation, 

— release for free circulation 

— processing under customs 

— end-use 

— export 

control(1) 
— exportation 

— re-exportation in the 

context of processing 
under customs control 

2 ―  imports or exports covered by the 
customs inward processing 
procedure 

3 ―  imports or exports covered by the 
customs outward processing 
procedure 

— inward processing, 

— inward processing 

— re-exportation of processed 

— re-exportation of processed 

goods 

goods 

— outward processing 

— outward processing 

— re-importation of processed 

— re-importation of processed 

goods 

goods 

9 ―  imports or exports not recorded from 

Not applicable 

customs declarations 

(1)   Imports are conceptually different from those under the inward processing procedure; as this trade is not temporary, it is to be allocated to code  

  1. 

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458. Peculiarities — exclusions. Trade covered by any other customs procedure is out of the scope of 
extra-EU  trade,  e.g.  the  entry  into  a  customs  warehouse  or  goods  covered  by  temporary  admission. 
However,  also  trade  flows  under  a  ‘valid’  customs  procedure  may  be  excluded  from  extra-EU  trade 
statistics (c.f. list of exclusions).  NSAs are required to establish the necessary routines to identify and 
exclude  such  trade  flows.  (For  their  identification,  the  data  element  ‘nature  of  transaction’  or,  under 
customs processing, the respective code of the 2nd subdivision of SAD-box 37 can be used if available at 
NSA level). 

Example 46  
Goods  for  repair  might  enter  either  under  the  customs  inward  procedure  or  under  release  for  free  circulation. 
Although  entering  under  a  ‘valid’  customs  procedure,  the  flow  is  excluded  from  extra-EU  trade  statistics.  It  should  be 
decided at national level between Customs and NSA how to identify repairs. 

459. Correlation  table  of  customs  procedures  to  statistical  procedures.  Member  States  shall  derive 
the statistical procedure from the 4-digit customs procedure. This should be done by the NSAs from the 
data  they  receive  from  Customs.  It  is  recommended  that  Customs  transmit  all  transactions  with  all 
customs procedures applicable to the NSAs, allowing for full statistical control of relevant transactions. 
For  this  purpose  it  is  recommended  that  every  NSA  establishes  a  correlation  table  linking  customs 
procedures to special (and if needed general) trade systems and to statistical procedures. Not all possible 
procedures will be used in all Member States. However, to allow for harmonised compilation, Member 
States shall refer to the correlation table in ANNEX 3 — Allocation of customs procedure to type of trade 
and  statistical  procedure,  which  contains  not  only  the  most  relevant  customs  procedures  but  also  error 
prone correlations. 

3.11  Nature of Transaction 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(1)(h) and Annex 
Commission Regulation (EC) No 1982/2004, Article 10 and Annex III 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(j), Article 6(1)(e) 
and Article 6(5) 
Commission Regulation (EU) 92/2010, Article 2(2)(o) 
Commission Regulation (EU) 113/2010, Article 10 and Annex II 

460. A two-digit coding system of Nature of transaction is used to differentiate between types of trade. 
The codes serve to determine the different characteristics (purchase/sale, work under contract, etc.) which 
are  deemed  to  be  useful  in  distinguishing  one  transaction  from  another  either  for  Balance  of  Payments 
and National Accounts purposes or for the identification of transactions which are excluded from ITGS, 
but recorded separately for national use (e.g. repair). 

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Table 7: Nature of transactions codes 

A 

B 

1.  Transactions involving actual or intended 

transfer of ownership from residents to non-
residents against financial or other 
compensation (except the transactions listed 
under 2, 7, 8) 

1.  Outright purchase/sale 
2.  Supply for sale on approval or after trial, for 
consignment or with the intermediation of a 
commission agent 

3.  Barter trade (compensation in kind) 
4.  Financial leasing (hire-purchase)(1) 
9.  Other 

2.  Return and replacement of goods free of charge 

after registration of the original transaction 

1.  Return of goods 
2.  Replacement for returned goods 
3.  Replacement (e.g. under warranty) for goods not 

being returned 

9.  Other 

3.  Transactions involving transfer of ownership 

without financial or in kind compensation (e.g. 
aid shipments) 

4.  Operations with a view to processing (2) under 

1.  Goods expected to return to the initial Member 

contract (no transfer of ownership to the 
processor)  

State of dispatch/country of export 

2.  Goods not expected to return to the initial 

Member State of dispatch/country of export 

5.  Operations following processing under contract 
(no transfer of ownership to the processor)  

1.  Goods returning to the initial country of export 
2.  Goods not returning to the initial country of 

export 

6.  Particular transactions recorded for national 

purposes 

7.  Operations under joint defence projects or other 
joint intergovernmental production programs 

8.  Transactions involving the supply of building 
materials and technical equipment under a 
general construction or civil engineering contract 
for which no separate invoicing of the goods is 
required and an invoice for the total contract is 
issued 

9.  Other transactions which cannot be classified 

1.  Hire, loan, and operational leasing longer than 

under other codes 

24 months 

9.  Other 

461. There  are  usually  three  dimensions  to  be  considered  when  determining  the  nature  of  a  given 
transaction,  namely  the  physical  movement  of  the  goods,  the  transfer  of  ownership  and  the  financial 
compensation. (For certain codes there are some more detailing aspects also to be considered, for example 
by code 7 and 8). 
462. Transaction code 1. All transactions involving an actual, anticipated or intended future transfer of 
ownership against compensation (financial or other) are reported under code 1.  ‘Transfer of ownership’ 
means a change of ownership between a PSI in the reporting Member State and an economic operator in 

(1) Financial leasing covers operations where the lease instalments are calculated in such a way as to cover all or virtually all of the value of the 
goods. The risks and rewards of ownership are transferred to the lessee. At the end of the contract the lessee becomes the legal owner of the 
goods. 

(2) Processing covers operations (transformation, construction, assembling, enhancement, renovation…) with the objective of producing a new or 

really improved item. This does not necessarily involve a change in the product classification. Processing activities on a processor’s own account 
are not covered by this item and should be registered under item 1 of column A. 

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another  Member  State  or  in  another  country.  This  transaction  code  includes  most  arrivals/imports  and 
dispatches/exports of goods. The following transactions are covered: 

  definite purchase/sale (code 11); 
  goods movements between subsidiaries in different Member States/countries (‘intra-firm trade’) 

(code 11); 

  sale on consignment, on approval, or on trial (code 12); 
  barter (payment in kind) (code 13); 
 
  other  (anticipated  or  intended  future  transfer  of  ownership,  e.g.  dispatch  to  warehouses  and 

financial leasing (hire purchase) (code 14); 

distribution centres in another Member State followed by a sale transaction) (code 19). 

Example 47  
A) A Lithuanian leasing company A (lessor) buys goods from another Member State and leases those goods (financial 
leasing contract) to another Lithuanian company B (lessee). The goods are delivered directly to the lessee from another 
Member State. The transaction should be reported by company A with NoT code 11. 
B) A Lithuanian leasing company A (lessor) leases a car (financial leasing contract) to a Latvian company (lessee). The 
car is physically dispatched from Lithuania to Latvia. Company A reports dispatch of goods under NoT code 14. 
C) A Lithuanian company C sells a car to  an Estonian leasing company Y. The Estonian company X (lessee) signs a 
financial leasing contract with the Estonian leasing company Y (lessor). Company C receives money (the total value) for 
the car from company Y. The Lithuanian company C delivers the car directly to company X. Company C should report 
dispatch  under  NoT  code  11.  The  sale  transaction  between  the  Lithuanian  company  C  and  the  Estonian  leasing 
company Y should be considered as an intra-EU supply/acquisition from the VAT point of view. 
D) A mail-order company sends goods to private persons in other EU Member States. The company has to declare a 
dispatch in the country of its place of business and from which the goods are being sent, using NoT 11. 

463. Anticipated or intended future transfer of ownership means that the economic operators intend at the 
time  of  the  arrival/dispatch  a  transfer  of  ownership  regardless  of  whether  the  transfer  of  ownership 
actually takes place by the time of border-crossing. If a subsequent transfer of ownership does not take 
place, a correction of code 19 to code 9 should be requested if the transaction is of statistical relevance 
(for more details and examples on using code 19 vs. 99 see also paragraphs 480 — 484). 
464. When goods move between two Member States, but the transfer of ownership does not concern any 
party in the reporting Member State, i.e. the change of ownership takes place between parties in two other 
Member States then the transaction shall be recorded using code 9 instead of code 1. This might happen 
when a tax representative declares for Intrastat in the case of the quasi-import. 

Example 48  
A  fiscal  representative  in  a  Member  State  clears  goods  from  a  non-member  country  for  free  circulation  with  a 
subsequent  intra-EU  dispatch  to  another  Member  State.  In  the  country  of  dispatch  an  Intrastat  declaration  has  to  be 
filed. As the tax representative is not the owner of the goods, NoT 99 has to be used. However, in the arrival Member 
State  NoT  11  has  to  be  used,  because  otherwise  the  transaction  cannot  be  identified  as  a  purchase  in  the  arrival 
country. 

465. Cross-border movements between members of the enterprise group are considered as effecting the 
change of  ownership  (excluding  here  special transactions  like  processing), because  the parent  company 
and the affiliated company (or two affiliates of the same group) are considered as separate legal entities 
being  resident  in  the  country  where  they  are  established  and  therefore  they  should  be  reported  under 
relevant  code  (1  or  3)  depending  on  the  compensation.  However,  cross-border  movements  registered 
between the different VAT registrations of the same company are to be recorded according to the nature 
of the underlying transaction (for example NoT 19, 4 and 5 or 99). 
466. Transaction  Code  2.  Returned  goods  and  replacement  deliveries  are  included  in  ITGS.  The 
reference month is the month when the return or replacement delivery takes place. NoT code 2 shall be 
used  only  when  the  original  goods  movement  is  meant  to  be  recorded  with  code  1  (even  if  it  is  not 
actually  reported  because  the  PSI  for  the  flow  concerned  is  below  the  threshold).  The  value  of  the 
returned or  replacement  goods  must be provided.  Return of  goods  and replacement  deliveries  are  to  be 
reported in the direction the goods are sent, i.e. goods received as imports/arrivals and goods dispatched 
as exports/dispatches. 

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Arrivals    Dispatches 
     21         20  
21         20 

Example 49  
A) Company Y in Member State A has purchased goods from Company X in Member State B. Due to quality problems 
part of the goods (with value 20) are sent back to Member State A. Company X compensates Y either by money refund 
or credit note. 
   NoT 
Country A 
Country B 
B)  If  the  returned  goods  are  not  refunded,  but  replaced,  the  following  transactions  are  also  recorded  after  the 
transaction with NoT Code 21: 
  NoT 
Country A 
Country B 
C)  If  the  goods  are  not  returned,  no  financial  compensation  is  given  but  replacements  are  sent,  the  following 
transactions are recorded: 
  NoT        
Country A 
Country B 

Arrivals    Dispatches 
     22         20  
     22         20  

Arrivals  Dispatches 
     23         20  
23         20  

467. Return of goods for which the original transaction was reported with NoT codes 3, 7, 8 and 9 shall 
be declared again with the same transaction codes (i.e. 3, 7, 8 and 9). Return of goods under NoT code 4 
shall be reported under code 5. 
468. Transaction Code 3. Free of charge transactions with a transfer of ownership (i.e. without financial 
or other compensation) shall be reported under code 3. These transactions often involve aid shipments by 
governmental, non-governmental and individual parties. Even though the goods are free of charge and no 
invoice will be issued, a value must be declared by traders. 

Example 50  
A producer of vehicles for fire-fighters sends a demonstration vehicle as a gift to a non-profit organisation in another EU 
Member State to fight forest fires. The producer of the vehicle has to declare a dispatch as a transaction with transfer of 
ownership without compensation using NoT 3. 

469. Transaction  Codes  4  and  5  (for  additional  information  please  refer  to  chapter  Processing  trade). 
Goods  exported  or  imported  for  processing  under  contract  should  be  reported  using  code  4.  Goods 
exported or imported following processing under contract should be reported with code 5. The following 
conditions must be met in order to use transaction codes 4 and 5: 

  There  is  no  change  of  ownership  occurring  in  the  framework  of  processing.  If  a  transfer  of 

ownership takes place (processing on processor's own account) code 1 shall be used. 

  There  must  always  be  an  inward  goods  movement  which  is  followed  by  an  outward  goods 
movement in the reporting Member State or vice versa for NoT code 41 and 51. However, for 
code 42, either a movement to any other country (NoT 52) or a sale in the country of processing 
(no ITGS transaction) after processing is acceptable. 

Example 51  
A) A company X — ordering party from Member State A — sends goods of value EUR 400 to a company Y in Member 
State B for processing. Company X is the owner of the goods. Company Y is receiving EUR 50 for work carried out. The 
processed goods are delivered back to company X. 

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Figure 16: Standard case of processing under contract 

The data  3 

B)  A  company  X  from  Member  State A  sends  goods  of  value  EUR 400  to  a  company  Y  in  Member  State B  for 
processing.  Company  X  is  the  owner  of  the  goods.  Company  Y  is  receiving  EUR 50  for  work  carried  out.  The  final 
products are sold by company X to a company Z in Member State C for EUR 500. The processed goods are delivered 
from company Y directly to company Z. 
Company  X  is  obliged  to  register  for  value  added  tax  (VAT)  in  Member  State  B  and  thus  to  report  within  Intrastat; 
company Y would report only if company X omitted to register for VAT in Member State B. The transaction is considered 
as  transfer  of  goods(1)  in  the  meaning  of  Article  17(1)  of  Council  Directive  2006/112/EC  and  thus  as  intra-EU  supply 
from Member State A to Member State B and the subsequent sale as intra-EU supply from Member State B to Member 
State C. 
NB: Since an intra-EU supply from Member State B to Member State C is declared for taxation purposes, the taxable 
amount reported within Intrastat by the VAT registration of company X in MS B (EUR 500) is higher than the value of 
goods after the processing (EUR 450); the reported value comprises also the trade margin of company X. 

Figure 17: Processing with subsequent sale to another Member State 

Goods  undergo  processing  in  Member  State  B;  the  processor  —  resident  in  Member  State  B  —  is  not  owner  of  the 
goods  because  neither  Company  X  nor  its  VAT  registration  in  Member  State  B  transfers  ownership.  The  processed 
goods do not return to the initial Member State of export. 
C)  A  company  X  from  Member  State  A  sends  goods  of  value  EUR  400  to  a  company  Y  in  Member  State  B  for 
processing. Company Y receives EUR 50 for work carried out. The final products are sold by company X to a company 

(1)  'Transfer to another Member State' shall mean the dispatch or transport of movable tangible property by or on behalf of the taxable person, for 
the  purposes  of  his  business,  to  a  destination  outside  the  territory  of  the  Member  State  in  which  the  property  is  located,  but  within  the 
Community. 

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98 

 MS B  MS A   NoT 41 €400       NoT 41 €400  Processing fee €50 NoT 51 €450       NoT 51 €450 Company Y — processor Company X — ordering party  MS B MS C MS A       Company Z —  purchaser VAT registration of company X in MS B NoT 52 €500 NoT 11 €500 Company Y — processor B A Company X —  ordering party / seller Payment for final product €500 = €400 + €50 + €50 (trade margin of company X) Processing fee €50 NoT 52 €450 NoT 11 €500  NoT 42 €400       NoT 42 €400  
 
 
 
 
                                                           
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Z in Member State B for EUR 500. The processed goods are delivered from company Y directly to company Z; goods 
are sold in Member State B — the Member State of processing. 
In this case company X is obliged to register for VAT in Member State B and thus to report within Intrastat; company Y 
would report only if company X omitted to register for VAT in Member State B. The transaction is considered as transfer 
of  goods  (see  footnote  above)  and  thus  as  intra-EU  supply  from  Member  State  A  to  Member  State  B  and  the 
subsequent sale as ‘domestic’ supply of goods in Member State B. 

Figure 18: Processing with subsequent sale in Member State of processing 

Company  X  does  not  transfer  ownership  of  goods  to  the  processor  in  Member  State  B;  the  processed  goods  do  not 
return to the initial Member State of export. 

470. Goods sent for processing but returned in an unprocessed state or as a side-product of the processing 
shall be reported under NoT code 5. 

Example 52  
Company X — ordering party from Member State A, sends goods of value EUR 400 to company Y in Member State  B 
for processing. Company X owns the goods. Company Y receives EUR 50 for the work carried out. Half of the goods 
undergo processing while the other half return to company X unprocessed. 

Figure 19: Return of unprocessed goods 

471. NoT codes 41 and 51 should be used when processed goods are returning to the original exporting 
country,  but  not  necessarily  to  the  ordering  company.  For  Member  States  collecting  NoT  codes  at  one 
digit level, whenever the goods are not returning to the original Member State of dispatch, NoT code 5 
should be used. 

Example 53  
A company X from Member State  A sends goods of value EUR 400 to a company Y in Member State  B for processing. 
Company  Y  receives  EUR  50  for  the  work  carried  out.  The  final  products  are  sold  by  company  X  to  a  company  Z  in 
Member State  A for EUR 500. The processed goods are delivered from company Y directly to company Z; the goods 
return after the processing to the initial Member State  of export. 

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99 

 MS B  MS A Company Z — purchaser Company Y — processor Company X — ordering party / seller No ITGS VAT registration of  company X in MS B No ITGS A B Processing fee €50  NoT 42 €400        NoT 42 €400 Payment for final product €500 = €400 + €50 + €50 (trade margin of company X)  MS B MS A  NoT 41 €400     NoT 41 €400 Processing fee €50 NoT 51 €250  Final products   NoT 51 €250 NoT 51 €200  Unprocessed goods   NoT 51 €200 Company Y — processor Company X — ordering party  
 
 
 
 
The data  3 

Even  in  this  case  company  X  is  obliged  to  register  for  VAT  in  Member  State   B  as  the  goods  do  not  return  to  that 
company(1).  Company  X  provides  statistical  information  within  Intrastat;  company  Y  would  report  only  if  company  X 
omitted to register for VAT in Member State  B. The transaction is considered as transfer of goods (see footnote above) 
and thus as intra-EU supply from Member State  A to Member State  B. 
It can be assumed that the subsequent sale of the final products will be realised under the VAT registration of company 
X in Member State  B as company X — its VAT registration in Member State  B may deduct VAT due in respect of the 
supply to it of service(2) by company Y. Since the supply of goods to another Members State is exempted from VAT, it is 
possible that the amount of deductions of the VAT registration of company X in Member State  B exceeds the amount of 
VAT due and therefore the registration will be entitled to a refund of the excess(3). 
Delivery  of  goods  to  company  Z  is  considered  as  intra-EU  acquisition  in  Member  State   A  from  Member  State   B. 
Therefore company Z is obliged to report the transaction within Intrastat. Company Z receives a foreign invoice with the 
VAT ID number of company X issued in Member State  B. 
NB:  Since  an  intra-EU  acquisition  in  Member  State   A  from  Member  State   B  is  declared  for  taxation  purposes,  the 
taxable  amount  reported  within  Intrastat  by  the  purchaser  in  Member  State   A  (EUR  500)  is  higher  than  the  value  of 
goods after the processing (EUR 450); the reported value comprises the trade margin of company X. It may happen that 
company Z will not report the NoT 51 as it is not aware that any processing was carried out in Member State  B. 

Figure 20: Processing with subsequent sale within the initial Member State of export 

472. It may be difficult to report codes 41 and 42 correctly, as at the time of import the exact destination 
of the goods after processing might not be known. Also, the final products might have several different 
destinations (for example distribution from the processing country). Part of the goods might return to the 
dispatching country, be moved to other countries, or be sold in the processing country. Similar problems 
might arise at the time of export after processing (code 51 and 52), whenever the final product consists of 
materials  coming  from  several  countries.  Therefore  PSI  should  make  suitable  estimations  in  order  to 
determine the proper NoT codes according to the share of the different country sources and destinations. 
If in exceptional cases such estimation is not possible, the application of code 42 and 52 is preferred. 

Example 54  
A) Company X from Member State  A sends goods of value EUR 400 to company Y in Member State  B for processing. 
There  are  additional  goods  of  value  EUR  100  purchased  by  company  X  from  a  company  Z1  and  delivered  directly  to 
company  Y to be used during  the processing. Company  Y  purchases goods of value EUR 25 in the domestic market 
and of value EUR 25 in another country. Company Y receives EUR 100; EUR 50 for the work carried out plus the price 
of  additional  goods  purchased  by  itself  (EUR 25  +  EUR 25).  The  processed  goods  are  delivered  back  to  company  X 
directly from company Y; goods return after the processing to the initial country of export. 

(1)  Council Directive 2006/112/EC, Article 17(2): 

The  dispatch  or  transport  of  goods  for  the  purposes  of  any  of  the  following  transactions  shall  not  be  regarded  as  a  transfer  to  another 
Member State: 
(f)  the supply of a service performed for the taxable person and consisting in valuations of, or work on, the goods in question physically carried 
out within the territory of the Member State in which dispatch or transport of the goods ends, provided that the goods, after being valued or 
worked upon, are returned to that taxable person in the Member State from which they were initially dispatched or transported. 
(2)  Processing under contract is considered as supply of service — supply of ‘work on movable tangible property’ according to VAT provisions. 
(3)  Council Directive 2006/112/EC, Article 183. 

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100 

 MS B MS A  Company Y — processor Company X —  ordering party / seller A BA  VAT registration of   company X in MS B NoT 41 €400             NoT 41 €400    NoT 41 €400 Payment for final product €500 Company Z — purchaser NoT 51 €500  = €400 + €50 + €50 (trade margin of company X)       NoT 51 €450    NoT 51 €500 Processing fee €50  
 
 
 
 
                                                           
Figure 21: Processing under contract with several suppliers 

The data  3 

B) Company X from Member State  A sends goods of value EUR 400 to company Y in Member State B for processing. 
Company  X  is  the  owner  of  the  goods.  Company  Y  receives  EUR  100  for  the  work  carried  out.  Company  Y  —  the 
processor  from  Member  State B  —  subcontracts  an  intermediate  processing  in  Member  State  C.  The  fee  for  the 
subcontracted processing is EUR 10 which is paid by company Y to company Z  — a subcontractor. When the goods 
leave Member State B their value has increased by EUR 50, i.e. the value of processing already carried out by company 
Y.  When  the  goods  return  to  Member  State  B  after  intermediate  processing  in  Member  State C,  the  processing 
continues. Subsequently company Y delivers the final products to company X. 
Company X does not transfer ownership of goods to company Y — the processor in Member State B.  As company Y is 
not  the  owner  of  the  semi-processed  goods,  it  cannot  transfer  their  ownership  to  company  Z  —  the  subcontractor  in 
Member  State C.  Both  the  initial  processor  and  the  subsequent  subcontractor  do  processing  under  contract. 
Intermediate processing in Member State C will not finish statistically the initial processing started in Member State B. If 
there was only one processing in Member State B, either the first or the last one, i.e. if company Y only passed either 
the material from Member State  A to Member State C or the finished goods from Member State C to Member State A, 
the same coding should be used. 

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 MS B Company Y — processor Goods purchased by processor in MS B €25 Company Z2 — supplier MS A MS C Company X — ordering party Company Z1 — supplier Goods purchased by processor in another country for €25 - NoT 11 Company Z3 — supplier Payment for goods delivered to processor €100  NoT 11 €100 NoT 42 €100 Processing fee €100 NoT 51 €600  NoT 51 €600  €600 = €400 + €100 + €50 (work) + €50 (additional goods) NoT 41 €400 NoT 41 €400  
 
 
 
 
 
 
Figure 22: Processing under contract with subsequent sub-contracting 

The data  3 

C) Company X from Member State A sends goods of value EUR 400 to company Y in Member State B for processing. 
Company  X  is  the  owner  of  the  goods.  Company  Y  receives  EUR  100  for  the  work  carried  out.  Company  X  also 
subcontracts an intermediate processing in Member State C. The fee for the intermediate processing is EUR 10 paid by 
company  X  to  company  Z  —  an  intermediate  processor.  When  the  goods  leave  Member  State  B  their  value  has 
increased by EUR 50, i.e. the value of processing already carried out by company Y. When the goods return to Member 
State  B  after  the  intermediate  processing  in  Member  State  C,  the  processing  continues.  Subsequently  company  Y 
delivers the final products to company X. 
Company  X  does  not  transfer  ownership  of  goods  to  company  Y  —  the  processor  in  Member  State  B  —,  nor  to 
company Z , the intermediate processor in Member State C. Both companies, the initial processor and the subsequent 
processor,  do  processing  under  contract.  Intermediate  processing  in  Member  State  C  will  finish  statistically  the  initial 
processing started in Member State  B. The same coding should be used for the case when the goods return to Member 
State B but processing is carried out by another company. 

Figure 23: Processing under contract in several countries arranged by ordering party 

Note: The coding as described in the examples B and C enables one to identify the processing operation in the Member 
States where the processing occurs, without regard to whether the goods return to the initial company or not. The usage 
of  the  second  digit  of   the  NoT  code    should  reflect  the  contractual  relationship  between  the  ordering  party  and  the 
processors  or  the  processors  themselves  and  thus  follow  the  principle  applied  in  the  alternatives  described  above. 
Recording of the transaction  in the initial and final country (which could be the same or not) should follow the coding 
described in the previous examples reflecting the possible transfer of ownership. 

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 MS B MS C MS A Company Y — processor Company X — ordering party Company Z — subcontractor NoT 41 €400 NoT 41 €400 NoT 41 €450 NoT 41 €450 Processing fee €10 Processing fee €100 NoT 51 €460 NoT 51 €460 NoT 51 €500 NoT 51 €500  MS B MS C MS A Company Y — processor Company X — ordering party Company Z — intermediate processor NoT 41 €400 NoT 42 €400 NoT 52 €450 NoT 41 €450 Processing fee €10 Processing fee €100 NoT 42 €460 NoT 51 €460 NoT 51 €510 NoT 52 €510  
 
 
 
 
 
 
 
Figure 24: Multi-country processing 

The data  3 

473. In  case  of  processing  of  vessels  and  aircraft,  the  partner  country  and  reporting  country  are 
determined by the rules for specific movements, i.e. they are allocated to the country where the economic 
owner  of  the  vessel/aircraft  is  established  and  the  country  (Member  State)  undertaking  the  processing 
under contract. 
474. Non-Community  goods  which  enter  the  EU  in  a  given  Member  State  without  release  for  free 
circulation, and move on to other Member States under customs inward processing procedures should be 
recorded  in  intra-EU  trade  statistics  accordingly.  These  transactions  should  also be  reported using NoT 
codes 4 or 5 if there is no change of ownership. 
475. The  valuation  principles  of  processing  transactions  are  described  in  the  chapters  Processing  trade 
and Value. 
476. Transaction  code  6.  This  code  is  reserved  for  particular  transactions  used  for  national  purposes. 
Examples  of  transactions  recorded  under  this  code  could  include  transactions  not  involving  transfer  of 
ownership  e.g.  repair,  hire,  loan,  operational  leasing  and  other  temporary  uses  of  less  than  two  years, 
except  processing  under  contract.  Code  6  may  have  an  important  role  in  extra-EU  trade  statistics  to 
exclude transactions out of the scope of ITGS, as the declaration of such transactions cannot be exempted 
due to Customs interest. 
477. Transaction code 7. Operations under joint intergovernmental production programmes (e.g. Airbus, 
high-speed  train)  might  involve  very  complex  processing  arrangements  between  Member  States. 
Therefore,  transaction  code  7  shall  be  used.  A  joint  production  programme  is  a  programme  for  which 
contractors from different countries join forces to carry out a major project. Businesses using transaction 
code  7  will  normally  be  prime  or  first  level  contractors.  NSAs  of  Member  States  involved  in 
intergovernmental production programmes are encouraged to agree for which projects transaction code 7 
should be applied and all PSIs concerned should be advised accordingly. 

Example 55  
The chassis of a high-speed train is manufactured in Member State A and is then sent to Member State B where the 
chassis is given a superstructure. The goods are then sent to Member State C for installation of air conditioning. These 
goods movements should be declared with transaction code 7 in each case. 

478. Transaction  code  8.  This  transaction  code  can  be  used  for  transactions  involving  the  supply  of 
building materials and technical equipment under a general construction or civil engineering contract for 
which no separate invoicing of the goods is done and an invoice for the total contract is issued. In other 
words,  the  contract  will  usually  cover  the  movement  of  goods  and  services  combined.  The  value  to  be 
declared  for  ITGS  shall  cover  only  the  value  of  the  goods  (whenever  possible,  estimates  might  be 
necessary to apportion the different values of goods and services in the total amount of the contract). If 
goods  and  services  are  invoiced  separately  the  transaction  code  should  be  1.  This  transaction  code  is 
useful for BoP and NA compilers to avoid double counting of materials reported also in the framework of 
International Trade in Services Statistics. 
479. Transaction code 9. Other transactions not elsewhere included shall be reported using code 9. This 
concerns  movements  of  goods  where  there  is  no  actual,  anticipated  or  intended  future  transfer  of 
ownership  and  where  the  movements  cannot  be  classified  under  the  other  transaction  codes.  The 
following transactions should be declared with transaction code 9: 

  Hire, operational lease with a duration of more than 2 years (code 91); 

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103 

 Initial country Final country MS B MS C MS A Processor 2 Processor 1 Processor 3 NoT 5x NoT 4x NoT 5x … … NoT 4x NoT 5x NoT 4x  
 
 
 
The data  3 

  Transfer  of  goods(1)  —  without  transfer  of  ownership,  or  change  of  ownership  involves  no 
resident unit in the receiving Member State (it might be difficult for supplier to identify whether 
the receiver is a resident in the receiving Member State or not) — to another Member State for 
logistical reasons (e.g. stock movements) (code 99); 

  Waste  treatment  and  disposal;  no  exclusion  as  temporary  movement  since  the  processing 

(transformation) will be carried out (code 99). 

Example 56  
A) Operator X is established in Member State A. For logistical reasons the goods are moved to Member State B, but the 
ownership is retained by X. According to EU VAT rules X has to apply for a VAT registration in Member State B and 
declare the goods movement as intra-EU supply in Member State A and as acquisition in Member State B. Accordingly, 
the transaction is to be reported for Intrastat under code 9. 
B) Company X in Member State A orders goods in a non-member country C. The goods are delivered to Member State 
A by passing through Member State B where they are declared for free circulation under CPC 4200 (goods released for 
free  circulation  which  are  the  subject  of    VAT-exempted  supply  to  another  EU  Member  State).  In  Member  State  B  a 
dispatch to Member State A should be reported under NoT code 99 as the goods became Community goods statistically 
by the release for free circulation. 

480. Considerations  on  whether  to  use  NoT  code  1  or  9  should  be  based  on  the  analysis  of  change  of 
ownership from the country perspective and for the entire period during which the goods are staying in a 
Member State. 
481. For those goods registered in VAT as intra-EU transactions between the two tax registrations of the 
same business entity, NoT is decided based on the transactions followed by the cross-border movement 
without change of ownership. If the goods are later sold to a resident in the Member State of arrival, then 
NoT code should be 19. 
482. If the goods return to the dispatching Member State without change of ownership (the reason for the 
movement  was  connected  to  logistical  reasons  only)  or  the  VAT  registration  in  the  acquiring  Member 
State sells the goods to another non-resident entity and the goods leave the Member State, code 99 should 
be used. 
483. There  might  be  chain-transactions  between  non-residents  and  residents  until  the  goods  leave  or 
finally stay in the acquiring Member State. As a rule of thumb the decision on whether to use NoT 19 or 
99  should  be  based  on  whether  or  not  there  was  a  resident  trader  in  one  of  the  transactions  in  the 
transaction chain. 

Example 57  
Company X is established in Member State A and operates a regional distribution centre in Member State B. Company 
X moves goods of book value EUR 100 to Member State B for intended future sale to Company Y in Member State B or 
company  Z  in  Member  State  C  (not  decided  yet,  but  goods  will  not  return  to  Member  State  A).  Although  there  is  no 
change of ownership by the time of the cross-border movement, according to EU VAT rules X has to apply for a VAT 
registration in Member State B and declare the goods of value EUR 100 as intra-EU supply in Member State A and as 
acquisition in Member State B by the time of the cross-border movement. Later on, company X sells half of the goods to 
company Y for EUR 60, and the other half to company Z for EUR 60. The sale to company Z has to be declared as VAT 
intra-EU supply in Member State B and as acquisition in Member State C (there is no resident owner in Member State B 
during  the  transactions).  If  the  contractual  arrangement  between  the  seller  and  its  distribution  centre  is  based  on 
consignment/sale commission agreement, code 12 should be used. 

(1)  As the non-resident operator keeps the ownership of the goods which are located in another Member State, this operator shall register for VAT 
in  that  Member  State.  When  supplying  those  goods  to  a  person  from  that  Member  State  or  from  another  Member  State,  the  transaction 
becomes taxable in the Member State where the goods are located. 

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Figure 25: Non-resident transaction 

The data  3 

3.12  Preferential treatment on import 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(k), Article 6(1)(f) 

Commission Regulation (EU) No 92/2010, Article 2(2)(p) 

Commission Regulation (EU) No 113/2010, Article 11 

484. NSAs  are  required  to  collect  information  on  the  preferential  treatment  of  imported  goods.  This 
information  relates  only  to  extra-EU  trade  and  only  to  imports.  Information  about  this  data  element  is 
available  in  SAD-box 36.  The  legislation  requests  that  Customs  transmits  to  NSAs  the  information  on 
their actually applied preferential treatment and not the treatment initially requested by the declarant. The 
reasons for a difference between  ‘requested’ and ‘granted’ preferential treatment  might e.g. be, that the 
goods 

  did not qualify for the requested preferential treatment or 
  were eligible for a different treatment than the requested one. 

485. As  a  general  rule,  the  preferential  tariff  system  is  designed  to  provide  reduced  or  free  rates  of 
customs duty to goods which have been manufactured in accordance with the preference ‘rules of origin’. 
These ‘rules’ are  in place to  ensure  that  a  specified  amount of work  or  processing  is undertaken  in the 
preference-receiving  country.  In  the  case  of  the  EU’s  Generalised  System  of  Preferences  (GSP),  the 
preference system enables the Least Developed and Developing Countries to penetrate the EU market and 
it encourages them to become more established. Proof of the preferential origin of the goods, normally a 
certificate  (e.g.  a  GSP  Form  A),  certified  by  an  authorised  body,  must  be  presented  with  the  goods  to 
claim the preferential rate of duty. 
486. However tariff treatment covers not only preferences in the narrow sense (e.g. reduced import duty 
rates under the GSP or under arrangements with the Countries of Africa, the Caribbean and the Pacific), 
but also various other measures affecting customs duties like ‘tariff quotas’, ‘suspensions’ and ‘end-uses’. 
SAD-Box 36 also covers information about the application of the normal non-member country duty rates 
and non-imposition of customs duties under customs union agreements. 
487. For reasons connected with the efficiency of the legislation, no comprehensively valid list of codes 
to  be  used  in  this  box  can  be  established.  Therefore  a  ‘matrix  approach’  has  been  taken:  the  necessary 
three-digit  code  has  to  be  made  up  of  a  one-digit  code  (standing  for  a  general  measure)  followed  by  a 
two-digit code (standing for a more detailed breakdown). It has to be noted that not all code combinations 
in the matrix are possible from a legal point of view or would make sense. 
488. Furthermore,  as  SAD-box 36  is  logically  linked  to  SAD-boxes 33  (‘Commodity’)  and  in  some 
extent with SAD-box 34a (‘Country of origin’),  only certain commodities originating in certain countries 
may be eligible for any given tariff treatment at any given time. 

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 MS B Distribution centre —  VAT registration of  company X in MS B Company Y — purchaser MS A MS C Company X — seller Company Z — purchaser NoT 19 €50 NoT 99 €50 NoT 19 €50 NoT 19 €50 Payment €60 NoT 11 €60      NoT 99 €60 Payment €60 No ITGS  
 
 
 
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489. Annex  38  of  Commission  Regulation  (EEC)  No  2454/93  provides  the  legal  basis  for  these  codes. 
More  information  about  the  use  of  preference  codes  and  tables  with  explanation  can  be  found  in  SAD 
guidelines. 

Table 8: Preference codes 

First digit of the code 

1 

2 

3 

4 

Tariff arrangement erga omnes 

Generalised System of Preferences 

Tariff preferences other than those mentioned under code 2 

Non-imposition of customs duties under the provisions of customs union agreements concluded 
by the Community 

Next two digits of the code 

00  None of the following 

10  Tariff suspension 

15  Tariff suspension with specified end-use 

18  Tariff suspension with certificate confirming the special nature of the product 

19  Temporary suspension for products imported with a certificate of airworthiness 

20  Tariff quota 

23  Tariff quota with specified end-use 

25  Tariff quota with certificate confirming the special nature of the product 

28  Tariff quota following outward processing 

40  Special end-use resulting from the Common Customs Tariff 

50  Certificate confirming the special nature of the product 

Example 58  
Code  100:  1  means  tariff  arrangement  applicable  for  all  non-member  countries  and  00  means  that  the  preferential 
customs duty is either not requested or does not exist. 
Code 200 means application of GSP duty rate without conditions or limits. 
Code 220 means that certain tariff quotas are granted only pursuant to the EU legislation on the GSP. 
Code  400  means  non-imposition  of  customs  duties  under  customs  union  agreements  concluded  by  the  Community, 
(e.g. of customs union agreements with Andorra, San Marino and Turkey). 

490. Whilst  NSAs  can  compile  the  preferential  code  from  SAD-box 36  in  the  customs  declaration,  it 
should  be  remembered  that  claims  to  preference  are  only  accepted  ‘at  face  value’,  i.e.  unless  there  is 
something  obviously  wrong  with  the  goods  at  the  time  of  receiving  the  customs  declaration  (e.g.  not 
covered  by  a  preference  certificate  of  origin),  the  claim  to  preference  will  usually  be  accepted  by  the 
customs authority. However, that preference may subsequently be overturned or refused. 
491. This  is  because  all  of  the  EU’s  preferential  tariff  arrangements  provide  for  the  post  clearance 
verification, by the importing customs authorities, of claims to preference. Such investigations can affect 
consignments up to three years old. When it is discovered that the goods do not qualify for preferential 
status,  the  claim  to  preference  is  refused  and  the  normal  rate  of  duty  becomes  payable.  Therefore 
Customs  are  required  to  transmit  to  NSAs  the  information  on  their  actually  applied  preferential 
treatment to enable NSAs to update the statistics. 

3.13  Mode of transport 
492. Availability of trade data by mode of transport is very important for many purposes, including the 
formulation  of  transportation  policy,  the  monitoring  of  international  transport  routes,  the  assessment  of 
the impact of trade on the environment etc. 

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3.13.1  Intra-EU trade statistics 

The mode of transport 

Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(2)(e) and Annex 

Commission Regulation (EC) No 1982/2004, Article 12 and Annex V 

493. Under the provisions on intra-EU trade statistics, data element ‘the mode of transport’ is optional. 
The mode of transport at the frontier is determined by the active means of transport by which the goods 
are presumed to be going to leave the statistical territory of the Member State of dispatch, on dispatch, 
and  by  the  active  means  of  transport  by  which  the  goods  are  presumed  to  have  entered  the  statistical 
territory of the Member State of arrival, on arrival. 
494. The  Member  States  which  collect  the  mode  of  transport  may  use  the  codes  given  in  Annex  V  of 
Commission Regulation (EC) No 1982/2004. The coding is the same as the one applied in extra-EU trade 
statistics (see Table 9 and the compilation rules below). Data transmission to Eurostat is optional. 
495. In the Member States which collect the mode of transport and apply a simplification threshold, PSIs 
may be exempted from providing information on the mode of transport if they belong to the group which 
benefits from the simplified reporting obligation. 

3.13.2  Extra-EU trade statistics 
496. Under  legislation  on  extra-EU  trade  statistics  applicable  from  the  beginning  of  2010,  three  data 
elements on the mode of transport must be compiled and transmitted to Eurostat. These data elements are 
the following: the mode of transport at the frontier, the internal mode of transport, the container. 
497. Until the end of 2009, the nationality of the means of transport was an obligatory data element too. 
However,  under  the  new  regulation  on  extra-EU  trade  statistics,  Member  States  may  compile  the 
nationality of the means of transport as optional information. 
498. The  mode  of  transport  is  reported  according  to  the  codes  specified  in  Annex  III  of  Commission 
Regulation (EU) No 113/2010. 

Table 9: Mode of transport codes 

Code 

Title 

1 

2 

3 

4 

5 

7 

8 

9 

Sea transport 

Rail transport 

Road transport 

Air transport 

Postal consignment 

Fixed transport installations 

Inland waterway transport 

Own propulsion 

499. Code 5 (Postal consignment)  is applied in cases where goods are transferred by a postal service, i.e. 
postal  operators  authorised  by  a  Member  State  to  provide  services  governed  by  the  Universal  Postal 
Union  Convention(1)only  if  the  means  of  transport  is  not  known.  Goods  transported  by  private  courier 
services shall be included in this category only if the active means of transport is unknown. Otherwise the 
relevant code should be used. 
500. Code  7  (Fixed  transport  installations)    is  applied  to  installations  for  continuous  transport  such  as 
pipelines  or  electric  power  lines.  Correctness  of  this  code  may  be  assured  by  checks  for  consistency 
between the mode of transport and the commodity code. 
501. Code  9  (Own  propulsion)  is  applied  for  means  of  transport  (mainly  aircraft  and  ships)  which  are 
themselves the subject of the trade transaction and cross the border under their own propulsion. In cases 

(1)  Definition as in the Draft IP to the Union Customs Code - website: http://www.upu.int/ 

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where  these  means of  transport  are  carried  on  other  means of  transport  (e.g.  lorries, vessels,  trains)  the 
code 9 shall not be applied. 

The mode of transport at the frontier 

Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(m)(i) and Article 
6(1)(g) 

Commission Regulation (EU) 92/2010, Article 2(2)(q) 

Commission Regulation (EU) 113/2010, Article 12(1) and Annex III 

502. The mode of transport at the frontier indicates the active means of transport by which, on export, the 
goods are presumed to leave the statistical territory of the European Union and, on import, the goods are 
presumed to have entered the statistical territory of the European Union. Information about the mode of 
transport at the frontier is to be derived from the customs declaration (SAD-box 25). 

The internal mode of transport 

Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 5(1)(m)(ii) and Article 
6(1)(g) 

Commission Regulation (EU) 92/2010, Article 2(2)(r) 

Commission Regulation (EU) 113/2010, Article 12(1) and Annex III 

503. The internal mode of transport indicates, if applicable, the active means of inland transport by which 
the goods reach  the place of arrival, on  import,  or  are presumed  to have left  the place of  departure, on 
export. Information about this data element is to be derived from the customs declaration (SAD-box 26). 
504. Information on the internal mode of transport is transmitted to Eurostat only when collection of this 
data  element  is  foreseen  by  the  customs  regulation.  According  to  the  Union  Customs  Code 
delegated/implementing  acts,  information  on  the  internal  mode  of  transport  is  not  to  be  provided  when 
customs formalities are carried out at the point of exit/entry from/to the customs territory of the EU. 

The container 

Regulation  (EC)  No  471/2009  of  the  European  Parliament  and  of  the  Council,  Article  5(1)(m)  (iii)  and 
Article 6(1)(g) 

Commission Regulation (EU) 92/2010, Article 2(2)(s) 

Commission Regulation (EU) 113/2010, Article 12(2) 

505. Information  about  container  indicates  whether  or  not  goods  are  transported  in  containers.  The 
following codes are used for the data on the container: 

0 —  if goods are not transported in containers when crossing the border of the statistical territory 

of the European Union, 

1 —  if goods are transported in containers when crossing the border of the statistical territory of 

the European Union. 

506. Information about ‘Container’ is in principle available on the customs declaration (SAD-box 19) as 
customs provisions also explicitly require the ‘presumed’ container-status of the goods when crossing the 
EU frontier. However, Member States'  Customs need not collect this information ‘if they can deduce it 
from information elsewhere in the declaration and so transmit it to the Commission in compliance with 
the provisions on the collection of external trade statistics(1)’. 
507. Such ‘information elsewhere’ could e.g. be the container number indicated in SAD-box 31(2). Such 
deduction,  however,  should  only  be  possible  in  cases  of  statistically  relevant  customs  declarations 
immediately provided at the point of entry to or exit from the EU. 

(1)  Commission Regulation (EEC) No 2454/93, Annex 37, Note [9]. 
(2)  SAD-Box 1 refers to ‘Packages and description of goods; Marks and numbers - Container No(s) - Number and kind’. 

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Example 59  
A) Exports: Goods are to leave the EU in a container, at the sea port of Rotterdam. 
A.1. Where the customs declaration is provided directly int Rotterdam, the container number would be known and would 
need  to  be  indicated  for  customs  reasons  in  SAD-box 31;  when  applying  the  waiver  for  SAD-box 19,  customs  could 
use the number to deduce the status of containerisation on exit. 
A.2. Where the customs declaration is provided at an inland customs office, the concrete container number would not 
necessarily  be  known  and  the  respective  part  of  SAD-box 31  would  remain  blank;  in  such  a  case  a  waiver  for  SAD-
box 19 would lead to incorrect information on the status of containerisation on exit. 
B)  Imports:  Goods  having  entered  the  EU  in  a  container at  the  sea  port  of  Rotterdam  are  cleared  for  a  customs 
warehouse, repackaged in smaller consignments and subsequently cleared for free circulation. 
Although  the  goods  had  crossed  the  EU  border  in  a  container,  they  are  not  in  a  container  when  declared  for  free 
circulation and the respective part of SAD-box 31 would remain blank; in such a case a waiver for SAD-box 19 would 
lead to incorrect information on the status of containerisation on entry. 

508. Data on container are not provided to Eurostat when the mode of transport at the frontier is indicated 
by codes 5 (Postal consignment), 7 (Fixed transport installations) and 9 (Own propulsion). 

3.14  Region 

3.14.1  Intra-EU trade statistics 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(2)(c) and Annex 

509. As  additional  information  Member  States  may  collect  on  dispatch  —  Region  of  origin  and  on 
arrival  —  Region  of  destination.  This  indicator  is  optional  and  serves  for  national  needs  of  Member 
States, e.g. for the dissemination of ITGS data at regional level. 
510. The  Region  of  origin  is  defined  by  the  regulation  as  the  region  in  the  Member  State  of  dispatch, 
where: 

a)  the  goods  were  produced  or  erected,  assembled,  processed,  repaired  or  maintained,  or  failing 

that, 

b)  the goods were dispatched, or failing that, 
c)  the commercial process took place. 

511. Region  of  origin,  to  be  collected  on  dispatch,  means  the  region  where  the  goods  were  produced, 
processed, maintained or any other actions with them could take place. So the region of origin will be an 
administrative region in Member State of dispatch, where a value was last added. 
512. The  region  from  which  the  goods  were  initially  dispatched  to  another  Member  State  means  that 
goods could be kept in storage before they were sold. This rule may apply if the region of last added value 
is not known, or there are many. The storage of the goods inherent in their transportation is not relevant to 
this case. 
513. The  region,  where  a  commercial  process  related  to  exported  goods  took  place  means  the  region, 
where the commercial transaction took place or the trader (exporter) is established. This rule may apply 
both  in  cases  when  the  region  of  last  added  value  and  the  region  of  dispatch  are  not  possible  to  be 
identified. 
514. The Region of destination is defined as the region in the Member State of arrival where: 

a)  the goods are to be consumed or erected, assembled, processed, repaired or maintained, or failing 

that, 

b)  the goods are to be acquired, or failing that, 
c)  the commercial process is to take place. 

515. Region of destination, to be collected on arrival of goods, means the region where the goods will be 
consumed, processed, maintained or any other actions with them could take place. Region of destination 
should be considered the administrative region in Member State of arrival, where a value is first added. 
516. The region where the goods will be stored before their final distribution within the Member State of 
arrival is considered under point b). This rule may apply if the region of consumption or first added value 
is not known, or there are expected to be many. The storage of the goods inherent in their transportation is 
not relevant to this case. 
517. The rule under point c) may apply whenever the region of first value added and the region where the 
goods were acquired are not possible to be identified. Then the region where the commercial transaction 
is to take place or the trader (importer) is established should be used to decide. 

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The data  3 

518. Member States collecting the region of origin should define the system of codes in such a way that 
it is possible to measure the re-exports of goods of non-national origin. Member States should define the 
regions in accordance with the administrative subdivision of the country in line with NUTS nomenclature. 

3.14.2  Extra-EU trade statistics 
519. The region is not required to be collected by regulation on extra-EU trade statistics. However some 
Member States collect this indicator for national needs. In this case the same rules as for Intrastat should 
be applied. 

3.15  Delivery terms 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 9(2)(d) and Annex 

Commission Regulation (EC) No 1982/2004, Article 11 and Annex IV 

520. Member  States  may  collect  the  ‘delivery  terms’    as  optional  information  in  Intrastat  by  recording 
only the code or, in addition, the place of delivery. The collection of this information is not required by 
the  regulation  on  extra-EU  trade  statistics  but  the  Union  Customs  Code  delegated/implementing  acts 
allow  Member  States  to  do  so  on  SAD-box 20.  Hence  it  is  up  to  Member  States  to  decide  whether  to 
collect it or not. 
521. Although  the  information  is not required  to  be  collected  directly,  it  is  very important  to know  the 
delivery  terms  for  correct  calculation  of  statistical  value  and  CIF/FOB  adjustments  within  balance  of 
payments  statistics.  NSAs  are  encouraged  to  use  the  delivery  terms  whenever  available  on  customs 
declarations. 
522. The  delivery  terms  are  defined  as:  ‘Those  provisions  of  the  sales  contract  which  lay  down  the 
obligations of the seller and the buyer respectively in accordance with the Incoterms of the International 
Chamber of Commerce’. 
523. Incoterms  are  unified  trade  definitions  i.e.  global  shipping  terms.  They  are  key  elements  of 
international sales contracts. The main advantage of using Incoterms is that they are a common language 
of the trade. Being only rules for the interpretation of global shipping terms included in specified articles 
of  the  sales  contract,  and without prejudice  to  the  rest of other  contract terms,  they  clearly  indicate  the 
point at which the responsibilities for the costs and risk factors related to the delivery of the goods shift 
from the seller to the buyer (exporter/importer). 
524. Incoterms 2010 are grouped into four categories (see Table 10), designed by the first letter of each 
term i.e. E, F, C and D. Terms beginning with F refer to shipments where the primary cost of shipping is 
not paid for by the seller. Terms beginning with C deal with shipments where the seller pays for shipping. 
E terms occur when a seller's responsibilities are fulfilled and when goods are ready to depart from their 
facilities.  D  terms  cover  shipments  where  the  shipper/seller's  responsibility  ends  and  when  the  goods 
arrive at some specific point. Because shipments are moving into a country, D terms usually involve the 
services  of  a  customs  broker  and  a  freight  forwarder.  In  addition,  D  terms  also  deal  with  the  pier  or 
docking charges found at virtually all ports and determining who is responsible for each charge. 
525. Since  there  is  a  strong  correlation  between  the  freight  and  insurance  amounts  agreed  under  each 
delivery term, for statistical purposes the delivery terms can be classified in two main types, a FOB-type 
and a CIF-type (see Table 10). This distinction may indicate in what way to adjust the invoice value when 
estimating the statistical value. 

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Table 10: Delivery terms codes 

Acronym 
group 

Code 

Incoterm 

Seller responsibilities 

Type of term 

The data  3 

E 

F 

C 

EXW  Ex Works, named place 

the  goods 
Seller  makes 
available 
own 
his 
at 
premises to the buyer 

FCA  Free Carrier, named place 

FAS  Free Alongside Ship, named 

port of shipment 

FOB  Free On Board, named port of 

shipment 

CFR  Cost and Freight, named port 

of destination 

CIF  Cost, Insurance and Freight, 

named port of destination 

CPT  Carriage Paid To, named 
place of destination 

CIP  Carriage and Insurance Paid 

To, named place of destination 

is 
Seller 
deliver 
the  goods 
carrier named by the buyer 

responsible 
to 

to 
the 

is 

responsible 

Seller 
for 
contracting  and  paying  for 
carriage  of  the  goods,  but 
no responsible for additional 
costs  and  risks  related  to 
the  goods  once  they  have 
been shipped 

D 

DAP  Delivered At Place 

DAT  Delivered At terminal 

DDP  Delivered Duty Paid, named 
place of destination 

Seller  is  responsible  for  all 
costs  and  risks  related  to 
delivering  the  goods  to  the 
named place of destination 

FOB 

FOB 

FOB 

FOB 

CIF 

CIF 

CIF 

CIF 

FOB 

CIF 

CIF 

526. However, for statistical data collection, the codes of delivery terms that are defined and adopted by 
the  implementing provisions  on  intra-EU  trade  statistics  or  by  the  International  Chamber  of  Commerce 
should be used if the provisions are not updated. More detailed information about Incoterms is available 
on the official site of the International Chamber of Commerce www.iccwbo.org 
527. There  exist  certain  problems  related  to  the  collection  of  delivery  terms.  Unfortunately  for 
statisticians the delivery terms are not always defined for trade transactions, and the trader cannot provide 
this information on the Intrastat or customs declaration. However, for statistical purposes (for calculating 
CIF/FOB  adjustment  ratios,  for  estimation  of  statistical  value,  etc.)  a  sample  of  transactions  might  be 
sufficient. 

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Specific goods or movements  4 

4  Specific goods or movements 

4.1 

Industrial plant 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 
Commission Regulation (EC) No 1982/2004, Article 15 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 
Commission Regulation (EU) No 113/2010, Article 17 

528. Definition.  A  complete  industrial  plant  refers  to  an  entity  required  for  producing  goods  (e.g. 
petroleum  refinery,  power  station)  or  services  (e.g.  hospital).  An  industrial  plant  is  constituted  by 
machines,  appliances,  engines,  apparatus,  equipment  and  materials  belonging  to  different  commodity 
codes. Other goods used to construct such a plant can be considered to belong to it unless excluded from 
statistics  according  to  the  Annex  I  of  the  Commission  Regulations  (EC)  No 1982/2004  and  (EU) 
No 113/2010 (e.g. tools needed for construction work that are returned after the completion of the plant). 
529. Conditions for application. In defining the commodity codes of goods to be delivered to complete 
industrial  plant,  simplified  procedures  can be  applied both  for arrivals and dispatches  in  intra-EU  trade 
and only for export in extra-EU trade, under certain conditions. 
530. The  total  value  of  the  industrial  plant  shall  be  more  than  EUR  3  million  in  order  to  apply 
simplification in the reporting. An exception to this is complete industrial plant to be reused, for which 
there is no such limit value. The total value is obtained by adding up the values of the different parts. The 
value of goods supplied free of charge is defined according to the price which would be invoiced in the 
event of normal sale or purchase. 
531. It can be beneficial for Member States to keep track of industrial plant movements, for instance, to 
assess whether the conditions for simplification are met. Therefore the competent national authorities 
listed in the chapter 98 of the CN are encouraged to require prior authorisation of PSI to use simplified 
reporting of an industrial plant through submission of a written application. 
532. This application should contain the following information: 

  description of the industrial plant; 
  Member State of destination or of consignment (intra-EU trade); 
  non-member partner country (extra-EU trade); 
 
  delivery period (anticipated beginning and completion of the deliveries); 
  description or list of goods to be delivered (possibly at CN2 level). 

total value of the industrial plant; 

533. As the legislation allows but does not prescribe the use of CN chapter 98 for reporting component 
parts of industrial plant, each Member State decides on the simplified reporting. The decision of the NSA 
to admit the use of chapter 98 for a complete industrial plant and/or its components is a statistical decision 
that is not binding for customs. Customs may require a detailed declaration from the trader even if he has 
a permission of the NSA to use CN chapter 98. What is not binding for national Customs may be refused 
by Customs of the third country, too.  
534. To  avoid  asymmetries  in  intra-EU  trade  it  may  be  reasonable  to  use  CN  chapter  98  also  in  the 
partner Member State if another Member State has given a company the permission to use CN chapter 98 
for the industrial plant even if the value criteria is not met in partner Member State as only a component is 
traded  from  there.  So  NSAs  are  encouraged  to  manage  the  application  of  simplified  reporting  for 
industrial  plant  in  the  way  which  minimises  the  asymmetries  in  the  trade  in  goods  with  other  Member 
States. NSAs which require prior authorisation may involve partner NSAs in decision making procedure 
following the relevant legal provisions. 
535. The aim of this simplification is to reduce the burden on the companies involved by not requiring all 
the  commodities  which  make  up  an  industrial  plant  to  be  classified  separately.  Additionally,  statistical 
authorities may allow non-declaration of the quantity of goods (net mass, supplementary unit). 

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Specific goods or movements  4 

536. Reference period to be applied. The reference period for the delivery of the goods is the month in 
which  the  cross-border  transaction  takes  place.  If  some  components  are  delivered  as  staggered 
consignments(1),  they  only  have  to  be  declared  once.  They  are  declared  in  the  month  in  which  the  last 
delivery of the goods in question takes place. 
537. Simplified  CN  codes  to  be  used.  The  8-digit  CN  code  for  goods  to  be  delivered  to  a  complete 
industrial plant is formed in the following way: 

  The first four digits are 9880; 
  The fifth and sixth digits must correspond to the number of that CN chapter (2 digits) to which 

the commodity code of the regrouping belongs; 

  The seventh and eighth digits are 0. 

Example 60  
A Finnish company has sold a complete power plant. For its construction, steel pipes, among other things, are exported 
from Finland. The commodity code of these pipes is 9880 73 00. 

4.2  Staggered consignments 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 
Commission Regulation (EC) No 1982/2004, Article 16 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 
Commission Regulation (EU) No 113/2010, Article 18 

538. Objective.  The  objective  of  the  provisions  on  staggered  consignments  is  to  make  declaration 
simpler for the PSI. The requirements of the article for the application of this simplification are the same 
for  intra-EU  and  extra-EU  trade.  The  legislation  does  not  oblige  Member  States  to  implement  this 
simplification; they may do so based on their national situation and the needs of traders and producers. 
The  application  of  this  simplification  in  extra-EU  trade  statistics  depends  on  the  decisions  and  rules 
defined by customs administrations. 
539. Definition.  Staggered  consignments  means  the  delivery  of  components  of  a  complete  item  in  an 
unassembled  or  disassembled  state  which  is  shipped  during  more  than  one  reference  period  for 
commercial or transport-related reasons. 
540. Conditions. The following conditions have to be met: 

  All components shall when assembled form a single, complete and classifiable commodity; 
  The shipment is between a single dispatcher and a single consignee; 
  The delay between the first and last shipment is only for logistical reasons. 
Therefore, the following transactions cannot be reported as staggered consignments: 

  Movements of stock; 
  Components diverted to another use; 
  The supply of spare parts. 

541. Reference  period.  The  reference  period  for  arrivals/  dispatches  or  imports/exports  of  staggered 
consignments may be adjusted so that data is reported only once, in the month when the last consignment 
is received or dispatched. 
542. Valuation. The full value of the complete product must be declared with the classification code for 
the assembled product. 

(1)  Commission Regulation (EC) No 1982/2004, Article 16; 
Commission Regulation (EU) No 113/2010, Article 18. 

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Specific goods or movements  4 

543. However  this  simplification  applied  only  by  one  Member  State,  but  not  by  partner  Member  State 
may  cause  mirror  discrepancies  at  product  level.  Therefore  NSAs  are  encouraged  to  coordinate 
application of this simplification in order to avoid mirror discrepancies. 

Example 61  
An international aircraft building company produces aircraft parts (like segments, wings, etc.)  in Germany, France, the 
United Kingdom  and Spain. These parts  are transported  into one  Member State  in order to  be assembled  in the final 
aircraft. The products like wings are shipped in an unassembled state. For transport reasons some parts of the wing can 
be transported by air, the other parts (like lamps, bolts etc.) may be transported by road. All these parts are meant to be 
integrated into one initial product (wing) on the manufacture site of destination. 
In such cases Member States may allow the traders to fill in Intrastat declarations only for the complete aircraft parts, 
reporting the total value and the single code of the Combined Nomenclature. 

4.3  Vessels and aircraft 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 
Commission Regulation (EC) No 1982/2004, Article 17 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 
Commission Regulation (EU) No 113/2010, Article 19 

544. Intra- and extra-EU trade in vessels and aircraft, considered as specific goods or movements, does 
not  reflect  the  physical  cross-border  movement  of  these  goods  —  standard  rule  for  recording  goods  in 
ITGS — but the change of economic ownership.  
545. Vessels  and  aircraft  concerned.  The  definition  of  'vessel'  refers  to  those  vessels  considered  as 
seagoing  according  to  CN  Chapter  89,  tugs,  warships  and  floating  structures.  Possible  CN  codes  are: 
8901 10 10,  8901 20 10,  8901 30 10,  8901 9010,  8902 00 10,  8903 91 10,  8903 92 10,  8904 00 10, 
8904 00 91, 8905 10 10, 8905 20 10, 8905 90 10, 8906 10 00, 8906 90 10. Trade in non-seagoing vessels, 
on  the  contrary,  falls  under  the  standard  rules  for  compiling  trade  in  goods  statistics.  Aircraft  includes 
aeroplanes within CN code 8802 30 and 8802 40; the other vehicles of CN Chapter 88 except 8802 60 10 
are subject to standard rules. 
546. Economic  ownership.  The  economic  owner  of  a  vessel/aircraft  is  a  taxable  person  (in  intra-EU 
trade) and a natural or legal person (in extra-EU trade) who claims the benefits associated with the use of 
a vessel/aircraft in an economic activity and therefore the person who accepts also the associated risks. 
547. The economic owner may be the same as the legal owner, but he may also differ. Under some legal 
arrangements,  risks  and  benefits  are  split  between  different  parties.  Therefore  the  substance  of  the 
transaction, not a title of the contract, shall be considered in order to identify the economic owner of the 
vessels and aircraft.  

Example 62  
A) Company X — resident in Member State A is selling a vessel/aircraft to company Y — resident in Member State B. 
Company Y will become the legal owner and also the economic owner of the vessel/aircraft.  
Dispatch from Member State A to Member State B/arrival in Member State B from Member State A is recorded as the 
economic ownership is transferred. 

Figure 26: Trade in vessels/aircraft — legal and economic ownership transferred to the one entity 

B) Company X — resident in MS A sells the legal property of a vessel/aircraft to company Y — resident in MS B. Company X remains the economic 
owner. Company Y will become only the legal owner of the vessel/aircraft.  
No transaction is reported in ITGS as the economic ownership does not change. A financial transaction will be recorded in BoP. 

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114 

 MS A Company X (seller) is legal and economic owner. MS B Company Y (purchaser) will become legal and economic owner. Transfer of legal ownership  Transfer of economic ownership  Cash flow  
 
 
 
 
 
Figure 26: Trade in vessels/aircraft — only legal ownership transferred 

Specific goods or movements  4 

C) Company X — resident in MS A is selling a vessel/aircraft to company Y — resident in MS B.  Company Y will become only the legal owner of 
the vessel/aircraft as the company Z established in MS C — the mother of the company Y becomes economic owner of the vessel/aircraft.  
Let's assume that the transactions are interlinked. Then dispatch in MS A to MS C/arrival in MS C from MS A is recorded in ITGS. 

Figure 27: Trade in vessels/aircraft — legal and economic ownership transferred to two different entities 

4.3.1  Tools to identify the economic owner 
548. The ITGS compilers may identify the economic owner of a vessel and aircraft, using either the list 
of indicative criteria or the business accounts kept in accordance with International Accounting Standards 
No 17 (IAS17)(1) when fulfilling the preconditions and depending also on the available information. 
549. List  of  indicative  criteria.  Several  indicators  which  may  be  used  individually  or  in  combination, 
enable compilers to identify the economic owner of a vessel/aircraft. 
550. An entity would be regarded as the economic owner of a vessel/aircraft (even if it is not the legal 
owner) if:  

a)  the entity accepts all or most of the operating risks (losses) related to the use (operation) of the 
vessel/aircraft and receives all or most of the economic benefits (profits) from the use (operation) 
of the vessel/aircraft; 

b)  the entity is responsible for providing (paying for) repair and maintenance of the vessel/aircraft; 
c)  the entity has the option to purchase the vessel/aircraft at the end of the lease period at a price 

that is lower than the fair value; 

d)  the entity leases the vessel/aircraft so that the present value of the lease payments amounts to the 

fair value of the vessel/aircraft at the inception of the lease; 

e)  the entity leases the vessel/aircraft for the major part of its economic life; 
f)  the entity has the unilateral right to terminate the lease contract; 
g)  the  entity  has  responsibility  for  replacing  the  vessel/aircraft  in  the  event  of  a  serious  and 

prolonged breakdown; 

h)  the vessel/aircraft is leased by the entity from a purely financial intermediary, even if called an 

aircraft or ship leasing company; 

i)  the entity uses the vessels/aircraft in its main activity. 

551. When the list of indicative criteria is used to decide on the economic owner of a vessel/aircraft as 
many  criteria  as  possible,  depending  on  the  availability  of  information,  shall  be  evaluated  in  order  to 
decide on the economic owner of a vessel/aircraft. The criterion a) is considered as the most important; 

(1)  International Accounting Standards are developed by the International Accounting Standards Committee, whose purpose is to develop a single 
set of global accounting standards. These standards should ensure a high degree of transparency and comparability for financial reporting of 
publicly traded companies. 

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115 

 MS A Company X (seller) is legal and economic owner. MS B Company Y in (purchaser) will become only legal owner. Cash flow Transfer of legal ownership  MS A Company X (seller) is legal and economic owner. MS B Company Y (purchaser - contractual party) will become legal owner. Cash flow Transfer of legal ownership  MS C Company Z will become economic owner. Transfer of economic ownership  
 
 
 
 
                                                           
Specific goods or movements  4 

the  remaining  criteria  and  their  order  could  be  used  as  additional  practical  tools  for  assessing  the 
substance of the transaction. 
552. The terminology used for the definition of the criteria may be incomprehensible to the staff of the 
different  parties  (operators,  leasing  companies,  charterers,  agents  etc.)  involved  in  the  shipping  and 
aircraft industries. Therefore it is necessary to translate these theoretical concepts into business language, 
i.e. to transfer it into a set of practical and understandable questions. 

Example 63  
a) Does the operator accept the main risks — commercial loss? 
b) Is the operator responsible for the repair/maintenance of the craft? 
c) Does the lessee have an option to buy the craft?  
d) Do the lease payments equal the value of the craft?  
e) How long is the lease? Does it cover the major part of the craft’s life?  
f) Who can terminate the lease contract?  
g) Which contractual party is responsible for replacing the craft? 
h) Is the lessor a financial intermediary?  
i) What is the main activity of the lessor/operator? 

553. Business accounts kept in accordance with   IAS17.  When  the  business  accounts  are  used  to 
decide on the economic owner and the national legislation defines the accounting standards, in particular 
those related to leasing arrangements, in line with the substance of IAS17, then intention of an entity to 
include/exclude  the  vessel/aircraft  as  an  asset  in/from  its  balance  sheet  shall  indicate  that  there  is  the 
transfer of economic ownership of the vessel/aircraft. In general, publicly traded companies listed on the 
stock  exchange  shall  follow  these  standards  concerning  consolidated  accounts  (Regulation  (EC) 
No 1606/2002 of the European Parliament and of the Council). The national legislation may require that 
annual  accounts  of  these  companies  or  consolidated/annual  accounts  of  other  entities  follow  these 
standards.  
554. International  Accounting  Standards  No 17  defines  the  criteria  which  explore  the  substance  of  the 
leasing  contract  and  which  are  very  similar  to  those  included  in  the  European  Systems  of  Accounts. 
Therefore  it  is  recommended  that  NSAs  acquaint  themselves  with  information  on  how  their  national 
legislation defines  the  accounting  standards,  in  particular  those  related  to leasing  arrangements,  as  they 
can be very helpful in determining a change in economic ownership. 
555. Decision tree is a way to facilitate the decision making process. It guides the compiler(s) through the 
actual transaction or case; and gives direction on the investigations and decisions to be made. Moreover 
the decision trees provide an overview on how the different transactions are handled from ITGS and ITSS 
perspectives. 
556. As the contract labels/standards are used in the decisive boxes the substance of the transaction shall 
be  examined  and  verified  when  contacting  companies.  Either  the  list  of  indicative  criteria  or  business 
accounts (IAS17) described above can be used to validate the transaction. 

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Figure 28: Decision tree for vessels 

Specific goods or movements  4 

Figure 29: Decision tree for aircraft 

557. If a vessel/aircraft is legally owned by a natural person who does not use it for commercial purposes 
(e.g. yachts), then the natural person should be considered as the economic owner of the vessel/aircraft. 
558. As  the  size  of  the  fishing  fleets  is  controlled  through  the  fishing  licence  and  the  residency  of  the 
licence  holder  is  correlated  with  the  flag  of  the  vessel,  the  holder  of  the  fishing  licence  should  be 
considered as the economic owner of the fishing vessel. 

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 Leasing agreement? YES Voyage charter? YES No ITGS Transportation services  General change of ownership (sale & purchase) NO Sale lease-back? YES Is back lease financial? NO No ITGS Operational leasing services YES Demis or Bareboat charter? YES Decision made on the basis of investigation NO Time charter? YES No ITGS/ITSS (no transaction) Back lease is operational. NO Included in ITGS  (transaction from A to B) Included in ITSS Operational leasing services (transaction from B to A) NO Flagging? YES Establishment of institutional unit required (resident according to NA principle)? YES Included in ITGS  NO Included in ITGS  NO No ITGS/ITSS (no transaction) AND  Leasing agreement? YES Dry lease? YES No ITGS Operational leasing services  General change of ownership (sale & purchase) NO Sale lease-back? YES Is back lease financial? NO No ITGS Transportation services YES Opreational leasing? NO Included in ITGS NO Wet lease No ITGS/ITSS (no transaction) Back lease is operational. NO Included in ITGS (transaction from A to B) Included in ITSS Operational leasing services YES Aircraft registration YES Establishment of an institutional unit required (resident according to NA principle)? YES Included in ITGS  NO Included in ITGS  NO No ITGS/ITSS (no transaction) AND Financial leasing  
 
 
 
 
 
 
 
 
Specific goods or movements  4 

4.3.2  Transactions and variables to be recorded 
559. International trade in goods statistics shall cover only the following transactions: 

  Arrivals:  the  transfer  of  economic  ownership  of  a  vessel/aircraft  from  a  taxable  person 
established  in  another  Member  State  to  a  taxable  person  established  in  the  reporting  Member 
State. 

  Dispatches:  the  transfer  of  economic  ownership  of  a  vessel/aircraft  from  a  taxable  person 
established  in  the  reporting  Member  State  to  a  taxable  person  established  in  another  Member 
State. 

  Imports: the transfer of economic ownership of a vessel/aircraft from a natural or legal person 
established  in  a  non-member  country  to  a  natural  or  legal  person  established  in  the  importing 
Member State. 

  Exports: the transfer of economic ownership of a vessel/aircraft from a natural or legal person 
established  in  the  exporting  Member  State  to  a  natural  or  legal  person  established  in  a  non-
member country.  

  The  arrivals/imports  and  dispatches/exports  of  vessels/aircraft  before  or  following  processing 

under contract.  

560. If  the vessel/aircraft  is new, a  transaction between  the  manufacturer and the  first  economic  owner 
shall  be  reported.  The  dispatch/export  is  recorded  in  the  Member  State  of  construction  and  the 
arrival/import in the Member State where the economic owner is established. 
561. In  case  of  a  new  vessel/aircraft,  the  processing  activities  linked  with  its  construction  including 
movements of incomplete or unfinished vessels /aircraft (e.g. Airbus) shall be reported according to the 
standard  ITGS  rules  including  distinction  between  processing  under  contract  and  processing  on 
processor's own account (see sub-chapter Processing trade). 
562. If  the  processing  operation  has  significantly  improved/changed  the  vessel/aircraft,  the  transaction 
between  the  processor  and  the  economic  owner  shall  be  reported.  In  order  to  distinguish  between 
processing  and  maintenance  activities  the  accounting  rules  for  gross  fixed  capital  formation  should  be 
applied.  If  a  rise  in  value  of  the  vessel/aircraft  is  capitalised  in  the  business  accounts  of  the  economic 
owner,  i.e.  recorded  as  an  increase  in  the  assets  then  the  operation  shall  be  reported  in  ITGS  as 
processing. 
563. Each  vessel  has  to  sail  under  the  flag  of  a  country.  The  countries  are  entitled  to  define  their  own 
conditions for the registration of vessels in their territory and for the right to fly their flag. Some countries 
may  require  that  the  legal  owner  and/or  operator  are  national  ‘companies’.  However,  if  there  is  no 
economic substance connected with the registration of a vessel according to the economic owner criteria 
set out, no transactions shall be recorded and vice versa. Flagging out/in of a vessel can be a trigger for 
further investigation but it is not an indicator of change of economic ownership. 
564. The  list  of  exclusions,  in  particular  the  definition  of  temporary  movements(1),  does  not  apply  to 
vessels  and  aircraft.  Therefore  the  duration  of  the  temporary  use  (under  or  over  24  months)  is  not  a 
determining indicator to record the transaction in ITGS. 
565. As a vessel/aircraft is considered as an asset, then the majority stakeholder is deemed to make the 
decision  as  to  who  operates  the  vessel/aircraft.  If  the  legal  owner/share  holder  relinquishes  (sells)  only 
part of the ownership, the economic owner remains with the operator who the stakeholder choses to use 
which may be the same one. Therefore where only a part of the vessel/aircraft is sold or bought, further 
assessment is required to decide whether the change of economic ownership occurred.  
566. A company may enter into a series of structured transactions (arrangements) with a party or several 
parties  (related  or  unrelated)  that  may  also  involve  the  legal  form  of  a  lease.  The  form  of  each 
arrangement  and  its  terms  and  conditions  can  vary significantly.  For  recording  the  series  of  interlinked 

(1)  Commission Regulation (EC) No 1982/2004, Annex I, point (c);  
Commission Regulation (EU) No 113/2010, Annex I, point (c).  

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Specific goods or movements  4 

transactions (e.g. sale and lease-back), the overall economic effect should be considered. Only the transfer 
of economic ownership between the initial and final economic owner shall be reported in ITGS. 
567. A sale and lease-back transaction involves the sale of a vessel/aircraft and the leasing back of the 
same vessel/aircraft. If the lease-back results in financial leasing in the sense of NA, no transaction will 
be recorded in ITGS and ITSS. However a lease-back resulting in operational leasing as defined by NA 
will  be  recorded  in  ITGS  (after  the  examination  of  the  substance  of  the  transaction)  as  a  sale  of 
vessel/aircraft and in ITSS as operational leasing services. 

Example 64  
A) A Danish aircraft leasing company has purchased five aircraft from the manufacturer and leased them to an operator 
in Latvia. Let's assume that the aircraft were directly purchased from the manufacturer as new aircraft; they have not 
been operated yet. The subsequent leasing arrangement was negotiated separately.  
Then  the  Danish  company  is  the  first  economic  owner  of  the  aircraft  and  arrival  in  Denmark  shall  be  reported.  If  the 
leasing  arrangement  between  the  Danish  lessor  and  the  Latvian  operator  results  in  a  financial  leasing  as  defined  by 
ESA2010  and  thus  in  a  transfer  of  the  economic  ownership  from  the  lessor  to  the  lessee,  dispatch  from  Denmark  to 
Latvia/arrival  in  Latvia  from  Denmark  shall  be  recorded.  Otherwise  no  transaction  between  Denmark  and  Latvia  is 
recorded. 
B) A Danish aircraft leasing company has purchased three aircraft from an operator in Latvia and leased them back to 
that operator in Latvia. The sales of three aircraft by the operator himself from Latvia to Denmark and the subsequent 
leasing from Denmark to Latvia shall be considered as a series of transactions. Let's assume that the operator was the 
economic owner of the aircraft at the time of their sale.  
If  the  leasing  arrangement  results  in  an  operational  leasing  as  defined  by  ESA2010  then  the  lessor  will  become  the 
economic owner of the aircraft and arrival in Denmark from Latvia/dispatch from Latvia to Denmark shall be recorded. 
Otherwise  no  transaction  between  Denmark  and  Latvia  is  recorded  (neither  dispatch  from  Latvia  to  Denmark  nor 
subsequent  dispatch  from  Denmark  to  Latvia)  as  the  overall  result  of  the  transaction  is  that  the  operator  remains  the 
economic owner of the aircraft due to financial leasing as defined by ESA2010. 
C) A Finnish company orders a ship from a Chinese shipbuilder. The Chinese company prefers to do financial business 
with  Luxembourg-based  customers,  therefore  the  Finnish  company  sets  up  a  daughter  company  in  Luxembourg.  The 
only  function  of  the  daughter  company  in  Luxembourg  is  to  manage  the  financing  of  the  ship.    The  Finnish  company 
sells the ship just bought from China to its daughter company in Luxembourg. This subsidiary pays for the ship when the 
ship  is  delivered  from  China.  The  Luxembourg  subsidiary  leases the  ship  back  to  the  Finnish  mother  company  under 
bareboat charter. The ship arrives in Finland, is registered in the Finnish national ship register and starts operating. 
The transactions shall be considered as interlinked (jointly  negotiated, related parties involved). If, after examining the 
substance of the transaction, the provisions of the bareboat charter enable the leasing arrangement to be classified as 
financial leasing then the import in Finland from China shall be recorded. Otherwise the transaction shall be recorded in 
Luxembourg, as the operational leasing arrangement does not transfer the economic ownership from the Luxembourg 
subsidiary to the Finnish mother company. 

Figure 30: Trade in vessels/aircraft — interlinked transaction 

568. Partner country. The partner country shall be the Member State or non-member country where the 
economic  owner  of  the  vessel/aircraft  who  is  transferring  the  ownership/to  whom  the  ownership  is 
transferred, is established.  

Example 65  
A) A ship building company X — resident in Member State A is selling a luxury cruise ship to a company Y resident in 
country  B.  However,  company  Z  established  in  Member  State  A  becomes  the  economic  owner  of  the  ship.  The 
company Y is a subsidiary of company Z (or vice versa).  
Let's assume that the transactions are interlinked. Then no transaction is reported in ITGS as the operation is resulting 
in  the  transfer  of  economic  ownership  between  residents  established  in  the  same  Member  State.  Member  State  B 
acquires only the legal property of the asset. 

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119 

 China Shipbuilder is legal and economic owner.  Luxembourg  Subsidiary of Finish company is financing the purchase. Cash flow Transfer of legal ownership  Finland Company will become economic owner. Transfer of economic ownership   
 
 
 
 
 
 
Figure 31: Trade in vessels/aircraft — economic ownership transferred within the MS 

Specific goods or movements  4 

B) A ship building company X — resident in MS A is selling a contract for building a new ship/aircraft to an EU based 
company Y — resident in Member State B. When the ship/aircraft is delivered, it is purchased by EU based company Z 
established in another Member State C. Company Z had acquired the contract of building from Y before the ship/aircraft 
delivery; Company Z will use the asset to run an economic activity.  
Dispatch in MS A to MS C/arrival in MS C from MS A is recorded as the economic ownership is transferred. MS B will 
not report any transaction in ITGS as it is only a financial transaction. 

Figure 32: Trade in vessels/aircraft — economic ownership transferred to another MS 

569. The establishment of the economic owner should be in line with the principles applied in National 
Accounts  for  ‘residence  of  institutional  units’.  According  to  this  concept,  a  unit  is  resident  and  thus  is 
established  in  a  country  when  it  has  a  centre  of  economic  interest  on  the  economic  territory  of  that 
country — that is, when it engages for an extended period (one year or more) in economic activities on 
this territory (ESA 2010, par. 1.61)(1). 

Example 66  
A number of fishing vessels are registered (UK flag/fishing licence) in the UK where they are also registered as Limited 
Companies. These companies are also registered for UK VAT and corporation tax purposes. However the companies 
are Spanish owned and all the directors are Spanish residents; the shareholders are either Spanish resident companies 
or Spanish resident individuals. A UK management company renders the managerial/administrative services including 
submission of Intrastat declarations on behalf of UK companies for a fee.  
The Spanish shareholders only receive dividends paid by the UK companies. The UK companies use the fishing vessels 
in their economic activity to generate the profit from which the dividends are paid. Thus Spanish individuals/businesses 
claim the benefits associated with the holding of the shares, not with the use of the vessel. Therefore the UK companies 
which own and also operate the fishing vessels under UK fishing licence are the economic owners of the vessels. 

570. The  partner  country  in  the  case  of  arrival/import  of  a  new  vessel/aircraft  shall  be  the  Member 
State/non-member country of construction. If the different stages of the construction take place in several 
Member States (e.g. Airbus), the partner country shall be reported according to the standard ITGS rules 
following the movements of goods. 
571. The definition of partner country for the processing activities enhancing the vessel/aircraft follows 
the  principle  of  economic  ownership  which  determines  when  the  transaction  between  processor  and 
economic owner shall be reported. Therefore the partner country for vessels/aircraft sent for processing 
shall  be  the  Member  State/non-member  country  where  the  processor  is  established.  Member  States 
undertaking  the  processing  shall  record  the  Member  State/non-member  country  where  the  economic 
owner of the vessel/aircraft undergoing processing is established. 

(1)  Regulation (EU) No 549/2013 of the European Parliament and of the Council of 21 May 2013 on the European system of national and regional 

accounts in the European Union. 

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120 

 MS A Company X (seller) is legal and economic owner.  MS B Company Y (purchaser- contractual party) will become legal owner. Cash flow Transfer of legal ownership  MS A Company Z will become economic owner. Transfer of economic ownership  MS A Company X (seller) is legal and economic owner.  MS B Company Y is initial purchaser. Cash flow Transfer of legal ownership  MS C Company Z will become economic owner. Transfer of economic ownership  
 
 
 
 
 
 
                                                           
Specific goods or movements  4 

Example 67  
An unfinished ship is brought to Norway for inward processing. The Norwegian processor subcontracts some operations 
to a Swedish shipyard. The ship leaves Norway under customs procedure outward processing. When the subcontracted 
operations are done, the ship returns to Norway for further inward processing.   
The movements of goods shall be reported, i.e. exports from Norway to Sweden/imports in Sweden from Norway. When 
the  processing  in  Sweden  is  finished,  the  exports  from  Sweden  to  Norway/imports  in  Norway  from  Sweden  shall  be 
recorded. 

572. Quantity. Quantity for vessels shall be expressed only in supplementary units — number of items. 
The quantity for aircraft shall be expressed in net mass and supplementary units. 
573. Value.  The  statistical  value  of  the  vessel/aircraft  is  the  total  value  that  would  be  invoiced  if  the 
whole vessel/aircraft was sold or purchased excluding the transport and insurance costs. In case of partial 
sales  of  the  vessel/aircraft  which  result  in  the  transfer  of  economic  ownership,  the  full  value  shall  be 
reported.  
574. Processing  operations  of  goods  whose  classification  under  CN  subheadings  qualifies  for  the 
provisions  on  the  specific  goods  or  movements,  both  the  value  of  the  unprocessed  and  the  processed 
goods, i.e. the initial value of unprocessed goods and the total value after the processing shall be reported. 
When a new vessel/aircraft is constructed, the value of the unfinished vessel/aircraft is recorded before 
the processing and its increased value after the processing. 

Example 68  
A) Company X from Denmark — economic owner of a ship of value EUR 40 million sends it to shipyard Y in Poland in 
order to extend its capacity. This operation considered processing under contract will increase the value of the ship by 
EUR 15 million.  
The  dispatch  from  Denmark  to  Poland/arrival  in  Poland  from  Denmark  of  the  ship  of  value  EUR  40  million  shall  be 
recorded  in  ITGS.  After  the  processing,  the  dispatch  from  Poland  to  Denmark  /arrival  in  Denmark  from  Poland  of  the 
ship of value EUR 55 million shall be recorded. 
B)  A  factory  in  Hamburg  supplies  the  fuselage  sections  and  wings  for  the  assembly  of  an  aircraft  to  the  factory  in 
Toulouse.  As  these  unassembled  parts  have  the  essential  character  of  the  finished  aircraft,  the  whole  delivery 
(qualifying  also  as  a  staggered  consignment)  is  classified  under  CN  8802 30 00.  The  value  of  the  consignment  is 
EUR 20  million.  After  the  assembly  (including  mounting  of  engines  and  landing  gear,  installation  of  electronic 
appliances) the aircraft returns to Hamburg to be furnished with seats and other board equipment. The assembly adds 
the value of EUR 30 million.  
If the assembly in France is declared as processing under contract then French arrival from Germany/German dispatch 
to France of value EUR 20 million and French dispatch to Germany/German arrival from France of value EUR 50 million 
(20 + 30 million) shall be reported in ITGS. 

575. If  the  statistical  value  is  not  available,  NSAs  can  obtain  the  information  in  different  ways,  for 
example by: 

  asking directly the owner of the vessel/aircraft; 
  using the published quotations for certain brands/kinds of aeroplanes/ships; 
  using available records similar to CN8/net mass/supplementary units as estimates. 

576. Reference  period.  The  reference  period  shall  be  the  month  when  the  transfer  of  economic 
ownership  occurs  for  arrivals/imports  and  dispatches/exports.  In  the  case  of  processing,  the  transaction 
shall be reported according to the standard rules. 

4.3.3  Data sources 
577. Customs,  fiscal  and  Intrastat  data  cannot  assure  the  total  coverage  of  trade  in  vessels  and  aircraft 
according  to  the  concept  of  economic  ownership.  Member  States  may  use  all  available  data  sources 
(including  national  and  international  registers)  in  order  to  identify  the  target  population,  to  ensure 
exhaustiveness of the statistical results and to collect/compile ITGS. 
578. A vessel/aircraft may be declared on the customs declaration in case of an acquisition/sale where the 
legal owner coincides with the economic one. In that case the customs declaration can be required as a 
document necessary for the registration in the national ship/aircraft register.  
579. Moreover  the  vessel/aircraft  undergoing  processing  should  be  reported  through  the  standard  data 
sources: customs and Intrastat declarations. NSAs are encouraged to establish a specific procedure for 
the  CN  codes  falling  under  the  specific  goods  or  movements  provisions  in  order  to  examine  the 
transactions and to verify their correct treatment in ITGS. 

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580. The  VAT  provisions  on  intra-EU  acquisitions  of  new  means  of  transport  extend  the  obligation  to 
submit a VAT return to all acquirers of these goods including the natural persons. Member States  may 
adopt different rules for the submission of VAT returns in this respect. In the case of vessels and aircraft, 
all new seagoing vessels for business use and new aircraft used by airlines operating for reward chiefly 
international  routes  are  excluded  from  the  VAT  reporting,  so  transactions  carried  out  by  airlines  or 
shipping companies are not covered. Even though VAT provisions concern only a very limited part of the 
transactions with vessels and aircraft (e.g. the purchase of a yacht or a private plane by a private person) 
NSAs are encouraged to examine the possibility to use VAT data about intra-EU acquisitions of new(1) 
vessels(2) and aircraft(3) in order to identify statistically relevant transactions.  
581. Where  possible,  it  is  recommended  that  NSAs  introduce,  at  national  level,  the  obligation  to 
complete  an  Intrastat  declaration  for  trade  transactions  involving  changes  of  economic  ownership, 
whatever the contractual arrangements (i.e. sale or leasing). 
582. Ships and aircraft registers. NSAs could use, if available, information on the economic ownership 
provided  by  the  national  authorities  responsible  for  managing  the  ships  and  aircraft  registers.  It  is 
recommended  that  NSAs  agree  with  these  competent  national  authorities  on  a  regular  information 
exchange on entries into and removals from the registers. 
583. Ships register.  The registration of ships is not regulated and harmonised at EU level and is based 
on the national legislation. The organisation of the vessels registers varies widely: some Member States 
have one single main register, others have several parallel registers. Nevertheless, in all Member States 
the national ships registers are managed by governmental institutions. Most national ships registers that 
are not centralised are regularly consolidated at central level. 
584. All  Member  States  should  be  able  to  access  their  national  ships  registers  without  administrative 
problems.  The  European  legislation  on  International  Trade  in  Goods  Statistics  is generally sufficient  to 
guarantee NSAs’ access to the registers. 
585. The  conditions  for  the  registration  of  vessels  in  the  national  registers  differ  considerably  among 
Member States. The establishment of the legal owner is the major requirement for registration; however 
other conditions may be applicable. In many Member States the information on statistically relevant data 
elements such as value, legal owner, economic owner or change of economic ownership is not present 
in  the  register.  The  information  available  in  the  register  should  be  a  basis  for  defining  the  target 
population to be contacted for statistical reporting.  
586. According 
to  Commission  Regulation  (EC)  No  26/2004  and  Council  Regulation  (EC) 
No 2371/2002, a fishing vessels register shall be managed by Member States. Fishing vessels register and 
general  vessels  register  could  overlap  at  national  level.  In  some  Member  States,  the  different  vessel 
registers  are  not  managed  by  the  same  public  institutions.  NSAs  should  investigate  if  information 
collected in the national fishing vessels register is relevant for statistical purposes.  
587. Aircraft register. The situation for aircraft registers is more homogenous. National aircraft registers 
are centralised and managed by governmental institutions in all Member States. European regulations are 
sufficient to guarantee access to the register by the NSAs. The conditions for registration of an aircraft in 
the national register differ among Member States. However there is a clear link between the registration 
in a register and the establishment of the legal owner or operator(4) in a Member State. In some cases the 
establishment of a legal or commercial representative in the Member State also enables a registration in 
the national aircraft register. In most cases information on the legal owner and/or the operator is available 
in the register. 
588. Other  data  sources.  In  addition  to  the  registers,  publicly  available  information  (e.g.  Internet, 
newspapers) might be used to identify transactions with a possible statistical relevance. Moreover NSAs 

(1)  Council Directive 2006/112/EC, Articles 2(2)(b)(ii) and (iii). 
(2)  Council Directive 2006/112/EC, Article 2(2)(a)(ii). 
(3)  Council Directive 2006/112/EC, Article 2(2)(a)(iii). 
(4)  Air operator means a natural person residing in a Member State or a legal person established in a Member State using one or more aircraft  in 
accordance with the regulations applicable in that Member State, or an EU air carrier as defined in the EU legislation (Council Regulation (EEC) 
No 3922/91). 

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may  utilise  registers  of  classification  companies,  information  provided/published  by  shipowners’ 
associations or other national and international databases. This information could be a trigger for further 
investigation. 
589. To integrate possible missing data, NSAs are encouraged to implement at least ad hoc surveys, for 
example on the occasion of the final data revision, to collect data directly from entities involved in the 
contractual arrangements which may lead to change of economic ownership.  
590. The criterion for recording the transfer of goods from one unit to another in NA and BoP is that the 
economic ownership passes from one to the other. In the case of trade in vessels and aircraft, the ITGS 
criteria  for  inclusion/exclusion  are  the  same  as  those  used  in  NA  and  BoP.  The  transactions  in 
vessels/aircraft that will be excluded from ITGS, will still trigger the registration of a financial transaction 
or  a  transaction  in  services  in  BoP,  MSs  are  encouraged  to  enhance  cooperation  of  all  compilers 
involved (ITGS, ITSS, BoP and NA). 
591. Furthermore MSs are encouraged to strengthen multilateral cooperation including exchange of any 
kind of information, even at transaction level, among them whenever possible. Where national conditions 
allow this, the provisions of the BoP regulation(1) enabling Member States to exchange micro-data for the 
sake  of  safeguarding  the  quality  of  BoP  figures  should  be  applicable,  as  ITGS  are  a  fundamental 
component  of  BoP.  Exchange  of  micro-data,  also  supported  by  the  European  statistics  law(2),  could be 
very  useful  to  capture  data  on  vessels  and  aircraft  trade,  to  improve  data  quality  and  to  reduce 
asymmetries,  particularly  in  intra-EU  trade.  Specifically,  if  an  economic  owner  established  in  one 
Member  State  takes  over  the  economic  ownership  of  a  vessel  registered  in  another  Member  State,  the 
reporting country might miss this transaction, unless the partner Member State alerts it. 

4.3.4  Leasing arrangements 
592. As many different kinds of leasing arrangements/contracts exist for vessels and aircraft, a distinction 
between  financial  and  operational  leasing  based  on  the  label/title  of  the  contract  is  not  sufficient  for  a 
correct  allocation  of  transactions  in  ITGS.  Besides,  as  the  duration  of  the  leasing  contract  cannot  be 
applied as the only criterion, so the substance of the contracts shall be investigated in order to identify the 
economic owner of the vessel or aircraft. 
593. NA  and  BoP  provide  definitions  of  operational  and  financial  leasing  that  look  at  the  economic 
substance  of  the  transaction.  In  the  case  of  operational  leasing,  according  to  ESA  2010,  the  service 
provided  by  the  lessor  goes  beyond  the  mere  provision  of  the  asset  and  may  include  responsibility  for 
providing  repair,  maintenance  or  replacement  at  short  notice  (ESA2010  paras. 15.09  and  15.11). 
Operational  leasing  in  line  with  ESA  definitions  shall  be  excluded  from  general  merchandise  and  thus 
also from ITGS since it is considered as a service. In the case of financial leasing the lessor remains the 
legal owner (providing a loan to the lessee), and the lessee becomes the economic owner. ESA 2010, par. 
15.19  also  specifies  that  ‘any  corporation  that  specialises  in  financial  leasing,  even  if  called  a  property 
company or aircraft leasing company, shall be classified as a financial intermediary offering loans to the 
unit  leasing  assets  from  them’.  Financial  leasing  contracts  in  line  with  ESA 2010  definitions  should  be 
considered within the scope of ITGS.  

Example 69  
A)  A  Slovak  construction  company  leases  an  aircraft  (CN  8802  30  00)  to  transport  its  employees.  The  company 
operates the aircraft itself. Even though the company makes no profit from the operation of the aircraft, it accepts the 
associated  risk  (e.g.  the  company  pays  for  repair,  in  case  of  a  breakdown  the  company  will  rent  another  aircraft  to 
replace the broken down aircraft etc.). If, after the substance of the transaction and its compliance with the definition of 
financial  leasing  according  to  ESA2010  has  been  examined,  the  leasing  is  classified  as  financial  and  if  the  lessor  is 
established in another Member State/country, then the transaction shall be treated as an arrival/import in Slovakia. 
B) A private person buying a yacht concludes a leasing contract with a financier who closely cooperates with the seller 
of the vessel. The buyer takes possession of the yacht immediately, though legally it remains the property of the lessor 
(financier) as a guarantee until all agreed payments have been made by the lessee. Even though the buyer, as a private 
person,  does  not  run  any  economic  activity  on  the  vessel,  the  transaction  should  be  considered  as  hire  purchase  —

(1)   Regulation (EC) No 184/2005 of the European Parliament and of the Council, Article 8(3). 
(2)  Regulation (EC) No 223/2009 of the European Parliament and of the Council, Article 21(1). 

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special  form  of  financial  leasing.  If  the  private  person  resides  in  a  Member  State/country  other  than  that  where  the 
financier is established the transaction shall be included in ITGS. 

594. The leasing arrangements concluded within the shipping and aircraft industries are standardised; a 
specific  terminology  is  used.  Although  the  type  of  contract  may  give  a  clue  as  to  how  the  transactions 
should  be  treated,  it  shall  be  verified  whether  the  contract  reflects  standardised  provisions  and  thus 
whether the transfer of economic ownership occurs or not. 
595. Chartering is an activity within the shipping industry. In some cases, a charterer may own a cargo 
and  employ  a  shipbroker  to  find  a  ship  to  deliver  the  cargo  for  a  certain  price,  called  the  freight  rate. 
Freight rates may be calculated on a per-ton basis over a certain route or alternatively may be expressed 
in  terms  of  a  total  sum  per  day  for  the  agreed  duration  of  the  charter.  A  charterer  may  also  be  a  party 
without a cargo who takes a vessel on charter for a specified period from the owner and then trades the 
ship to carry cargoes at a profit above the hire rate, or even makes a profit in a rising market by re-letting 
the ship out to other charterers. There are mainly three types of chartering: 

  A  Voyage  charter  is  the  hiring  of  a  vessel  and  crew  for  a  voyage  between  a  loading  and  a 
discharging port. The charterer pays the vessel owner on a per-ton or lump-sum basis. The owner 
pays the port costs (excluding stevedoring), fuel costs and crew costs. Given that the substance 
of the contract has been verified, this arrangement usually does not indicate change of economic 
ownership and shall not therefore be included in ITGS, but it is included in ITSS. 

  A Time charter is the hiring of a vessel for a specific period of time; the owner still manages the 
vessel but the charterer selects the ports and directs the vessel where to go. The charterer pays 
for all the fuel the vessel consumes, port charges, and a daily 'hire' to the owner of the vessel. 
Given  that  the  substance  of  the  contract  has  been  verified,  this  arrangement  usually  does  not 
indicate  change  of  economic  ownership  and  shall  not  therefore  be  included  in  ITGS,  but  it  is 
included in ITSS. 

  Demise or Bareboat charters. This arrangement is completely different from the previous two. 
The charterer takes full control of the vessel along with the legal and financial responsibility for 
it.  The  charterer  pays  for  all  operating  expenses,  including  fuel,  crew,  port  expenses  and  hull 
insurance. The demise shifts the control and possession of the vessel. These arrangements can be 
difficult to determine whether there is a change in economic ownership or not. 

596. The  vessel  operator  is  the  natural  person  or  the  legal  person  responsible  for  the  commercial 
decisions  concerning  the  use  of  a  ship  and  therefore  the  one  who  decides  how  and  where  that  asset  is 
used. This company may also be responsible for purchasing decisions on bunkers and port services. For 
example,  a  medium  to  long-term  or  bareboat  charterer  is  considered  to  be  the  operator  of  the  ship. 
Companies heading operator pools (e.g. Cool Carriers or Gear bulk) are operators of the ships in the pool. 
On the other hand voyage or time charterers are normally not responsible for the commercial decisions 
concerning the use of the ship, so they cannot be considered as an operator. 
597. For  aeroplanes,  there  are  two  main  kinds  of  leasing  contracts  that  can  be  defined,  in  a  simplified 
way, as follows: 

  Wet Lease is a leasing arrangement whereby one airline (lessor) provides an aircraft, complete 
crew, maintenance, and insurance, to another airline (lessee), who pays by operated hours. The 
lessee provides fuel, covers airport fees, and any other duties, taxes, etc. The flight uses the flight 
number of the lessee. Given that the substance of the contract has been verified, this arrangement 
usually does not indicate change of economic ownership and shall not therefore be included in 
ITGS, but it is included in ITSS. 

  Dry  lease  is  the  lease  of  the  basic  aircraft  without  crew,  and  usually  without  insurances, 
maintenance  etc.  Usually  in  dry  lease  the  lessor  is  a  leasing  company  or  a  bank.  A  dry  lease 
requires the lessee to put the aircraft on his own Air Operator's Certificate and to provide aircraft 
registration. A typical dry lease starts from two years onwards and bears certain conditions as far 
as depreciation, maintenance, insurances. There are generally two types of dry lease:  financial 
lease and operational lease. Given that the substance of the contract has been verified, financial 
lease  does  usually  indicate  change  of  economic  ownership  and  shall  therefore  be  included  in 
ITGS. However, operational lease does normally not indicate change of economic ownership and 
shall not therefore be included in ITGS, but it is included in ITSS. 

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598. A Member State operator is able to dry-lease aeroplanes only from EU Member States (Regulation 
(EC)  No 1008/2008  of  the  European  Parliament  and  of  the  Council);  a  dry  lease  with  non-member 
countries requires a specific political and economic agreement between the Member State and the non-
member countries. The National Aviation Authority should have information on the starting and finishing 
of  new  dry-lease  contracts  and  on  the  country  of  the  previous  economic  owner  (most  likely  a  leasing 
company).  

4.4  Motor vehicle and aircraft parts 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Commission Regulation (EC) No 1982/2004, Article 18 

599. The  declaration  of  motor  vehicle  and  aircraft  parts  and  accessories  generally  necessitates  the 
classification  of  a  wide  variety  of  goods  in  different  sub-headings  of  the  Combined  Nomenclature.  To 
relieve  the  reporting  burden  on  the  automobile  and  aircraft  industry,  a  simplified  declaration  of  motor 
vehicle and aircraft parts was requested by a few Member States in the framework of the Intrastat system. 
600. NSAs are encouraged to apply the simplified reporting on motor vehicle and aircraft parts only in a 
conservative  way.  However,  if  they  do  introduce  particular  provisions  they  should  apply  the  following 
conditions: 

  Each concession should be monitored by the national statistical authority; 
  The CN codes 9990 87 zz (cars); 9990 88 zz (aircraft) should be used (zz according to national 

purposes). 

4.5  Goods delivered to vessels and aircraft 
Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 
Commission Regulation (EC) No 1982/2004, Article 19 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 
Commission Regulation (EU) No 113/2010, Article 20 

601. Definition. ‘Delivery of goods to vessels and aircraft’ means delivery of products for the crew and 
passengers as well as for the operation of engines, machines and other equipment of vessels or aircraft. 
602. ITGS covers only dispatches and exports of those goods which are delivered on the territory of the 
reporting  Member  State  to foreign  vessels or  aircraft.  Foreign vessel  or  aircraft  is the vessel or  aircraft 
whose economic owner is established in another Member State or non-EU country. So the deliveries of 
goods to national vessels or aircraft i.e. to vessels or aircraft whose economic owner is established in the 
reporting Member State are considered domestic transactions and consequently they are not recorded in 
ITGS. 
603. Identification of economic owner of a vessel and aircraft and consequently to make the distinction 
between domestic and international trade-in-goods transactions may be difficult within monthly routine. 
So Member States or non-member country where the purchaser of the goods (the supplier’s contractor) 
resides  could  be  a  pointer  to  residency  of  economic  owner.  However  NSAs  should  make  all  effort  to 
differentiate the deliveries to domestic and foreign vessels or aircraft following the economic ownership 
at the latest when finalising the data.  
604. For  the  purpose  of  statistical  reporting  of  these  goods,  statistical  regulations  provide  with  the 
following simplifications when transmitting data to Eurostat: 

  Simplified  reporting  of  commodity  code.  The  following  simplified  Combined  Nomenclature 
codes shall be used for the goods delivered to vessels and aircraft of other Member States or may 
be  used  for  the  goods  delivered  to  vessels  and  aircraft  of  non-member  countries  at  national 
harbours or airports:  
○  9930 24 00: goods from CN chapters 1 to 24; 
○  9930 27 00: goods from CN chapter 27; 
○  9930 99 00: goods classified elsewhere. 

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  Simplified  reporting  of  partner  country.  According  to  the  legislation,  the  partner  country  is 
the Member State or non-member country where the economic owner of the vessel or aircraft is 
established. A simplified partner code can be used: QR for intra-EU deliveries and QS for extra-
EU deliveries.  

  Simplified reporting of quantity. The transmission of data on the quantity is optional except for 
goods belonging to CN chapter 27 (mineral fuels and mineral oils). For these goods the reporting 
of  net  mass  is  mandatory.  The  Doc MET 400  provides  specific  rules  how  to  provide  quantity 
data to Eurostat. 

605. Scope  of  application.  The  provisions  apply  exclusively  to  goods,  which  are  intended  for 
consumption during the journey and are therefore unlikely to be taken off the vessel or aircraft again. So 
statistical  simplification  options  should  apply  to  the  goods  which  are  supplied  to  vessels  and  aircraft 
operating  on  international  routes  and,  from  the  point  of  view  of  customs  and  tax  administrations,  are 
benefiting from duties and tax exemptions and from simplified reporting.  
606. Delivery of durable goods and equipment, which remain on the vessel or aircraft should be reported 
according to the standard rules. In order to distinguish these goods from deliveries to vessels and aircraft 
NSAs could examine whether the goods are VAT exempted according to Article 148, points (a), (b) and 
(e) of VAT Directive. If not, such goods can be considered durable. This might include, for instance, the 
delivery of bed linen, or of musical instruments for the musicians of the ship, or TV sets for the cabins or 
other durable goods.  
607. Customs and VAT provisions do not provide specific lists of goods which unambiguously fall under 
the scope of supplies to vessels and aircraft. Every Member State can limit the scope at national level. 
Therefore NSAs  are  encouraged  to  analyse  the  national  VAT  legislation  in  order  to clearly  define the 
scope of goods which can benefit from simplifications. 
608. Simplified provisions for the delivery of goods to vessels and aircraft may be fully exploited within 
intra-EU  trade  statistics  only  when  collecting  information  on  the  Intrastat  declaration,  following  the 
national instructions. However, the application of simplification for extra-EU trade statistics depends on 
national customs provisions, which may use it or not. Moreover, the reporting obligation relates only to 
dispatches/exports, i.e. the economic owner of the vessels or aircraft, who is established in the reporting 
Member State and who was supplied with goods for consumption in foreign harbours or airports, needs to 
provide neither statistical arrival nor customs imports declarations. 
609. For  the  purposes  of  national  accounts  and  balance  of  payments  statistics  goods,  such  as  fuels, 
provisions, etc. procured by resident transport operators in foreign ports from non-resident providers have 
to  be  included  in  imports  of  goods.  Although  this  information  may  be  collected  using  specialised 
statistical  surveys,  in  line  with  current  regulations,  it  must  not  be  included  in  ITGS  transmitted  to 
Eurostat.  Member  State  considering  such  imports  economically  or  environmentally  significant  may 
record them in their national trade in goods statistics.  

Table 11: Scenarios of the reporting deliveries to vessels and aircraft 

Scenario(1) 

Reporting requirements 

Reason 

Deliveries to national vessels or aircraft in a 
reporting Member State.  

Deliveries to national vessels or aircraft in a 
partner Member State or non-EU country 
(foreign harbours or airports).  

Are not recorded in ITGS. 

Domestic transaction. 

Are not recorded in ITGS. 

Exempted by statistical 
regulation indirectly 

Deliveries to foreign vessels or aircraft in a 
reporting Member State. 

Are recorded as exports or 
dispatches, accordingly. 

No exemption in statistical 
regulation, customs 
declaration might be 
required. 

(1) ‘National vessel or aircraft’ is the vessel or aircraft whose economic owner is established in the reporting Member State. 
    ‘Foreign vessel or aircraft’ is the vessel or aircraft whose economic owner is established in another Member State or non-member country. 

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4.5.1  Data sources  
610. Customs declarations. The data about extra-EU supplies to vessels and aircraft, which operate on 
international routes, are collected by the national Customs. These data are provided to the NSA together 
with the regular data sets.  
611. In a majority of Member States data related to intra-EU supplies are also collected by Customs. This 
ensures  a  good  coverage  of  data  and  excludes  problems  related  to  non-response.  Moreover,  the 
completeness  of  the  intra-EU  trade  data  is  improved  because  the  data  are  not  affected  by  Intrastat 
exemption thresholds. The data via Intrastat system must not be collected, hence the trader has to report 
only once and the response burden is minimised.  
612. Customs  declarations  in  combination  with  Intrastat  reporting.  In  part  of  Member  States, 
Customs are not requiring to declare some specific goods (e.g. oil and  oil products) supplied to vessels 
and aircraft on customs declaration. In such cases, Intrastat system according to national instruction could 
be used to complement data, which are not provided by Customs.  
613. Intrastat  declarations.  In  several  Member  States,  intra-EU  supplies  to  vessels  and  aircraft  are 
collected  via  the  Intrastat  system  according  to  national  instructions.  The  regulation  on  intra-EU  trade 
statistics  does  not  prohibit  collecting  information  on  intra-EU  supplies  directly  from  catering  and 
supplying companies according to the national instructions. 
614. In  few  Member  States  special  surveys  or  special  procedures  are  in  place  for  the  collection  of  this 
information.  However,  the  European  ITGS  legislation  does  not  provide  a  legal  basis  for  setting  up 
additional  statistical  surveys.  Therefore,  the  collection  of  data  outside  Intrastat  and  customs  systems 
should be covered by national regulations. It is recommended that NSAs use the Intrastat system for the 
collection of data on intra-EU supplies to vessels and aircraft only in case Customs are not providing the 
necessary data.  
615. Whatever  data  source  model  is  applied  in  a  Member  State,  the  risk  of  double  counting  this 
information  still  exists.  The  catering  and  supply  companies  might  provide  Intrastat  declarations 
voluntarily  without  acknowledging  that  this  information  has  already  been  provided  via  the  customs 
systems.  Therefore  the  NSAs  are  encouraged  to  establish  a  control system  which  would  eliminate  the 
risk of double counting of data from two sources (customs and Intrastat declarations). 
616. Problems  related  to  allocation  of  partner  country.  Statistical  regulations  define  as  the  partner 
country the Member State or non-member country where the economic owner of the vessel or aircraft is 
established.  However  in  customs  legislation,  the  country  of  destination  (i.e.  partner  country)  is  defined 
according  to  the  flag  the  vessel  is flying  or  according  to  the  country  of  airplane registration.  Therefore 
when  the  data  about  supplies  are  provided  by  Customs,  the  concept  of  economic  ownership  is 
implemented  only  to  the  extent  where  country  of  registration  of  economic  owner  coincides  with  the 
country  of  the  flag  of  the  vessel.  However  the  impact  of  misallocation  of  the  partner  country  is  less 
significant  due  to  the  use  of  simplified  country  codes,  which  allow  to  separate  between  intra-EU  and 
extra-EU deliveries. 
617. The correct allocation of the partner country according to the economic ownership concept remains 
the  same  problematic  when  the  data  are  collected  via  Intrastat  system.  The  company  responsible  for 
providing the information may not always be able to identify the country where the economic owner of 
the vessel or aircraft is established, or even to identify whether the economic owner is established within 
or outside of  the  EU.  Therefore  in  cases where  economic  ownership of the  vessel  or  aircraft  cannot be 
identified, the flag of the vessel or the country of the recipient of the invoice may be considered as proxy 
to  the  economic  ownership  concept  when  compiling  monthly  data.  However  the  real  economic  owner 
should be identify for significant transactions in terms of value(1) when definitive data are compiled.  
618. When the data on intra-EU supplies are recorded by Customs, the NSA should pay attention that the 
value of supplies to the national vessels or aircraft are not included in ITGS under country code QR.  
619. EU customs requirements for the goods delivered to vessels and aircraft. The supplies to vessels 
and  aircraft  is  a  special  type  of  export,  for  which  the  export  procedure,  within  the  meaning  of  Article 

(1)  The significance of transactions could be assessed individually, one by one, or aggregated by operator/vessel/aircraft. 

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161(1)  of  Council  Regulation  (EEC)  No 2913/92,  shall  be  used  where  Community  goods  are  to  be 
brought to a destination outside the customs territory of the Union.  
620. The  Community  Customs  Code  implementing  provisions,  Article  786  as  well  as  Union  Customs 
Code,  Article  269  mention  the  supplies  to  vessels  and  aircraft.  These  provisions  fixe  very  important 
concepts:  

  supplies to vessels and aircraft is a form of export, for which the export customs formalities can 

be used; 

  supplied goods should be VAT and excise duty exempted; and 
  supplies to vessels and aircraft should be treated in this fashion regardless of the destination of 

the vessel or aircraft. 

621. The  export  formalities  are  to  be  used  with  regard  to  supplies  to  vessels  and  aircraft  so  that  the 
companies delivering such supplies can receive a proof of exit. This proof is needed for the purposes of 
VAT exemption. The same rules apply where non-Community goods are to be re-exported under customs 
re-export procedure.  
622. The  customs  legislation  provides  with  various  simplification  options  which  can  be  used  for 
declaring  vessels  and  aircraft  supplies.  However  the  simplifications  might  be  implemented  in  Member 
States  to  different  extents.  Therefore  the  NSAs  are  encouraged  to  analyse  the  recording  practices  in 
Customs of supplies to vessels and aircraft in order to identify whether simplifications applied are not in 
contradiction with statistical requirements.  
623. VAT  requirements.  For  VAT  purposes  the  supply  of  goods  for  the  fuelling  and  provisioning  of 
vessels and aircraft is exempted from VAT. The VAT Directive(1) provides only general conditions for 
the  exemption  from  VAT  of  goods  and  services  supplied  to  vessels  and  aircraft,  whereas  the  Member 
States can delimit the scope of its application.  
624. Supplies to vessels and aircraft are not considered as intra-EU supply and therefore neither the value 
of the supplies is included in the intra-EU related VAT return box nor the VIES declaration is provided. 
625. In  the  majority  of  Member  States,  for  VAT  purposes,  the  supply  of  goods  for  fuelling  and 
provisioning covers goods for use on a voyage or flight with a non-private purpose and with an eventual 
destination outside the Member State. This may include: 

fuel, 

 
  goods for running repairs or maintenance, for example lubricants, spare and replacement parts, 
  goods for general use on board by the crew, 
  goods for sale by retail to passengers carried on the voyage or flight who intend to use the stores 

on board only. 

626. In order to be exempt from VAT, the supplied goods must fulfil many additional conditions. It has 
to  be noted  that  every Member State  can define  the  scope  of goods  and services  which  are  eligible  for 
VAT exemption.  

4.6  Goods delivered to and from offshore installations 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Commission Regulation (EC) No 1982/2004, Article 20 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 

Commission Regulation (EU) No 113/2010, Article 21 

Offshore installations refer to the equipment and devices 

(1)  Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax. 

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627. Offshore installations refer to the equipment and devices installed and stationary in the sea outside 
the  statistical  territory  (which  includes  the  territorial  waters)  of  any  given  country.  This  includes 
equipment and devices for exploitation of mineral resources or for generating power. For the purposes of 
statistical recording the term ‘national offshore installation’ is used to describe an installation which is 
situated  beyond  the  territorial  waters  of  the  reporting  Member  State  (12  NM  from  baseline)  but  still 
within its exclusive economic zone (EEZ) (200 NM from baseline). Offshore installations located in other 
countries' EEZ are called ‘foreign offshore installations’. (For the precise definitions of maritime zones 
please refer to the Glossary). 
628. The deliveries of goods to the equipment and devices installed and stationary in the territorial waters 
of the reporting Member State are not considered as specific goods or movements. All movements to or 
from  such  installations  should  follow  the  standard  recording  practices  like  any  other  goods  moved 
into/from the territory of that Member State.  
629. There  are  three  basic  types  of  business  activities  related  to  offshore  installations:  offshore  oil  and 
gas extraction, deep-sea mining and production of power from offshore wind farms. Oil and gas offshore 
industry is extracting hydrocarbons from the ocean floor. The offshore wind industry covers all activities 
related  to  the  development  and  construction  of  wind  farms  in  marine  waters  and  exploitation  of  wind 
energy for generation of electricity. The deep-sea mining is process of extracting minerals from the ocean 
floor, usually in the high seas, which are outside of countries EEZ and legal continental shelf. 
630. For  the  purpose  of  statistical  recording  of  goods  delivered  to  and  from  offshore  installations  the 
statistical territory of the Member State is de facto extended beyond its territorial waters and comprises its 
exclusive  economic  zone.  In  all  other  cases  of  statistical  recording  of  goods  the  statistical  territory  is 
equal to customs territory, which comprises only the territorial waters of that Member State.  
631. In practice it means that, offshore installations for statistical purposes are considered to belong to the 
Member State or non-member country which has exclusive rights to exploit the seabed or subsoil where 
they are located. This ownership determines the partner country to be recorded in the trade statistics. 
632. Current  legislation  does  not  cover  the  cases  when  an  offshore  installation  is  installed  beyond  of 
exclusive economic zone, on the continental shelf or even outside the shelf, on  the high seas. Since the 
coastal states have the right to authorize and regulate drilling on the  their continental shelf where these 
rights  are  allocated  to  a  Member  State,  for  statistical  recording  the  statistical  territory  of  that  Member 
State should be extended to the continental shelf.  

4.6.1  Recording difficulties and data sources 
633. In  most  of  the  cases  the  standard  data  sources  (customs  and  Intrastat  declarations)  are  in  use  for 
collecting of information on goods moving to and from offshore installations. However NSAs should pay 
attention to the fact that not all goods movements related to offshore installations, which are recorded by 
Customs have to be included in statistics.  Moreover, the additional data sources should be used for the 
collection of information, which is not available at Customs.  
634. The  difficulties  are  stemming  from  the  differences  in  the  definitions  of  customs  and  statistical 
territories, which for the purpose of recording of goods moving to and from offshore installations are not 
anymore the same. Customs records all goods crossing customs territory, i.e. the goods which are moved 
beyond  Member  States’  territorial  waters.  However  this  movement  of  goods  should  not  be  counted  in 
statistics, if these goods are destined to the national offshore installation. This movement of goods should 
be considered as internal movement of goods within the territory of the Member State. An vice versa, the 
goods  moving  directly  to  (or  from)  national  offshore  installation  from  (or  to)  non-member  country  or 
from  foreign  offshore  installation,  should  be  recorded  in  statistics.  For  this  purpose  additional  data 
sources should be defined.  
635. Customs declarations. The customs declarations cannot ensure completeness of all data needed for 
statistics. Moreover, various customs procedures applied for the recording of goods moving to and from 
offshore installations make difficulties to reuse this information for statistical purposes.  
636.  When the goods are imported from non-member countries in a view to move them to the national 
offshore  installation,  various  customs  procedures  can  be  used:  imports,  customs  warehousing,  direct 
transit,  temporary  imports.  The  problems  may  arise  to  correctly  record  imports,  especially  when  the 
customs  warehousing  or  transit  procedures  are  in  use.  These  two  procedures  are  not  in  the  scope  of 
special trade system, therefore additional efforts may be needed to find out and to include this information 

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in ITGS. Therefore the NSAs are encouraged to analyse the recording practices in Customs of the goods 
moving  to  and  from  offshore  installations  in  order  to  ensure  complete  coverage  and  to  avoid  double 
counting.  
637. Next to the customs and Intrastat declarations, various other data sources are used by NSAs for the 
monitoring  of  goods  movements  to  and  from  offshore  installations.  Some  Member  States  use  relevant 
administrative data from the ministries or agencies responsible for the supervision of offshore installation 
businesses. The data may be collected directly from companies operating offshore installation. In many 
Member  States  the  registers of offshore  installations  are  available  which  information  could  be used for 
monitoring of completeness of statistical data.  
638. The use of VAT data. The VAT data cannot be considered as an additional data source for intra-EU 
offshore transactions. There are no common rules established how to treat the goods moving to and from 
of  EEZ  for  VAT  purposes,  therefore  the  practices  may  differ  from  one  Member  State  to  another.  In 
majority  of  Member  States  the  EEZ  is  considered  as  being  outside  of  VAT  territory,  therefore 
transactions are not considered as intra-EU supplies, the VIES declaration is not provided. Therefore in 
most of the cases the statistically relevant information is not available or is recorded in other boxes than 
intra-EU acquisitions and supplies of VAT return, which do not allow identifying these trade flows.  
639. According to the ITGS legislation, goods moving to and from offshore installations are considered 
as specific goods or movements for which special legal provisions apply. The special provisions apply as 
regards to: 

  simplified reporting of the goods delivered to and from offshore installations,  
 

the definition of the reporting and the partner Member State or non-member country. 

640. There are two distinct types of goods to be included in intra-EU and extra-EU trade statistics: 

 

 

‘goods  delivered  to  offshore  installations’  —  which  refers  to  the  delivery  of  products  for  the 
consumption  of  the  crew  (e.g.  food)  and  for  the  operation  of  engines,  machines  and  other 
equipment of the offshore installation (e.g. fuel, spare parts); 
‘goods  obtained  from  or  produced  by  offshore  installations’  —  which  refers  to  products 
extracted  from  the  seabed  or  subsoil  (e.g.  gas  and  oil)  or  produced  by  the  installation  (e.g. 
electricity produced by wind turbines). 

641. Arrivals/Imports should be recorded:  

  where  goods  are  delivered  from  another  Member  State  or  non-member  country  to  an  offshore 

installation established in an area where the importing Member State has exclusive rights; 

  or  the  goods  are  obtained  from  or  produced  by  an  offshore  installation  established  in  an  area 
where  another  Member  State  or  non-member  country  has  exclusive  rights  and  are  sent  to  the 
importing Member State; 

  or  the  goods  are  obtained  from  or  produced  by  an  offshore  installation  established  in  an  area 
where  another  Member  State  or  non-member  country  has  exclusive  rights  and  are  sent  to  an 
offshore installation in an area where the importing Member State has exclusive rights. 

Figure 33: Recording of arrivals/imports relating to offshore installations 

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                                                             200 NM EEZ 12 NM Territorial waters From the UK point of view as reporting MS  
 
 
 
 
Specific goods or movements  4 

Example 70  
Consumables sent from Germany to a UK offshore installation should be treated in the UK as an arrival from Germany, 
and in Germany as a dispatch to the UK. 
Oil obtained from a Norwegian offshore installation which is piped to the UK for domestic use  should be treated in the 
UK as an import from Norway, and in Norway as an export to the UK 
Spare parts sent from a German offshore installation to an UK  offshore installation should be treated in the UK as an 
arrival from Germany, and in Germany as a dispatch to the UK. 

642. Dispatches/Exports should be recorded  

  where  goods  are  obtained  from  or  produced  by  an  offshore  installation  established  in  an  area 
where  the  exporting  Member  State  has  exclusive  rights  and  are  delivered  to  another  Member 
State or non-member country; 

  or  the  goods  are  delivered  from  the  exporting  Member  State  to  an  offshore  installation 
established in an area where another Member State or non-member country has exclusive rights; 
  or  the  goods  are  obtained  from  or  produced  by  an  offshore  installation  established  in  an  area 
where  the  exporting  Member  State  has  exclusive  rights  and  are  sent  to  an offshore  installation 
established in an area where another Member State or non-member country has exclusive rights. 

Figure 34: Recording of dispatches/exports related to offshore installations 

Example 71  
Electricity produced by a Norwegian offshore installation which is sent directly to the UK would be treated in Norway as 
an export to the UK, and in the UK as an import from Norway. 
Consumables  sent  from  Denmark  to  a  Norwegian  offshore  installation  would  be  treated  in  Denmark  as  an  export  to 
Norway, and in Norway as an import from Denmark 
Food sent from a UK offshore installation to a German offshore installation would be treated in the UK as a dispatch to 
Germany, and in Germany as an arrival from the UK 

643. Businesses established in the reporting Member State who are involved in the movements covered in 
paragraphs 642 and 643 may have the following reporting obligations according to national instructions: 

 

 

if the offshore installation is located within an area where another Member State has exclusive 
rights, to report arrivals and dispatches within the Intrastat system, or 
if the offshore installation is located within an area where a non-member country has exclusive 
rights, to report imports and exports for extra-EU trade statistics. 

644. As  customs  may  require  a  customs  declaration  also  for  goods  moving  between  a  Member  State’s 
mainland and its own offshore installations, to avoid a false report, Member States should remove these 
customs declarations from the compilation of ITGS. 
645. Goods code to be used. The simplified codes are allocated for recording the dispatches/exports and 
arrivals/imports of goods delivered to crew and for the functioning of engines. Although only mandatory 
for  intra-EU  trade  statistics,  they  may  be  used  for  extra-EU  trade,  if  national  Customs  apply  this 
simplification: 

  9931 24 00 for goods from Chapters 1 — 24 of the CN; 
  9931 27 00 for goods from Chapter 27 of the CN; 
  9931 99 00 for goods from any other Chapter of the CN. 

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Specific goods or movements  4 

646. The investment goods for the construction or technical improvement of the offshore installation or 
goods acquired or produced by the offshore installation shall be recorded with appropriate CN codes. The 
reporting  Member  State  and  partner  country  Member  States  should  be  determined  according  to  rules 
valid for goods delivered to offshore installation. 
647. Recording  of  quantity.  With  the  exception  of  goods  classified  within  Chapter  27  of  the  CN, 
quantity information is not required.  
648. In  addition,  simplified  partner  country  codes  are  permitted,  namely  ‘QV’  (for  intra-EU  trade)  and 
‘QW’ (for extra-EU trade). 

4.7  Sea products 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Commission Regulation (EC) No 1982/2004, Article 21 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 

Commission Regulation (EU) No 113/2010, Article 22 

649. Definition. ‘Sea products’ means fishery products, minerals, salvage and other products which have 
not yet been landed by seagoing vessels. Although fishery products make up the most important part of 
the ‘sea products’ category, it is necessary to remember that other products extracted from the sea such as 
minerals, salvage etc. are recorded based on the provisions of this article. 
650. Definition  of  reporting  and  partner  country.  The  sea  products  shall  be  assigned  to  the  non-
member country or to the Member State where the  legal or natural person who exercises the economic 
ownership of the vessel is established. No matter in which geographical location the sea products were 
caught  or  acquired  (in  the  territorial  waters,  exclusive  economic  zone,  international  waters,  etc.),  the 
partner  country  of  the  sea  products  will  be  the  country  where  the  economic  owner  of  the  vessel  is 
established. 
651. The trade flows. Both outgoing and incoming flows shall be recorded. It should be noted that only 
trade of the first landing of the sea products falls under these specific provisions; onward trade after the 
first landing should be reported according to the normal legal provisions: 

  Arrivals/imports  shall  be  reported  when  a  vessel  from  another  Member  State/non-member 
country lands sea products in the reporting Member State’s port or when a vessel of the reporting 
Member State acquires the sea products from the vessels of other countries at sea. 

  Dispatches/exports  shall  be  reported  when  a  vessel  of  the  reporting  Member  State  lands  sea 
products in other Member States’/non-member countries’ ports or in other countries’ vessels at 
sea. 

Figure 36: Recording of sea products 

652. To  compile  statistics  on  sea  products  may  be  quite  complicated  because  it  is  difficult  to  monitor 
economic operators which could provide statistical information, particularly when the economic operators 
in the reporting Member State are in charge of a vessel which flies another country’s flag. 

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Specific goods or movements  4 

653. The compilers of trade statistics should be aware that the definition of the partner country applicable 
for customs purposes and statistics is not the same. The definition of partner country in Customs for sea 
products  relates  to  the  geographical  place  where  the  sea  products  were  caught  or  acquired,  whereas  in 
statistics the partner country should be allocated according to the establishment of the economic owner of 
the vessel. Moreover, in Customs the vessels’ nationality mainly depends on the flag which the vessel is 
flying, whereas  in  statistics  the  vessel  is attributed  to  the country of  the  establishment  of  the  economic 
owner of the vessel. 
654. Therefore  the  use  of  additional  data  sources  alongside  the  traditional  one  is  necessary  in  order  to 
compile  full  coverage  of  trade.  In  general  there  are  several  data  sources  which  may  be  used  for 
compilation of sea products statistics: direct data collection from PSIs via the Intrastat system, data from 
customs declarations, T2M form and data from fishery statistics (in particular landing statistics). The use 
of the ships registers could also help to monitor economic owners. 
655. NSAs are encouraged to establish an appropriate data collection system and to combine these data 
sources  in  a  comprehensive  manner  so  that  double  counting  or  missing  trade  flows  are  avoided.  The 
provisions for trade statistics on sea products are part of the rules on specific goods or movements, which 
allow  maximum  of  flexibility  as  regards  data  collection.  This  includes  the  use  of  any  additional  data 
sources (e.g. landing declarations of national vessels on sea products landed abroad), which would help to 
implement legal requirements. 
656. A T2M form is used to prove the EU status of fish products caught by EU fishing vessels and may 
be required when fish landed in a non-member country is then brought into the EU: 

 

 

for  products  of  sea-fishing  caught  by  an  EU  fishing  vessel,  in  waters  other  than  the  territorial 
waters of a country or territory outside the customs territory of the EU; 
for goods obtained from such products on board that vessel or from an EU factory ship, (using in 
the production possibly other products having EU status) and which are to be brought into the 
customs territory of the EU. 

657. Therefore a T2M form acquired from Customs might be useful for compiling intra-EU statistics on 
arrivals of fish from other Member States. 
658. Some good practices on how to improve compilation of sea products statistics might be mentioned: 

  establish relations with the fishery statistics and use their data for trade statistics needs; 
  analyse  the  usefulness  of  all  additional  data  sources  from  relevant  administrations,  such  as 

 

landing declarations, catch certificates, T2M forms, etc.; 
identify the VAT registered fishing companies and provide them with  additional guidelines on 
their reporting obligations. 

4.8  Spacecraft 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Commission Regulation (EC) No 1982/2004, Article 22 and Annex I, point (i) 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3 

Commission Regulation (EU) No 113/2010, Article 23 and Annex I, point (i) 

659. Specific  provisions  for  spacecraft  and  their  launchers  are  necessary  because  of  certain  unique 
circumstances, namely: 

 

 

the  various  transactions  which  may  take  place  between  the  spacecraft’s  production  and  its 
putting  into  orbit.  Broadly  speaking,  the  following  stages  can  be  identified:  production  of  the 
spacecraft; its possible purchase/sale; its transfer from the production site to the launch base; its 
launching; its commercial use; 
the significance, as far as physical flows are concerned, of the countries where the launch bases 
are located such as France (French Guiana); 

  high proportion of the total cost of the spacecraft taken up by transport and insurance costs. 

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660. Consequently,  it  is  somewhat  problematic  to  apply  the  ‘physical  movement’  criterion  to 
international transactions in spacecraft and their launchers when compiling ITGS: 

  The ‘physical movement’ approach ‘inflates’ the statistics of the launching country, which adds 
to its own stock of material resources all the transactions involving the launcher on the one hand 
(imports  of  parts  required  to assemble  the  launcher,  export  of  the  launcher  into  space)  and  the 
spacecraft  on  the  other  (its  import  and  export).  Moreover,  the  values  themselves  are  ‘inflated’ 
since they incorporate considerable transport and insurance costs; 

  The  launching  of  the  launcher  is  treated  as  an  ‘export’  (an  export  declaration  is  generally 
completed  for  customs  purposes)  whereas  in  fact  the  launcher  is  merely  a  means  of  transport 
used only to project the spacecraft into space; 

  The real economic and commercial nature of the transactions is disguised, the reason being that 
spacecraft are not usually included in ITGS of the countries which buy and use them, since they 
are generally dispatched directly from the production site to the launching site; 

  The  requirements  of  National  Accounts  and  Balance  of  Payments  departments  who  need  to 

monitor transfers of ownership are not met. 

661. Sending  a  launcher  into  space  is  excluded  from  trade  statistics.  Satellite  launchers  —  CN 
8802 60 90  —  (such  as  Soyouz,  Vega  or  Ariane  rocket)  should  be  treated  as  means  of  transport. 
Consequently,  sending  a  launcher  into  space  should  be  treated  as  a  service  and  not  be  recorded  as  an 
export in ITGS of the launching country. However, all transactions (imports and exports, whether final or 
for processing) linked to the construction of the launcher shall be recorded normally. 

Example 72  
Part of a launcher produced in Germany is delivered to France for final assembly. This movement shall be treated as 
German dispatch to France/French arrival from Germany. 
A finished launcher is dispatched from France to the space centre in Kazakhstan. The German producer delivers also 
some  spare  parts  of  the  launcher  directly  to  Kazakhstan.  French  export  of  the  launcher/German  export  of  the  spare 
parts to Kazakhstan shall be recorded in ITGS. 

662. The  principle  of  transfer  of  economic  ownership  applies  to  trade  with  spacecraft.  Commercial 
transactions  involving  finished  spacecraft  —  CN  8802 60 10  —  shall  be  recorded,  at  the  time  of 
launching, on the basis of the transfer of economic ownership, assuming such a transfer takes place, rather 
than  on  the  basis  of  physical  flows.  The  exporting  country  would  therefore  be  the  country  where  the 
satellite was produced prior to the transfer of economic ownership; the importing country would be  the 
country where the first economic owner of the new satellite is resident once the transfer has taken place. 
663. Where  no  transfer  of  economic  ownership  occurs,  dispatching  a  satellite  from  the  country  of 
production to the launching country and putting it into orbit would therefore not be recorded in ITGS. All 
transactions  (imports  and  exports,  whether  final  or  for  processing)  linked  to  the  construction  of  the 
satellite should be recorded normally. However, transfer of economic ownership transactions of satellites 
in orbit are excluded from trade statistics. 
664. The  ex-works  value.  The  statistical  value  recorded  shall  be  the  value  'ex-works'  for  both  arrivals 
and dispatches. Consequently, any transport cost incurred for sending the spacecraft to the launch bases 
and further on into orbit are excluded. 

4.9  Electricity and gas 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Commission Regulation (EC) No 1982/2004, Article 23 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 

Commission Regulation (EU) No 113/2010, Article 24 

665. According to the ITGS regulations electricity and gas are considered specific goods or movements 
for  which  special  legal  provisions  apply.  Electricity  is  classified  under  CN  code  2716 00 00,  while  gas 
considered is natural gas in gaseous state under CN code 2711 21 00. Special provisions on gas concern 

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only  the gas which  is moving  through  the pipeline.  Gas  in  liquid  state or  in  gaseous state  which  is not 
transported via pipelines shall be statistically treated as all other goods. 
666. Two main reasons have led to the adoption of specific statistical treatment for natural gas in gaseous 
state and electricity: firstly the very specific physical characteristics of these goods and secondly the fiscal 
rules  of  taxation  applied  since  2005,  which  require  VAT  to  be  paid  at  the  place  where  the  trader  of 
electricity or gas is established or where the customer effectively uses and consumes them(1). Moreover it 
can be difficult to capture the physical movement of electricity crossing the border at a given period in 
time, as it is a continuous flow in one or other direction. 
667. The ITGS regulations do not specify methodological exceptions for the recording of electricity and 
gas. NSAs are required to record only the physical flows of electricity and gas in intra-EU and extra-EU 
trade statistics. In extra-EU trade, as a partner country for imports should be recorded country of origin, 
for intra-EU trade country of consignment. The regulations provide access to all additional data sources, 
which  may  help  to  compile  statistics.  In  addition,  the  statistical  value  of  electricity  and  gas  may  be 
estimated.  
668. Estimation of statistical value. The transaction value of trade in electricity and gas may not always 
be  available  for  statisticians,  especially  when  the  data  are  collected  from  grid  operators.  Therefore  the 
legislation  allows  the  statistical  value  to  be  estimated.  Member  States  may  choose  any  data  source 
available for the estimations, e.g. weekly, monthly market prices, Intrastat or customs declaration. NSAs 
are required to inform Eurostat about the estimation method used before its application. 

4.9.1  The electricity sector business model 
669. One  of  the  main  changes  introduced  by  the  EU  directives(2)  is  the  requirement  to  split  electricity 
sector  into  four  independent  entities:  generation,  transmission,  distribution  and  supply.  In  practice,  the 
directive  imposes  a  legal  separation  and  minimum  criteria  to  ensure  organisation  and  decision-making 
independence.  
670. The electricity sector consists of the following players:  

  Generator: It is a company, producer or importer, who agrees to inject into the grid the amount 

of energy purchased by the customer.  

  Transmission system operators (TSO): It is the operator of the grid (mostly high voltage) used 
for  interregional  and  international  transportation  of  electricity.  TSOs  role  is  to  facilitate  the 
market.  TSO  are  responsible  for  operating,  maintaining  and  developing  the  network  and  its 
interconnections. 

  Distribution  system  operators:  It  is  the  operator  of  the  electricity  network  (low  or  medium 

voltage) to which the final customer is physically connected.  

  Suppliers:  Energy  suppliers  act  as  distributors  of  the  electricity  to  the  final  customers.  The 
energy supplier purchases electricity at the best price and sell it to the final user. Its margin thus 
depends essentially on the cost of energy supply and the selling price to the customer. Depending 
on the countries, the generator of electricity can be also the main supplier. 

  An independent regulator: each Member State has its own institution which is responsible for 
ensuring the proper functioning of the energy market and manages disputes between users and 
various operators. Its jurisdiction extends to the electricity and gas markets.  

671. At the European level, several directives were issued which created two institutions with a specific 
role: 

  Agency  for  the  Cooperation  of  Energy  Regulators  was  created  in  2011  with  the  aim  of 
assisting  and  coordinating  the  work  of  national  authorities  regulating  energy  markets  for 
electricity and gas. The agency plays a central role in the development of EU-wide networks and 

(1)  Council Directive 2006/112/EC, Article 38 and 39. 
(2)  Directive  2003/54/EC  of  the  European  Parliament  and  of  the  Council  of  26  June  2003  concerning  common  rules  for  the  internal  market  in 

electricity and repealing Directive 96/92/EC. 

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establishment  of  market  rules.  Moreover,  it  monitors  the  work  of  European  Networks  of 
Transmission System Operators (ENTSO). 

  European  Network  of  Transmission  System  Operators  for  Electricity  is  responsible  for 
managing  the  electricity  transmission  system  and  for  allowing  the  trading  and  supplying  of 
electricity across borders in the Community. It ensures the security of the system in the context 
of the liberalisation. 

672. As far as trade statistics in electricity is concerned, the main players of interest among those listed 
above  are  the  generators  of  electricity,  the  TSO  and  the  ENTSO.  Nevertheless,  Agency  for  the 
Cooperation  of  Energy  Regulators  and  national  equivalent  counter  parts  can  also  provide  information 
since their role is to monitor the application of the legislation by various players.  
673. NSAs are encouraged to develop the necessary knowledge about functioning of electricity and gas 
markets at the national and the EU levels in order to be able to correctly compile ITGS and to develop 
methodologies for the collection of the statistical data. 
674. It  is  very  important  that  ITGS  compilers  establish  close  contacts  between  producers  of  ITGS  and 
TSOs at national level: these institutions are the key contacts for better understanding and identification 
of data related to physical flows of electricity and gas. 

4.9.2  The gas sector business model 
675. The gas industry consists of a number of technically demanding and capital intensive activities. The 
upstream stage of the gas operating system consists of exploration, drilling, extraction and purification of 
gas. The downstream stage consists of transmission and distribution of gas. The gas is transported from 
production to consumption areas mainly by high pressure pipelines on land, underground or underwater 
(similar to transmission network in electricity). Transportation of gas by pipelines is the most reliable and 
cost effective solution.  
676. Like in electricity sector there are similar players in the gas sector, however, due to the fact that the 
gas can be stored, there is an additional player for storage facilities:  

  Producers:  they  exploit  underground  gas  fields  and  sell  the  gas  to  wholesale  traders.  What 
concerns  the  EU  market,  producers  are  mainly  located  outside  Europe(1).  Gas  is  imported  by 
pipelines  and  by  LNG  tankers.  The  main  producers  involved  in  European  supplies  of  gas  are: 
Gazprom (Russia), Sonatrach (Algeria) and Statoil (Norway). 

  Suppliers: Suppliers buy gas from producers on the wholesale market and sell it to customers on 
the retail market. They have to pay for the access to the transmission and distribution networks 
(or other facilities for storage) needed to deliver the gas to the final users. This activity is open to 
competition. Important European suppliers are, for instance, TEGAZ, E.ON, ENI, GDF SUEZ, 
VNG,  RWE,  SPP,  etc.  Those  companies  are  also  often  involved  in  upstream  activities 
(exploration, production, etc.).  

  Transmission System Operators: TSOs role is to bring gas to customers on behalf of various 
suppliers  and  to  ensure  the  quality  and  continuity  of  energy.  They  are  also  in  charge  of  the 
development  and  the  maintenance  of  the  gas  transmission  and  distribution  network  and  are 
responsible for meters and balancing the network. This activity being a natural monopoly is not 
open to competition.  

  Storage  system  operators:  They  offer  to  suppliers  gas  storage  facilities  in  order  to  secure 

supply and to overcome the variation of supply and demand.  

  LNG Terminal Operators: they  manage, develop and maintain LNG terminal infrastructures. 
LNG terminals make their facilities available to all suppliers in the marketplace, as required by 
the EU legislation. 

(1) 

Import dependency for gas (measured as the ratio of net imports to gross inland consumption plus international marine bunkers) for the EU is in 
between 60 and 70%. Only Denmark and the Netherlands are net exporters of gas. 

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  Distribution  System  Operators:  Gas  distribution  networks  connect  high-pressure  gas 
transmission  systems  (managed  by  TSO)  to  end  customers.  Distribution  System  Operators 
ensure planning, development, operation and maintenance of these regional networks dedicated 
to retail trade.  

  An independent regulatory body: it monitors the competition on the gas market and checks if 
rules  are  respected  by  the  different  players  (e.g.  access  to  gas  network,  independence  of 
transmission  and  distribution  system  operators,  etc.).  This  institution  also  monitors  prices, 
wholesale markets and import/export transactions. 

677. At European level, two institutions have been created with a specific role: 

  The Agency for the Cooperation of Energy Regulators was created in 2011 with the aim of 
assisting the authorities regulating energy markets to exercise at Community level the regulatory 
tasks performed in the Member States and, where necessary, to coordinate their action. 

  The European Network of Transmission System Operators for Gas (ENTSO-G) was created 
following the adoption of the European Union third legislative package on the electricity and gas 
markets.  It  aims  to  promote  the  completion  and  cross-border  trade  for  gas  on  the  European 
internal market, and development of the European natural gas transmission network. According 
to  the  third  energy  package  European  Network  of  Transmission  System  Operators  for  Gas  is 
required to develop an EU wide ten year gas network development plan. 

678. As far as trade statistics in gas is concerned, the main players of interest among those listed above 
are  the  suppliers,  the  TSO  and  the  European  Network  of  Transmission  System  Operators  for  Gas. 
Nevertheless, Agency for the Cooperation of Energy Regulators and national equivalent counter parts can 
also provide information since their role is to monitor the application of the legislations by the different 
players. 

4.9.3  VAT rules for electricity and gas supplies 
679. Before  the  changes  in  VAT  Directive  the  place  of  taxation  of  natural  gas  in  pipelines  and  of 
electricity was the place of supply. These rules have worked adequately in a national context but were no 
longer suitable within liberalised market and increased cross-border supplies of electricity and gas. It was 
difficult to determine where the place of supply of electricity and gas was located. Moreover, the Member 
States  interpreted  the  rules  differently,  which  made  difficulties  for  traders  supplying  electricity  and  gas 
across borders. 
680. The  new  requirements  in  the  case  of  supplies  of  electricity  and,  departed  from  the  basic  principle 
governing  the  VAT  treatment  of  goods  —  the  place  of  taxation  is  the  place  where  the  goods  are 
physically  located.  New  rules  changed  the  place  of  taxation  from  the  place  of  supply  to  the  place  of 
consumption,  which  facilitated  the  functioning  of  the  energy  Single  Market,  eliminated  problems  of 
double taxation or non-taxation and distortions of competition between traders.  
681. A supply of electricity or gas to a trader established in another Member State either for resale or for 
own  consumption  should  be  exempt  in  the  country  of  origin  and  taxable  in  the  country  where  the 
receiving trader/consumer is located. The problem is that the supplier cannot provide the necessary proof 
of the transportation of electricity in order to obtain an exemption. 
682. The VAT Directive  makes  a distinction between  a  taxable  dealer  and  a  final  consumer. A  taxable 
dealer is defined as a ‘taxable person whose principal activity in respect of purchases of electricity, gas, 
heat  or  cooling  energy  is  reselling  those  products  and  whose  own  consumption  of  those  products  is 
negligible’. More over the place of taxation not only defines the nature of the goods but as well how the 
goods are supplied.  
683. The directive provides that: 

  supplies of electricity and gas (through the natural gas distribution system) made with a view to 
resale would be taxable in the country where the buyer was located. Where the supplier and the 
buyer were not established in the same territory, the buyer would be the person subjected to VAT 
under self-assessment arrangements. 

  supplies of electricity and gas (through the natural gas distribution system)  to final consumers, 
whether or not they are traders, would be taxed at the place where the actual consumption took 
place. Taxation would thus accrue to the Member State of final consumption. 

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684. The supply of electricity and of gas through the natural gas distribution system is taxed at the place 
of the customer. Therefore in order to avoid double taxation, the import of electricity and gas is therefore 
exempted from VAT. 

4.9.4  Data sources for recording electricity and gas 
685. The recording of trade in electricity and gas statistics requires data on both quantity and value. The 
statistical value can be collected or computed using data on quantities and prices. 
686. Beside Intrastat or customs declarations, several alternative sources of information are available, in 
particular: administrative data (VAT), data from grid operators, control agencies, stock exchange markets, 
and energy and price statistics. Each data source includes advantages and disadvantages, it can be used 
separately, combined or it can be compared with other sources to crosscheck information. 
687. Data from Intrastat and customs declarations. Intrastat or customs declarations are the traditional 
way  of  collecting  trade  data.  However  traders  cannot  be  considered  as  a  fully  relevant  data  source  for 
electricity  and  gas,  as  with  the  opening  of  the  market,  several  trade  transactions  might  be  followed  by 
only  one  physical  movement  of  goods.  As  a  result,  quantities  and  values  provided  by  traders  are  not 
necessarily  directly  linked  with  the  physical  movements  of  electricity  and  gas.  The  collection  of 
information directly from traders might therefore not be sufficient or accurate. As regards extra-EU trade, 
the data on trade flows with non-member countries could be collected via customs declarations. However, 
in  case  a  Member  State  is  geographically  surrounded by  other  Member  States,  the  use  of  customs  data 
might lead to double counting. 
688. Even in the cases where the trade transaction is followed by physical movement, the real quantities 
transmitted  might  be  different  due  to  the  quite  significant  losses  during  transmission,  especially  in  the 
case of electricity.  
689. Administrative data (VAT returns). Alongside to Intrastat declarations VAT data in general are 
very useful for crosschecking and completeness of ITGS statistics. All intra-EU acquisitions and supplies 
are declared in respective VAT returns boxes and this information can be reused by Intrastat.  
690. All  intra-EU  trade  contracts  in  electricity  and  gas,  in  spite  of  the  fact  whether  the  physical  flow 
follows  the  financial  transaction,  will  be  declared  for  VAT  purposes.  As  the  place  of  supply  is  very 
difficult to define for electricity and gas transmitted via grids, the taxation rules follow the commercial 
transactions.  
691. From  the  VAT  point of  view  (in  contrary  to other  goods)  it  is not important  if  electricity  and gas 
cross the border and therefore traders might not always know what are corresponding physical flows. In 
consequence,  the  traders  cannot  provide  reliable  data  on  physical  flows  of  electricity  and  gas.  After 
several financial transactions, only one physical flow might be delivered. Therefore to connect financial 
flow to physical flow is impossible.  
692. From the point of view of VAT, intra-EU trade in electricity and gas is not considered as intra-EU 
supply and acquisition, therefore the amounts of traded electricity are not recorded in the respective VAT 
declaration boxes in most of Member States. The VIES declaration (the VAT recapitulative statement on 
intra-EU supplies) is not filled in for supplies of electricity and gas as well.  
693. The value of acquisitions or only the amount of VAT due for transactions in electricity and gas will 
be declared on other VAT declaration boxes, which are nationally specific. Moreover, in the same VAT 
return  box  can  be  declared  other  specific  goods  (e.g.  the  goods  for  which  reverse  charge  mechanism 
applies)  and  therefore  it  is  not  possible  to  distribute  these  values  according  to  the  products  traded. 
Consequently  to  use  the  VAT  data  for  statistical  purposes  might  be  very  difficult,  especially  in  cases 
when the amount of financial transactions, which are not followed by physical flows, is significant.  
694. Although  the  VAT  on  trade  in  electricity  and  gas  are  not  providing  statistics  with  reliable 
information,  NSAs  are  encouraged  to  analyse  with  tax  administrations  the  national  provisions 
concerning recording of these data and to evaluate its possible reuse for ITGS purposes. 
695. Data from grid operators. TSOs are good data source for information on physical movements of 
electricity and gas. Since they are in charge of managing and balancing the grids, they record information 
about  the  amounts  which  are  injected  in  the  national  grids.  However,  the  grid  operators  cannot  always 
distinguish transit flows neither precisely define the partner countries.  

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Specific goods or movements  4 

696. Grid  operators  record  only  physical  flows  with  neighbouring  countries  at  interconnection  points. 
Because of the physical laws, electrical current follows the path of the least resistance, meaning that the 
power  flowing  through  a  network  follows  non-determined  route  (so  called  unplanned  flows).  In  other 
words,  when  a  supplier  and  a  generator  contract  for  the  delivery  of  a  certain  amount  of  power  at  a 
certain  time,  the  supplier  can  never  be  sure  that  the  power  he  bought  is  coming  from  the  generator  he 
contracted with. Moreover, due to significant transmission losses, the electricity is consumed as closest to 
the production sites.  
697. For the particular issues of transit flows and grid loss, an adjustment would be needed. To correctly 
and precisely define partner countries for electricity is not possible. Only information with neighbouring 
countries is available. Nevertheless, according to the experience of some Member States, it is possible to 
estimate the share of transit trade and losses in the grids of electricity on the basis of expert knowledge.  
698. The same situation occurs with gas transported via pipeline. Once the gas is loaded to the grid, the 
origin or country of consignment on imports or the country of last destination on exports can hardly be 
traceable. Therefore reliable estimations methods of the partner countries are required. Country of origin 
is very important information for the users of gas imports data. However intra-EU trade records only the 
country of consignment.  
699. Data  from  stock  exchange  markets.  The  prices  from  organised  exchange  markets  are  an 
alternative data source, however they should be used with the caution. To use spot markets(1) prices for 
the estimation of the statistical value of electricity and gas might provide not reliable results since these 
prices reflect only short-term transactions, they are often higher than long-term transaction prices and are 
highly volatile. However the bulk of transactions are usually done under long-term contracts.  
700. NSAs are encouraged to use for the estimation of statistical value of electricity and gas long-term 
contract prices and other available information which correctly reflects the value of electricity and gas on 
the  particular  market.  It  is  recommended  that  NSAs  establish  methodologies  for  the  estimations  of 
transit trade of gas where the collection of data is not possible. The price of electricity and gas may vary 
greatly depending on the type of commercial transaction. Prior to the use of price data from other sources, 
conceptual constraints should be precisely analysed. Moreover, for the estimation of transit trade, NSAs 
are encouraged to consult transmission system operators, who could estimate the share of transit trade in 
the total flows of electricity and gas.  
701. Energy  Statistics  data.  The  energy  statistics  provide  users  with  the  monthly  quantitative  data  on 
exports and imports of electricity and gas and therefore could be a good complementary data source for 
compiling trade in goods statistics. Nevertheless, several methodological differences exist between ITGS 
and energy statistics: 

  Although definitions are very close to ITGS (both areas are recording physical flows of goods), 
energy  statistics  records  exports  and  imports  of  electricity  including  transit  flows.  Therefore 
the total quantities recorded by energy statistics should be always higher than in ITGS. There are 
differences in allocation of the partner countries. 

  The  annual  imports  data  of  gas  in  energy  statistics  are  compiled  based  on  the  same 
methodological  requirements  as  in  ITGS  (records  physical  flows  with  exclusion  of  transit). 
However exports data are more difficult to compare, as energy statistics is recording only export 
of  gas  which  is  domestically  produced  or  re-gasified  from  liquefied  natural  gas  and  then 
exported, whereas ITGS records exports of gas which might be previously imported. In this case, 
exports of gas data in ITGS can be higher than energy statistics data. The monthly gas data in 
energy statistics are compiled including transit. There are as well differences in allocation of the 
partner countries. 

702. Data  from  European  Agencies.  The  table  below  provides  information  on  the  main  regional 
databases  containing  monthly  information  broken  down  by  partner  countries.  Data  published  in  these 

(1)  Within  organised  power  exchange  markets,  the  spot  market  (also  called  the  day  ahead  market)  is  used  mainly  for  trading  of  electricity  for 
planning  purposes.  Estimation  of  electricity  needs  and  supplies  are  planned  long  time  in  advance  by  actors  (using  a  long  term  contract), 
however the exact needs are known accurately only one day in advance. The spot market is used by actors to adjust the quantity of needed 
electricity at the last moment (more exactly one day ahead). 

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Specific goods or movements  4 

databases are collected from the Member States. Although the methodology used for the compilation of 
the  data  needs  to  be  analysed,  this  information  could  be  reused  by  ITGS  compilers  as  alternative  data 
source for cross checks. 

Table 12: Data sources for trade in electricity and gas 

Indicator  

Source 

Description 

Constraint 

Quantity for gas 

International Energy 
Agency 
http://www.iea.org/gtf/inde
x.asp  

Quantity for 
electricity 

ENTSO-E database  
https://www.entsoe.eu/dat
a/data-portal/exchange/  

Prices for 
electricity and gas 

European market 
exchanges prices  
http://www.platts.com/ and 
various European trading 
plate forms 

IEA  has  been  collecting 
The 
monthly gas flow data on an entry 
and  exit  point  basis  (physical 
flows).  Data  are  provided  by 
country administrations. 

Electricity  physical  flows  crossing 
borders.  Data  are  from  national 
TSO. Consolidated data including 
all  ENTSO-E  members 
is 
available since January 2010. 

Day ahead base load prices. 

Transit trade not 
distinguished 

Transit trade not 
distinguished 

Data reflecting 
mainly short term 
transactions prices. 

703. NSAs  are  encouraged  to  identify  alternative  data  sources  for  quality  checks  and  compilation  of 
ITGS  in  gas  and  electricity  regarding  physical  flows,  prices  or  values.  For  each  new  data  source 
identified, a pro and cons table considering methodological requirement for ITGS should be established. 
The additional data sources should be used systematically for quality checks of ITGS data (in particular 
when Intrastat or customs declarations are the main data sources).  
704. It  is  recommended  that  NSAs  compare  ITGS  quantitative  data  with  the  data  of  the  energy 
statistics,  grid  operators  or  any  other  available  quantitative  data  in  order  to  verify  whether  further 
reconciliation is needed and to identify exact reasons of discrepancies. 

4.10  Military goods 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(b) 

Commission Regulation (EC) No 1982/2004, Article 24 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(3) 

Commission Regulation (EU) No 113/2010, Article 25 

705. Military goods are all goods intended for military use, e.g. arms, trucks, cars, aircraft, fuel, or any 
supplies  for  armed  forces.  These  goods  shall  be  included  in  intra-EU  and  extra-EU  trade  statistics  and 
standard statistical methods and rules shall be applied. 
706. However the legislation provides a possibility to transmit less detailed data if the information about 
the  trade  in  military  goods  falls  under  military  secrecy  in  line  with  the  national  definitions.  In  such 
cases,  NSA  should  obtain  information  about  trade  under  military  secrecy  from  relevant  national 
administrations or PSIs, at least the total value of such goods. 
707. NSAs are encouraged to be well aware of which national acts define the information falling under 
military or state secrecy and their content. 
708. Administrations responsible for the trade in military goods (e.g. Ministry of Defence), may request 
NSA application of confidentiality for the goods they have imported or exported. In such cases standard 
procedures of the application of passive confidentiality should be applied. 
709. The following strategy should be applied: 

  Whenever  possible,  the  most  detailed  data  should  be  collected  and  transmitted  to  Eurostat 

(without any confidentiality); 

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Specific goods or movements  4 

 

 

If the PSI requests confidentiality for military goods which do not fall under military secrecy, the 
standard  rules  for  confidentiality  provisions  apply;  the  detailed  data  should  be  collected  and 
transmitted  to  Eurostat,  but  the  data  should  be  flagged  for  confidentiality  according  to  the 
provisions of Doc MET 400; 
If the NSA receives, from the relevant national administration, information falling under military 
secrecy in aggregated form only, then the total value is included in total exports and imports; the 
simplified partner country (QX, QY,QZ) and CN codes (9999 99 99, 9999 xx 99 or 9999 xx xx) 
in line with Doc MET 400 should be used. 

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Particular trade flows  5 

5  Particular trade flows 

5.1  Goods in transit 
710. Definition.  According  to  the  UN  concepts  and  definitions  of  International  Merchandise  Trade 
Statistics, goods in transit are goods entering and leaving a Member State with the exclusive purpose of 
reaching another Member State/country. They should be excluded from ITGS in the transit Member State. 
So NSAs are required to ensure that any goods in transit are excluded from ITGS. The UN Compilers 
Manual  recommends  identifying  goods being  simply transported  through  a  country  as  goods  which  are 
entering the compiling country for transportation purposes only. 

Intra-EU trade statistics — Goods in simple circulation 

5.1.1 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 2(g), Articles 3(2) and 
3(3) 

711. Article 2(g) of Regulation (EC) No 638/2004 defines ‘goods in simple circulation between Member 
States’  and  Articles  3(2)  and  3(3)  of  the  same  regulation  exempt  the  reporting  of  ‘goods  in  simple 
circulation between Member States’ with the consequence that in the ‘transit Member State’ nothing has 
to be declared. 
712. Goods in simple circulation between Member States means Community goods dispatched from 
one Member State to another, which, on the way to a Member State of destination travel directly through 
another Member State or stop for reasons related only to the transportation of goods. This definition was 
agreed  for  intra-EU  trade  in  order  not  to  use  the  term  ‘transit’  which  normally  should  be  used  only  in 
relation to extra-EU trade and customs procedures. 
713. Determination of the beginning and the end of a trade flow is a crucial factor for a coherent picture 
of trade between Member States. Therefore, the reporting obligations of the Member State of dispatch and 
of the Member State of arrival are defined to that effect in the legislation. Only the trade flows between 
the Member State of consignment and the Member State of destination are recorded. Any halts inherent in 
the transport of the goods are not reported. 
Figure 35: Simple circulation between Member States 

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142 

 MS A reports dispatch to MS C MS B no reporting Trade flow 1 Goods in simple circulation in MS B MS B  reports  arrival from MS A dispatch to MS C A halt NOT inherent in transport takes place in MS B MS A reports dispatch to MS B Trade flow 1 MS C reports arrival from MS A MS A reports dispatch to MS C A halt inherent in transport takes place in MS B MS B no reporting Trade flow 1 MS C reports arrival from MS A  MS C reports arrival from MS B Trade flow 2     
 
 
 
Particular trade flows  5 

714. Identification  of  partner  Member  State.  When  goods  enter  one  or  more  Member  States  in  transit 
before  reaching  the  Member  State  of  arrival  and  have  been  subject  in  those  Member  States  to  halts  or 
legal  operations  not  inherent  in  their  transport  (e.g.  change  of  ownership),  the  Member  State  of 
consignment shall be taken as the Member State where such halts or operations occurred. 

5.1.2  Extra-EU trade statistics 
715. Definition.  Customs  transit  is  a  customs  procedure  used  to  facilitate  the  movement  of  goods 
between two points of a customs territory, via another customs territory, or between two or more different 
customs  territories.  It  allows  for  the  temporary  suspension  of  duties,  taxes  and  commercial  policy 
measures that are applicable at import, thereby allowing customs clearance formalities to take place at the 
destination rather than at the point of entry into the customs territory. 
716. Customs  transit  is  particularly  relevant  to  the  Community  where  a  single  customs  territory  is 
combined with a multiplicity of fiscal territories: it allows the movement of goods under transit from their 
point of entry into the Community to their point of clearance where both the customs and national fiscal 
obligations are taken care of. 
717. Under  customs  transit  procedures  only  non-Community  goods  are  transported.  These  goods  are 
declared to Customs under special procedure related to transit and should be excluded from deliveries of 
data related to trade statistics. 

5.2  Triangular trade 
718. Definition.  Triangular  trade  in  the  meaning  of  Intrastat  exists when  three  subjects  are involved  in 
the intra-EU trade transaction. The most common case occurs when a company in Member State A sells 
goods to a company in Member State B — intermediary, which in turn sells it to a company in Member 
State C, although the goods are physically moved only once — from A to C. 
Figure 36: Triangular trade — standard case 

719. In  such  cases,  intra-EU  trade  statistics  shall  record  a  dispatch  from  A  to  C  and  an  arrival  in  C of 
goods from A. There is, however, a risk that Member State A or C will declare Member State B as its 
trading  partner,  because  the  sales  and  purchase  contract  are  concluded  with  Member  State  B,  whereas 
Member State B might declare an arrival and a dispatch although there is no physical movement in B. 
720. Reporting  obligations  for  fiscal  purposes  (following  the  invoices)  and  for  trade  statistics  may  be 
different in the case of triangular trade.  The principle of following the movement of the goods remains 
applicable for statistical purposes, and the invoice does not have to be followed: 

  The  PSI  in  the  Member  State  of  dispatch  (A)  must  declare  the  partner  Member  State  (C)  to 

which the goods are delivered, regardless of where the invoice is sent; 

  The  PSI  in  the  Member  State  of  arrival  (C)  must  declare  the  partner  Member  State  (A)  from 
which the goods are delivered, regardless of the Member State to which the payment is made; 
  The 1st purchaser must not report the goods movement for Intrastat when the goods do not enter 

the intermediate Member State (B). 

721. Reporting errors due to triangular trade should be minimised. The following measures are advisable: 
Identify  trade  operators  engaged  in  triangular  trade  —  both  in  the  intermediate  Member  State 
and in the reporting Member States; 

 

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143 

 Definition: MS A — MS of dispatch MS B — Intermediary MS C — MS of arrival  MS B MS A  Invoice MS C Supplier of goods 1st purchaser Invoice Final customer Goods  
 
 
 
Particular trade flows  5 

 
Inform PSIs in detail of their reporting obligations when they are involved in triangular trade; 
  Use  mirror  statistics  in  order  to  discover  incorrect  partner  country  reporting  and  erroneous 

declarations in the intermediate Member State; 

  Use  VIES  data  for  additional  quality  checks  concerning  the  correct  reporting  of  the  partner 

country. Explain the differences in the concept of triangular trade used in VIES and ITGS. 

Example 73  
Triangulation with two Member States 
A) The goods are delivered from Member State A directly to a company B2 in Member State B, but a VAT registered 
company B1 in Member State B has concluded the contract giving rise to the delivery. Company B1 sends the invoice to 
company B2. 
Company B1 shall declare the arrival for Intrastat. A dispatch declaration has to be reported in Member State A. 

Figure 37: Triangular trade with 1st purchaser and customer from the same MS 

B) The goods are delivered directly from a company A1 in Member State A to a company B in Member State B, but the 
invoice  is  addressed  by  company  A1  to  another  VAT  registered  company  A2  which  has  concluded  the  contract  giving 
rise to the dispatch in the Member State A. The movement from A to B has to be declared for Intrastat. 
Company A2 , even if it is not in charge of the transport, shall declare for Intrastat. An Intrastat declaration on arrival has 
to be declared in Member State B. 
Figure 38: Triangular trade with supplier and 1st purchaser in the same Member State 

C)  Company  A1  in  Member  State  A  sells  goods  to  company  B  in  Member  State  B.  The  goods  are  delivered  from 
company A1 to another company A2 in Member State A. However, the invoice is addressed to a VAT registered person 
in Member State B. 
No Intrastat declaration is made, because the goods have not left Member State A. 

Figure 39: Triangular trade with supplier and customer in the same Member State 

Triangular trade with a partner in a non-member country 
D) Company X is established in a non-member country. Companies A and B are established in two different Member 
States. The company B buys the goods from company X. However the company X buys these goods from company A. 
The goods will be directly delivered from A to B. 

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144 

 MS A Company A – supplier MS B Company B1 Company B2 Invoice Goods Invoice  MS B MS A Company A1 Company A2 Invoice Company B Goods Invoice  MS B MS A Company A1 Company A2 Invoice Company B Invoice Goods  
 
 
 
 
 
Particular trade flows  5 

Where  the  selling/purchasing  company  in  the  intermediate  country  is  established  in  a  non-member  country  X  the 
appointment of a tax representative may be necessary (either in Member State A or B) depending on the requirements 
of the Member States involved. 
An Intrastat dispatch will be declared by company A and arrivals by company B. 
Figure 40: Triangular trade with 1st purchaser in a non-member country 

E)  Where  the  country  of  final  destination  is  a  non-member  country  X  and  the  goods  do  not  enter  the  intermediate 
Member State B an export declaration must be made in the Member State where the goods are physically presented to 
Customs (Member State A). 
These  transactions  should  not  be  declared  for  Intrastat  even  if  invoices  are  issued  between  the  operators  in  the 
intermediate Member State B and the exporting Member State A. 
Only  the  export  transaction  based  on  the  customs  declaration  shall  be  taken  into  account  within  the  extra-EU  trade 
statistics in Member State A. 

Figure 41: Triangular trade with customer in a non-member country 

F) A company B in Member State B buys goods from a company A in another Member State, however the goods are 
delivered directly from a non-member country. 
The same practice applies when the country of consignment (origin) is a non-member country X. An import declaration 
has to be made in the Member State where the goods are released for free circulation and are physically presented to 
Customs (Member State A). 
The customs import declaration has to be done  and be included in extra-EU trade; there should be no declaration for 
Intrastat. 

Figure 42: Triangular trade with supplier in a non-member country 

5.2.1  Triangular trade within the context of VIES 
722. There  exists  a  special  simplification  option  to  simplify  the  taxation  procedures  for  companies 
dealing with triangular trade within the EU. The purpose of this simplification option is to avoid double 
taxation in triangular trade transactions. The requirements are that three traders must be involved in the 

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145 

 MS A   Company A — supplier Country X Company X — 1st purchaser MS B Company B — customer Invoice Invoice Goods  MS A   Company A — supplier Country X Company X — customer MS B Company B — 1st purchaser  Goods Invoice Invoice  MS A   Company A — customer Country X Company X — supplier MS B Company B — 1st purchaser Invoice Invoice Goods  
 
 
 
 
 
Particular trade flows  5 

triangular  trade  transactions  and  that  all  three  must  be  registered  for  VAT  in  three  different  Member 
States. The place of residence is not essential, i.e. also non-member traders can be involved in triangular 
trade, on condition that they are registered for VAT in one of the Member States. 
Figure 43: Triangular trade within the context of VAT recapitulative statements (VIES) 

723. It has to be noted that the concept of triangular trade in a VIES context is different from the one used 
in ITGS, where all variations of triangulation mentioned above are possible. However, in the context of 
the  VAT  recapitulative  statement  (VIES)  the  trade  transaction  is  marked  as  triangular  trade  only  if  the 
goods are not physically present in the reporting Member State. Therefore, when comparing Intrastat and 
VIES  data,  all  transactions  marked  as  triangular  trade  shall  be  excluded  from  the  data  of  the  reporting 
Member State. However, in the Member State of arrival of the goods these (flagged) data might be used 
for the reconciliation of intra-EU trade asymmetries and check of partner country allocation. 
724. Whereas,  in  the  framework  of  Intrastat,  the  physical  goods  flow  is  followed,  the  reporting 
obligations in VIES are different, as it is the invoice flow which is followed. In the situation described in 
the example above the following obligations for traders occur: 

  The seller of goods in Member State A reports intra-EU supply indicating the VAT ID number 
of the trader in Member State B. In the VAT recapitulative statement this transaction should not 
be marked as triangular trade as the goods were physically in Member State A. At the same time 
the trader in Member State A should report dispatch of goods for Intrastat, indicating as partner 
country Member State C; 

  The trader in the Member State B reports an intra-EU supply indicating the VAT ID number of 
the partner in the Member State C in his VAT recapitulative statement and marks this transaction 
as triangular trade. He will not report this transaction for Intrastat, as the goods move outside of 
Member State B; 

  The  buyer  of  goods  in  Member  State  C  does  not  need  to  provide  a  recapitulative  statement. 
However the Intrastat arrival declaration has to be filled in indicating as partner country Member 
State A. 

5.3  Quasi-transit 
725. Definition.  Quasi-transit  occurs  when  goods  enter/leave  an  economy  and  are  declared  as 
imports/exports  for  customs  purposes  without  the  transit  economy  having  acquired  ownership  of  the 
goods. So quasi-transit concerns imports or arrivals in a Member State of goods which are dispatched or 
exported without changing ownership to a resident of that Member State. In contrast to real transit, quasi-
transit has to be recorded as a basic principle for EU purposes. Processing operations, where the change 
of ownership does not occur, are not considered as quasi-transit. 
726. Quasi-transit affects mainly imports into the European Union. The Customs legislation provides for 
a  possibility  to  release  the  goods  for  free  circulation  (via  a  representative)  at  any  customs  office in  the 
EU, regardless of whether the goods are then transported to another Member State or not. The release of 
goods for free circulation at the external frontier of the European Union provides certain advantages: once 
customs  duties  have  been  paid,  the  trader  is  able  to  freely  dispose  of  the  goods  without  any  further 

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146 

 MS A Company A — supplier MS B Company B — 1st purchaser MS C Company C — customer Intrastat: dispatch to MS C Goods Intrastat: arrival from MS A VIES: intra-EU supply to MS C + ▲ Invoice VAT: intra-EU acquisition from MS B VIES: intra-EU supply to MS B   Invoice  
 
 
 
Particular trade flows  5 

customs  supervision  or  the  goods  can  be  stored  in  one  Member  State  before  being  delivered  to  a 
purchaser in another Member State. 
727. However,  exports  are  influenced  as  well.  In  exceptional  cases,  the  exporters  are  able  to  carry  out 
customs clearance, not in the actual Member State of export, but in the Member State of exit, i.e. in the 
Member  State  from  which  the  goods  are  exported  from  the  customs  territory  of  the  EU.  The  share  of 
quasi-transit in exports is increasing and is affecting Member States situated at the border of the EU. 
728. Quasi-imports. A non-resident imports goods from non-member countries, clears them for import 
in a Member State and dispatches them to another Member State. 
Figure 44: Quasi-import 

729. Movement of goods between a non-member country and a Member State of final destination will be 
divided into two trade flows — one reported within extra-EU trade (import of goods from outside of EU 
will be declared on customs declaration) and subsequent dispatch of goods should be reported on Intrastat 
declaration.  The  customs  clearance  usually  takes  place  in  a  first  Member  State  located  at  the  external 
frontier of the European Union. Very often it happens in such countries as Belgium and the Netherlands 
which have important ports for transhipment of goods, e.g. Rotterdam, Antwerp. 
730. In order to clear the goods for Customs the owner of the goods (trader/importer) does not need to be 
established  in  the  Member  State  where  the  customs  declaration  is  lodged.  It  is  enough  to  be  VAT 
registered  in  that  Member  State  or  to  appoint  tax  representative,  who  will  be  in  charge  of  clearing  the 
goods  in  Customs  and  will  fulfil  VAT  obligations.  The  entity,  which  handles  customs  procedures  and 
pays  import  duties,  does  not  become  the  owner  of  the  goods.  It  may  be  a  local  tax  representative  or 
accountant dealing with Customs and providing services to non-residents. 
731. Quasi-exports. A trader transports the goods from one Member State to the border Member State 
where customs clearance for export takes place. 

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 MS A MS B Import customs declaration is lodged Intra-EU flow Non-member country Extra-EU flow Quasi import MS B Normal transit Normal import MS A Import customs declaration is lodged Non-member country Extra-EU flow  
 
 
 
 
 
Figure 45: Quasi-export 

Particular trade flows  5 

732. To  export  the  goods  outside  the  EU,  from  the  administrative  point  of  view,  there  are  even  less 
administrative procedures to follow for traders than when importing the goods. In order to lodge customs 
declarations  in  the  exit  Member  State,  the  non-resident  trader  does  not  need  to  be  registered  in  that 
Member State and does not need to appoint a tax representative. 
733.  According to the Community Customs Code implementing provisions, with some minor exceptions, 
the  customs  declaration  can  be  lodged  at  one  of  the  following  customs  offices:  the  customs  office 
responsible  for  the  place  where  the  goods  were  or  are  to  be  presented  to  Customs;  the  customs  office 
responsible for supervising the place where the exporter is established; or where the goods are packed or 
loaded for export shipment. 
734. Consequences  for  data  collection.  The  figures  above  show  that  the  place  where  the  customs 
declaration is lodged is crucial for the reporting of trade in intra-EU and extra-EU trade statistics in case 
of quasi-transit: 

 

 

If the customs clearance is done in border Member State B, import and dispatch (or exports and 
arrival)  declarations  shall  be  provided  in  Member  State  B.  In  Member  State  A  —  an  Intrastat 
arrival (or dispatch) declaration should be provided as well, recording partner Member State B; 
If the customs clearance is done in Member State A, the goods are in transit in Member State B 
and no reporting is done in Member State B. Member State A reports an import or export within 
extra-EU trade statistics only. 

735. Member  States  are  often  facing  difficulties  in  collecting  intra-EU  trade  flows  in  the  intermediate 
Member State after the goods have been cleared for free circulation by Customs. The customs declaration 
in the intermediate Member State can be provided by a tax or customs representative or a carrier of goods. 
However these representatives are not always aware of their Intrastat obligations. Furthermore, the PSI in 
the Member State of destination or actual export might assume that he has already fulfilled his reporting 
obligations after the customs clearance was done in the partner Member State. If one of the two fails to 
report, discrepancies will arise in the statistical records. Therefore NSAs are encouraged to inform the 
PSIs about these reporting obligations. 
736. Part of the trade related to quasi-imports can be identified via customs procedure codes 42 and 63. 
These  procedures  were  introduced  by  Customs  in  order  to  relieve  the  trader  from  paying  VAT  in  the 
country of customs clearance, because the goods are destined for another Member State and VAT has to 
be paid in the country of final consumption. All goods declared for these procedures should be declared in 
parallel as dispatches on the Intrastat declaration and on the VIES declaration as well. Therefore NSAs 
are encouraged to use customs information at least for completeness checks. 
737. Problems  related  to  quasi-exports.  The  trader  in  dispatching  Member  State  does  not  need  to 
provide VAT return and VIES declaration to the tax administration about the dispatch to Member State 
where the export customs declaration is lodged as there is no trade transaction between these two Member 
States.  Therefore  NSA  and  Customs  in  dispatching  Member  State  have  no  information  available  about 
dispatches, nor about exports of goods. 

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 MS A  MS B Export customs declaration is lodged Intra-EU flow Non-member country Extra-EU flow Quasi export MS B Normal transit Normal export MS A Export customs declaration is lodged  Non-member country Extra-EU flow  
 
 
 
Particular trade flows  5 

738. Although  this  has  a  neutral  effect  from  the  EU  exports  perspective,  the  quasi-exports  lead  to 
distortion of individual Member States' trade statistics: 

  Member State of clearance will record excessive exports of goods having no economic relation 

to this country; 

  The trade balance of this Member State is distorted, as only export is recorded, without recording 

incoming flow; 

  The  coverage  of  exports  in  dispatching  Member  State  will  be  undervalued  as  no  export  or 

dispatches will be recorded in this Member State. 

739. In order to avoid an imbalance of the national trade figures in arrivals and exports in  the Member 
State  of  clearance,  NSAs  are  encouraged  to  use  data  from  the  customs  declarations  for  compiling  the 
missing Intrastat arrivals. Whenever the information provided in the customs declaration is sufficient to 
derive  an  adequate  arrival  record  in  Intrastat,  it  is  recommended  that  NSAs  do  not  collect  this 
information from traders or from declarants in order not to increase the reporting burden. 
740. The Member State should take all possible measures in order to avoid double counting and capture 
the correct information for the arrivals. The cooperation among Member States is necessary in order to 
provide information from Member State B to Member State A. 
741. Whenever  the  export  declaration  does  not  contain  information  on  the  Member  State  of  actual 
export,  optional  SAD-Box 15a,  the  Member  State  of  dispatch  should  be  derived  from  SAD-box 2, 
otherwise the simplified country code QV should be used. 
742. Impact  on  statistical  data.  The  phenomenon  of  quasi-transit  makes  the  interpretation  of  EU 
statistics complicated. The partner country allocation might be distorted and, in particular, asymmetries 
between non-member countries and individual EU Member States appear. Several Member States exclude 
quasi-transit from their national statistics because there is no change of ownership between a resident in 
the  reporting  Member  State  and  a  non-resident.  Including  quasi-transit  in  ITGS  complicates  the 
comparability  with  the  Rest  of  the  World  account  in  National  Accounts  and  Balance  of  Payments 
Statistics  of  a  Member  State.  However,  EU  legislation  requires  quasi-transit  related  to  the  reporting 
Member State to be included in extra-EU trade statistics to ensure correct coverage of imports and exports 
at EU level. Even if the border Member State can identify quasi-transit in its data, the Member State of 
destination or actual export is unable to adjust the data accordingly. 
743. Moreover, because of quasi-transit, the value of trade flows is distorted, when goods enter Member 
State of clearance and are declared as imports for customs purposes at values that differ from those that 
are declared when the goods leave the same Member State. The price difference can lead to significant 
statistical discrepancies and distortions in import and export data. 
744. Statistical discrepancies bring problems for balance of payments statistics for which it is important 
to identify and exclude the goods which do not change ownership to the resident of the reporting country. 
This is the case in both normal transit of goods and quasi-transit. However in ITGS statistics it is much 
easier  to  identify  and  properly  record  (exclude)  transit  trade  than  it  is  to  properly  handle  quasi-transit 
trade. The example below describes the case of quasi-imports and related valuation problems. 

Example 74  
A  global  company  A  in  sports  articles,  with  its  base  in  the  United  States,  commissions  a  Chinese  company  B  to 
manufacture sports shoes with a brand name of A for the European market. The shoes are sold by B for EUR 1 million 
to a subsidiary  C of A in Hong  Kong,  which  resells them for the inter-company price of EUR 4 million (including profit 
margin and costs for e.g. research and development) to the European sales company D in Belgium, also a subsidiary of 
A. 
The shoes, however, are shipped from Hong Kong  to a logistic service provider E in the Netherlands, where the shoes 
are stored in a customs warehouse. After a while the shoes are sold by D to wholesale company F in Germany for the 
price of EUR 5 million. Before the shoes are dispatched to Germany F lodges an import declaration in the Netherlands 
on behalf of D. 
The customs value is EUR 1 million based on the ‘first sale for export’-rule, saying that the first transaction in the supply 
chain resulting in the export may be used for the calculation of the customs value for the import following the export. 
For VAT purposes D is represented in the Netherlands by E. Because the exemption threshold is exceeded, E has to 
report  to  Statistics  Netherlands  the  dispatch  to  Germany  according  to  the  taxable  amount  on  the  VATreturn,  which  is 
EUR 5 million. The import of EUR 1 million and the dispatch of EUR 5 million are classified as quasi-transit by Statistics 
Netherlands.  The  difference,  EUR  4  million,  is  not  a  value  added  of  the  Dutch  economy.  Only  a  small  part  of  it 
represents the value added by the logistics service provider E. 

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Particular trade flows  5 

Figure 46: Example of a quasi-import transaction 

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150 

 Netherlands Customs  warehouse USA Germany Company A — ordering party Goods of value € 5 million China Company B — manufacturer Hong Kong Company C — subsidiary of A € 1 million Company F —wholesaler Belgium Company D —subsidiary of A € 5 million € 4 million Goods Company E —  logistic provider Company D represented by E Goods of value € 1 million  
 
 
 
 
Thresholds within Intrastat system  6 

6  Thresholds within the Intrastat system 

Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 10 

Commission Regulation (EC) No 1982/2004, Article 8(2), Article 13 

745. In order to satisfy users’ needs for the statistical information without imposing excessive burdens on 
economic operators, Member States shall define each year  the thresholds expressed in annual values of 
intra-EU  trade,  below  which  parties  are  exempted  from  providing  any  Intrastat  information  or  may 
provide simplified information. 
746. The thresholds shall be defined by each Member State, separately for arrivals and dispatches. 
747. The Intrastat system applies the exemption thresholds. The EU legislation enables Member States to 
define simplification thresholds. 
Figure 47: Coverage levels for Member States with simplification thresholds 

748. Apart  from  the  mandatory  collection  of  specific  data  Member  States  may  also  collect  additional 
information,  such  as  the  identification  of  the  goods  at  a  more  detailed  level;  the  country  of  origin  (for 
arrival); the region of origin (for dispatch), the region of destination (for arrival); the delivery terms; the 
mode of transport; or the statistical procedure. While the collection of this information is optional at the 
EU level, it may be mandatory by legal decision at national level. 
749. In  order  not  to  burden  all  PSIs  NSAs  are  encouraged  to  define  thresholds  (further  referred  to  as 
'optional  variables  threshold')  only  above  which  PSIs  are  obliged  to  provide  additional  information  to 
those specified in Article 9(1) of Regulation (EC) No 638/2004. The application of this threshold depends 
on the rules decided by the Member State. 
750. Member States may collect the statistical value of the goods and thus the collection of the statistical 
value from companies remains optional. However NSAs are required to transmit data on the statistical 
value to Eurostat. 

6.1  Exemption threshold 
751. Definition. The exemption threshold defines the value above which the parties (taxable persons) are 
obliged to provide Intrastat information. Member States are required to determine this threshold each 
year.  The  threshold  is  expressed  in  annual  values  and  it  is  set  in  order  to  ensure  that  the  information 
provided is such that at least 97% of the total dispatches and at least 93% of the total arrivals, expressed 
in value, of the relevant Member State’s taxable persons is covered. 

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151 

 No Intrastat declaration Simplified declaration Exemption threshold 87% Arrival 91% Dispatch 7% A 3% D Total trade Estimates All prescribed information is provided Detailed statistical declaration At least goods, partner MS and value is provided 6% Arrival 6% Dispatch Simplification threshold  
 
 
 
Thresholds within Intrastat system  6 

752. Companies  which  do  not  achieve  this  threshold  for  arrivals  or  dispatches  do  not  have  to  compile 
Intrastat declarations. 
753. Although  the  only  legal  requirement  for  defining  the  exemption  thresholds  is  the  collection  of  at 
least 97% of the total dispatches and at least 93% of the total arrivals, it is recommended that NSAs set 
the  exemption  threshold  in  line  with  certain  quality  requirements.  In  particular,  Member  States  should 
examine  whether  the  exemption  of  the  PSIs  below  the  threshold  will  lead  to  a  considerable  lack  of 
information or to biased information as regards the flow, the trade with certain partner Member States and 
certain commodities. 
754. It  is  recommended  that  NSAs  determine  the  threshold  in  such  a  way  that  the  largest  number  of 
traders  is  exempted  from  providing  information  to  the  Intrastat  system,  to  reduce  burden,  and  by 
simultaneously  keeping  the  quality  of  the  collected  information.  It  might  be  useful  to  examine  various 
scenarios for setting the level of the threshold before deciding which particular value should be set for the 
following year. 

6.1.1  How to calculate the exemption threshold 
755. Total  trade.  For  the  determination  of  total  trade  it  is  recommended  that  NSAs  calculate 
cumulative total value based on the most recent data available at the time of calculation of thresholds over 
a period of at least 12 months taking into account: 

 
 

Intrastat information submitted by PSI; 
Intrastat  information  estimated  by  the  NSA  (e.g.  estimates  for  non-response,  partial  response, 
etc.); 

  any other information acquired from administrative data sources (including customs declaration), 

which is included in total results of Intrastat; 
the VAT data for below threshold trade. 

 

756. For the determination of the level of the exemption threshold, it is recommended that NSAs use 
the following procedure: 

  Calculate the value of trade by each economic operator, over the period of the latest 12 months; 
  Calculate the total amount of trade by flow; 
  Sort the list of economic operators by decreasing value of trade, for each flow; 
  Calculate sequentially the cumulative value, for each flow; 
  Calculate  the  value  of  the  coverage  rate  for  each  flow:  97%  of  the  total  amount  of  trade  for 

 

dispatches and 93% of the total amount of trade for arrivals; 
Identify the threshold value when the cumulative value reaches the value of the coverage rate for 
each flow; 

  Examine  various  scenarios  close  to  the  coverage  rate  to  determine  the  threshold  value  which 

most limits the reporting burden by ensuring that quality requirements are met. 

757. NSAs  are  encouraged  not  to  calculate  the  exemption  threshold  exactly  to  the  point,  as  a  ‘safety 
margin’ should be left for the remaining non-response and the fluctuations in the economic activity. 
758. A trader is required to provide an Intrastat declaration if: 

or if 

 

 

the trade with other Member States exceeded the threshold during the previous year 

the trade with other Member States exceeds the threshold during the year of application from the 
month in which the threshold is exceeded. 

759. To identify economic operators which become responsible for providing information in the current 
year a permanent and close monitoring of VAT data provided by fiscal authorities has to be ensured. 
760. The threshold is set annually and comes into force on 1 January each year. NSAs are required to 
send the information on the thresholds applied by them to Eurostat no later than 31 October of the year 
preceding the year to which they apply. 
761. The  EU  legislation  asks  for  the  transmission  of  data  on  total  trade  to  the  Commission  (Eurostat). 
Therefore,  NSAs  are  required  to  transmit  estimates  of  trade  below  the exemption  threshold  at  least  at 

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Thresholds within Intrastat system  6 

chapter  level  and by  partner country.  NSAs  should  inform  Eurostat  on  their  estimation  methods  with  a 
view to exchanging the best practices. 

6.2  Simplification threshold 
762. Definition. The simplification threshold defines the value below which the parties (taxable persons) 
may be exempted from providing part of the Intrastat information. The variables to be exempted and the 
application of this threshold depend on the decision of the Member State. 
763. Member  States  are  required  to  apply  simplification  thresholds  for  at  most  6%  of  the  smallest 
(expressed  in value)  companies  which  are required  to  provide  Intrastat  information. This  simplification 
measure is then applied only to critical small enterprises, which will be the enterprises having a level of 
arrivals  or  dispatches  between  the  exemption  and  simplification  threshold,  and  its  major  purpose  is  to 
reduce burden on enterprises. 
764. According  to  the  decision  of  the  Member  State,  companies  may  benefit  from  the  following 
simplifications: 

  exemption  from  providing  information  about  the  quantity  of  the  goods  (net  mass  and/or 

supplementary unit); 

  exemption from providing information about the nature of transaction; 
  possibility  of  reporting  at  least  10  of  the  detailed  relevant  subheadings  of  the  Combined 
Nomenclature, that are the most used in terms of value, and regrouping the other products in a 
simplified commodity code (9950 00 00). 

765. However the companies included in this simplification threshold are obliged to report: 

 

 
 

the commodity code (at least for the 10 largest commodity codes, if the Member State adopted 
this simplification measure, and regrouping the others in code 9950 00 00); 
the partner Member State code; 
the value of goods (taxable amount). 

766. For the determination of the level of the simplification threshold it is recommended that NSAs use 
the following procedure: 

  Use  the  list  of  economic  operators  identified  as  having  transactions  above  the  exemption 
threshold (previously calculated as explained in 6.2), with the respective value of trade for each 
flow over the period (previous 12 months); 

  Calculate the total amount of trade by flow, for the enterprises in that list; 
  Calculate 6% of the total amount of trade for each flow; 
  Sort the list of economic operators by increasing value of trade, for each flow; 
  Calculate sequentially the cumulative value, for each flow; 
 

Identify the threshold value when the cumulative value reaches the value of the 6% of the total 
amount of trade, for each flow; 

  Examine  various  scenarios  close  to  the  coverage  rate  to  determine  the  threshold  value  which 

most limits the reporting burden by ensuring that quality requirements are met. 

767. If a company below the simplification threshold achieves a trade value above that threshold during 
the year, it should stop submitting the simplified declaration and start to provide complete Intrastat data 
(detailed statistical declaration) from the month the simplification threshold is exceeded. 
768. An assessment of the quality impact when implementing a simplification threshold should be carried 
out. 

Individual transaction threshold 

6.3 
769. PSIs have reporting obligations for each trade transaction, even when these are of very low value. 
However,  Member  States  may  under  certain  conditions,  which  meet  quality  requirements,  simplify  the 
information to be provided for the small individual transactions. 
770. Depending on Member States, it could be allowed that a PSI may group together transactions with 
individual values less than EUR 200, reporting only: 

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Thresholds within Intrastat system  6 

  commodity code 9950 00 00; 
  partner country; 
  value of goods. 

771. However,  the  simplified  reporting  is  only  permitted  when  individual  transactions  are  carried  out, 
with each of them having a value less than EUR 200. The artificial division of a transaction into shares 
below EUR 200 is not allowed in this context. 
772. With  a  view  to  lightening  the  reporting  burden  of  the  trade  operators,  NSAs  are  encouraged  to 
provide  PSIs  with  a  possibility  of  simplified  reporting  on  small  individual  transactions.  However, 
Member  States  must  ensure  that  the  simplification  is  not  abused  and  that  the  quality  of  the  statistical 
results is not damaged as a result. 

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Thresholds applicable in extra-EU trade  7 

7  Thresholds applicable in extra-EU trade 

7.1  Statistical threshold applied by NSA 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 3(4) 

Commission Regulation (EU) No 92/2010, Article 2(4) 

Commission Regulation (EU) No 113/2010, Annex I, point (j) 

773. Statistical  threshold  —  definition.  The  extra-EU  trade  statistics  regulatory  framework  has  not 
explicitly designated a general ‘statistical threshold’. It is only in relation to ‘goods declared orally to 
customs’ that a ‘statistical threshold of EUR 1 000 in value or 1 000 kg in net mass’ is mentioned. 
774. Statistical threshold — exclusion of trade. This statistical threshold was introduced with a view 
to  the  exclusion  of  trade  (see  paragraph  100).  The  goods  declared  orally  to  Customs  are 
excluded if: 
the goods are for non-commercial purposes, without limitation in value or quantity; 
the goods are for commercial purposes up to a value of EUR 1 000. Where the value is below 
EUR 1 000 but the net mass is above 1 000 kg the exclusion does not apply. 

 
 

Example 75  
A French traveller returns back home with a video camera he bought during his holiday in Japan: 
—  the  value  is  EUR 1 500,  the  camera  is  for  private  purposes  and  the  customs  declaration  is  made  orally 

excluded from extra-EU trade statistics 

—  the value is 900 Euro, the camera is for commercial purposes. 
  — 

the customs declaration is made orally    

excluded from extra-EU trade statistics 

  — 

the customs declaration is made in written/electronic form   

included in extra-EU trade statistics 

A stonemason imports in his own car pieces of rock he found in a quarry for use in his business. The estimated value 
of  the  rocks  is  EUR 200,  their  actual  weight  1 600  kg.  The  customs  declaration  is  made  orally.  Since  the  exclusion 
included in extra-EU trade statistics (N.B. Customs would have to supply to the NSA the 
does not apply, therefor
relevant statistical data). 

775. Statistical  threshold  –—  inclusion  of  trade.  However,  whenever  written  or  electronic  customs 
declarations are available for trade below the threshold, the exclusion provisions do not apply and the 
respective trade is to be included in trade statistics. 
776. In  order  to  allow  NSAs  to  reduce  the  compilation  workload  linked  with  the  validation  and 
processing  of  the  numerous  records  when  treating  customs  declarations  (data  sources)  or  any  other 
transactions below the statistical threshold, this trade may be included in the compilation process with 
less  detailed  information  (data  elements),  however,  including  the  trade  at  least  in  total  trade.  This 
means  in  practice  that  NSAs  when  transmitting  data  to  Eurostat  may  aggregated  the  customs  records 
whose statistical value is below EUR 1 000 under code 9969 99 99 indicating code 3 in the section 2 
‘Threshold indicator’ according to Doc MET 400. 
777. NSAs are encouraged to apply the simplification only where it would not lead to negative effects 
on the availability of data at detailed level. The statistical value where the ‘value of the goods’ is not 
available should be used as criterion for application of the simplification. 

Example 76  
A NSA receives a full and complete customs declaration, indicating the statistical value of 950 Euro and the net mass 
of 5 kg. The NSA shall include the transaction in the compilation process 
  a) either with all individual details 
  b) or only at TOTAL trade level 

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Thresholds applicable in extra-EU trade  7 

7.2  Thresholds applied by Customs 
778. There are two thresholds applied by national customs authorities which cross refer to the statistical 
threshold: 

Imports and exports of goods of a commercial nature 

Commission Regulation (EEC) No 2454/93, Article 225(b) and Article 226(b) 
779. Customs  may  require  only  an  oral  customs  declaration  for  goods  of  a  commercial  nature(1) 
provided, inter alia, the total value per consignment (and not per individual customs declaration) does 
not exceed the statistical threshold. 

Postal consignments 

Commission Regulation (EEC) No 2454/93, Articles 237 and 238 

780. The  term  ‘postal  consignments’  relates  only  to  parcel  post  conveyed  by  postal  authorities  or 
‘postal  operators  authorised  by  a  Member  State  to  provide  services  governed  by  the  Universal  Postal 
Union Convention’(2), thus excluding transport of parcels by commercial express companies for which 
the normal procedural provisions apply. 
781. For goods imported or exported through national postal services, and covered by simplified postal 
declarations  (customs  form  CN22  or  CN23),  no  customs  declaration  needs  to  be  provided  (subject  to 
certain conditions) for consignments containing goods for commercial purposes of an aggregate  value 
up to the statistical threshold.  
782. The customs form CN22 or CN23 itself is not a customs declaration in the sense of Community 
customs provisions. Postal consignments accompanied by CN22/CN23 declaration are only considered 
to have been declared at their time of presentation according to Article 237 of Commission Regulation 
(EEC) No 2454/1993. As there is no customs declaration, this trade is not included in the statistics. 
783. However a formal customs declaration would need to be lodged for the postal consignments above 
the value referred to in Article 238. Member States may apply a higher threshold under Article 238. So 
Customs are encouraged to actively involve NSAs in the process of fixing such a threshold.  

(1)  ‘Goods  of  a  commercial  nature’  in  the  sense  of  customs  provisions  are  in  general  goods  sent  from  ‘business  to  business’  or  ‘business  to 

private’. 

(2)  Definition as in the Draft IP to the Modernised Customs Code - website: http://www.upu.int/ 

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Quality  8 

8  Quality 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 13 

Commission Regulation (EC) No 1982/2004, Article 26 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 9 

Commission Regulation (EU) No 92/2010, Article 3 

784. As mentioned in the Introduction to this Guide, ITGS serve the needs of different users, including 
governments,  businesses,  academic  communities  and  researchers  and  the  general  public.  They  are  an 
essential  source  of  information  for  Balance  of  Payments  statistics,  National  Accounts  and  short-term 
economic studies. With growing interest in ITGS the production of timely and high quality data is of 
primary importance for the producers of statistics. 
785. Harmonisation of compilation practices among Member States is of paramount importance. Given 
the  cross-cutting  nature  in  both  the  collection  and  legislation  of  ITGS,  a  Quality  Handbook  is  being 
developed  which  documents  the  quality  framework  (Volume I),  the  quality  items  and  requirements 
(Volume  II),  the  methods  and  practices  applied  in  Member  States  and  results  of  the  annual  reporting 
exercises (Volume IV). 
786. The data quality monitoring system as it is described in The Quality Handbook Volume I includes, 
besides  the  national  quality  report,  the  annual  and  monthly  intra-EU  asymmetries  reports  and  the 
monthly  Mirror  Outlier  Detection  reports.  The  annual  asymmetries  report  is  a  basis  for  the 
reconciliation exercise enabling Member States to exchange information in order to reduce asymmetries 
for  specific  codes  of  Combine  Nomenclature.  The  Mirror  Outlier  Detection  reports  provide  Member 
States with more information on specific outliers which they can investigate. 
787. The  Quality  Handbook  Volume  II  is  based  on  the  document  Doc  MET  1000;  gives  detailed 
information on each quality item to be reported by the Member States in the framework of the annual 
assessment procedure, including its definition and objective.  
788. The  overall  objective  is  to  provide  robust,  reliable,  relevant  and  timely  ITGS  while  easing  the 
reporting  burden  on  traders.  Quality  and  standardisation  of  methodologies  are  key  to  reaching  this 
objective.  
789. Moreover, in order to accomplish this objective, the primary data collected from/submitted by the 
operators should meet the quality requirements. Therefore it is recommended that NSAs instruct trade 
operators on how to correctly fill in Intrastat declarations, provide them with the necessary manuals and 
maintain a helpdesk.  
790. NSAs  are  required  to  provide  completed  quality  questionnaire  annually.  Using  information 
transmitted  by  Member  States  in  their  quality  report  as  well  as  information  available  at  Eurostat  (for 
instance on timeliness of data or impact of confidential trade), a summary quality report is published on 
Eurostat’s website at the end of the year. In addition,  Eurostat prepares an assessment report for each 
Member State. 

8.1  Asymmetries 
791. For  trade  in  goods  statistics,  comparability  across  countries  is  a  more  visible  quality  dimension 
than for most other statistical domains. Once asymmetries are identified and measured through a mirror 
analysis,  further  analytical  work  should  be  initiated  to  identify  their  causes.  Some  of  the  reasons  are 
easy to pinpoint and correct while for some cases it may be harder. In any cases, data corrections and/or 
changes  in  methodologies  and  practices  require  the  Member  States  involved  to  perform  the  analysis 
jointly, to agree on the asymmetry causes and on the corrections to be done in their respective data. This 
is called a ‘reconciliation exercise’. 
792. Within the limit of available human resources,  it is recommended that NSAs regularly monitor 
the  asymmetries  related  to  the  main  partner  countries  and  major/key  products  and  react  as  quickly as 

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possible to unexpectedly high or new asymmetries by checking the accuracy and completeness of the 
available national statistical data sources. 
793. Moreover  NSAs  are  encouraged,  within  the  limit  of  available  human  resources,  to  periodically 
conduct  bilateral  or  multilateral  reconciliation  exercises  for  major/key  products  and  to  take  any 
measures  to  ensure  the  success  of  such  exercises.  In  particular,  this  means  that  any  necessary 
information — data and metadata — should be made available to the partner(s) within the legal limits.  

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9  Confidentiality 

9.1  The principle of passive confidentiality 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 11 

Commission Regulation (EC) No 1982/2004, Article 25(7) 

Extra-EU trade 
Regulation  (EC)  No  471/2009  of  the  European  Parliament  and  of  the  Council,  Article  10(1),  second 
paragraph 

Commission Regulation (EU) No 92/2010, Article 2(5) 

794. Individual company data shall never be published, distributed or used by NSAs in any way other 
than  for  pure  statistical  needs.  Individual  company  or  personal  data  are  always  confidential,  highly 
protected and never transmitted by the NSA to other public administrations or to other users. 
795. However,  even  aggregated  data,  indirectly,  could  reveal  individual  data.  When  only  one  or  two 
companies are responsible for the totality of trade for a certain product or with a particular country, the 
published information could reveal individual trader’s data. Therefore, the data shall be considered as 
confidential when they allow a natural or legal person to be directly or indirectly identified. 
796. There  are  two  types  of  confidentiality  applied  in  statistics:  active  and  passive.  Active 
confidentiality is applied for the majority of statistical areas and its principles of application are defined 
in  Regulation  (EC)  No  223/2009  of  the  European  Parliament  and  of  the  Council.  Applying  active 
confidentiality the National Statistical Authorities have to take the initiative to suppress data, which 
could  indirectly  reveal  the  data  of  an  individual  company.  NSAs  are  required  to  apply  active 
confidentiality  when  compiling  and  transmitting  intra-EU  and  extra-EU  trade  statistics  by  business 
characteristics. 
797. Passive confidentiality means that the NSA will suppress the disseminated data only on request of 
the PSI whose individual data might be indirectly revealed from published results. NSAs are required 
to apply passive confidentiality when compiling and transmitting monthly detailed intra-EU and extra-
EU trade statistics. 
798. Application  of  active  confidentiality  has  negative  consequences  on  the  accessibility  of  the 
collected  data  to  the  users.  One  difficulty  in  applying  it  is  over-emphasis  of  the  actual  disclosure 
problem,  i.e.  some  of  the  data  providers  would  have  no  objections  if  the  data  which  might  indirectly 
reveal  their  economic  activities  were  to  be  published.  On  the  other  hand,  application  of  active 
confidentiality might be counterproductive to the costs of data collection: i.e. if more than 60 or 70% of 
detailed  data  at  CN8/partner  level  cannot  be  disseminated  because  of  the  application  of  active 
confidentiality, the needs and benefits of such information must be reassessed. 
799. In ITGS the passive confidentiality principle is applied exactly for the reason that application of 
active confidentiality would decrease the volume of published information so dramatically that it would 
not be worthwhile to collect such detailed statistics without being able to disseminate them. 
800. Although application of passive confidentiality allows much more information to be published for 
users,  it  affects  the  quality  of  trade  statistics  as  regards  accuracy  (the  total  EU  trade  for  detailed 
products  may  be  biased),  clarity  (the  lack  of  information  for  users)  and  comparability  (increases 
asymmetries in Member States' data). 
801. The  application  of  passive  confidentiality  could  be  problematic  if  national  legislation  imposes 
active  confidentiality  in  all  domains  of  statistics  (including  ITGS).  However,  the  primacy  of  EU  law 
over  national  law  means  that  the  provisions  of  EU  regulations  are  applicable  in  the  Member  States 
without the need to adopt national implementation provisions. If national provisions do not comply with 
EU law, the provisions of EU law take precedence over the conflicting national provisions. 

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9.2  Application of passive confidentiality in practice 
802. When  a  PSI  addresses  a  written  request  to  its  national  NSA  for  application  of  confidentiality 
provisions for trade statistics in certain products or partner countries, the NSA is obliged to investigate 
whether  the  request  from  the  company  is  justified.  If  the  analysis  of  data  reveals  that  the  trader  is 
dominant  and  complies  with  the  nationally  established  criteria  defining  confidentiality,  the  trader  is 
informed that the information about the requested product or partner country will not be made public to 
the users. 
803. It is recommended that NSAs grant confidentiality only for a limited time (e.g. the request has to 
be  renewed  periodically/annually)  and  only  for  as  few  data  elements  as  possible  (value  or  quantity, 
product  or  partner).  In  addition,  it  is  recommended  that  NSAs  establish  national  instructions  which 
clarify the following aspects: 

  Confidentiality application form and procedures; 
  Standardised decision making process by the NSA applicable for all statistical areas (e.g. rules 
for confidentiality analysis and criteria for granting, deadlines for the approval or refusal); 
  Setting  time  limits  to  keep  the  data  confidential  (historical  data  are  much  less  sensitive  for 

companies). 

804. Two types of data can be made confidential in connection with a Member State’s statistics on trade 
between Member States: the product code and the partner country code in relation to value or quantity. 
NSAs are required to supressed confidential data in such way that they may be published at least at 
chapter level of the CN provided confidentiality is thereby ensured. So when suppressing data due to 
confidentiality, NSAs should report any information deemed confidential (suppressed) in full detail at 
the  next  higher  level  of  commodity  (HS6,  4  or  2  digit  as  opposed  to  CN  digit)  and/or  partner 
aggregation that adequately protects confidentiality. 
805. Product  confidentiality.  The  information  about  a  product  may  be  regarded  as  confidential 
because  it  is  considered  commercially  sensitive  either  for  its  value,  its  quantity  or  the  ratio  of  both 
(≈price).  Therefore  the  information  on  the  product  code  may  be  suppressed.  Suppression  might  be 
applied  when  only  a  few  companies  (e.g.  ≤3)  together  or  separately,  cover  more  than  a  certain 
percentage  (e.g.  70%  or  80%)  of  the  total  trade  for  this  commodity.  Suppression  can  also  be  applied 
when a few companies, together or separately, cover more than a certain percentage of the total trade for 
a commodity/country combination. In the latter case, only the product code should be suppressed and 
not the country code. 
806. It  is  recommended  that  NSAs  suppress  a  product  in  such  a  way  that  as  much  information  as 
possible  on  the  commodity  is  published  whilst  still  guaranteeing  the  confidentiality  of  the  PSI. 
Therefore a code containing at least an indication of the CN chapter to which it belongs should be used 
(e.g. 27 + blanks for products of CN chapter 27). In exceptional cases, the special code 9990 00 00 may 
be used if it is possible to deduce the suppressed commodity trade by deducting from totals the sum of 
the data on the published codes in that chapter. Under no circumstances should another real CN8 code 
be used to camouflage another commodity. 
807. Partner confidentiality. A company may consider the partner country as commercially sensitive, 
therefore, national authorities must examine whether a ‘secret’ country code shall be used. This usually 
involves using either code QY (intra-EU trade) or code QZ (extra-EU trade). However, partner country 
confidentiality should be applied exceptionally because it is rare that one or only a few companies cover 
most of the trade with a single country. 
808. NSAs  are  encouraged  to  define  the  rules  used  in  the  evaluation  of  a  request  for  confidentiality 
considering: 

  a  threshold  for  the  number  of  PSIs  trading  in  a  certain  product,  partner  or  product-partner 

combinations; 

  a threshold for the percentage of trade declared by the dominant PSI; 
 

the period over which data shall be examined (e.g. whether data of the previous year might be 
used for the decision on whether confidentiality should be granted). 

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9.3  Transmission of confidential data to Eurostat 
809. NSAs  are  required  to  transmit  to  Eurostat  data  which  are  confidential.  In  addition,  they  must 
transmit  the  designated  confidential  code  according  to  the  transmission  standards  specified  in 
Doc MET 400. NSAs must indicate whether a record transmitted to Eurostat is confidential or not. The 
meaning of confidentiality flags is defined in section 17 of Doc MET 400: 

0:  Confidentiality is not applied 
1:  Access to confidential data restricted to Eurostat 
2:  Access restricted to Eurostat and other services within the Commission. NSAs are encouraged 

to use confidentiality flag '2' instead of '1' whenever possible. 

810. NSAs must indicate whether product and/or partner confidentiality should be given: 

 

 

If  the  product  is  confidential,  the  real  product  code  must  be  given  in  section  5  and  the 
confidential codes in section 18 (HS6-4-2 code) and in section 19 (SITC3-2-1 code); 
If the partner country is confidential, the real country code must be given in section 6 and the 
disguised code (1 or 2) in section 20. 

811. NSAs have to specify what indicator should be disguised: 

 

 

 

the value (the real value must be given in section 24 and confidentiality flag 1 in section  21) 
and/or 
the net mass (the real net mass must be given in section 25 and confidentiality flag 1 in section 
22) and/or 
the  supplementary  units  (the  real  supplementary  unit  must  be  given  in  section  26  and 
confidentiality flag 1 in section 23). 

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10  Data transmission 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 12 

Commission Regulation (EC) No 1982/2004, Article 25 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 8 

Commission Regulation (EU) No 92/2010, Articles 2(3) and 2(5) 

Commission Regulation (EU) No 113/2010, Article 26 

10.1  Doc MET 400 
812. National  statistical  authorities  have  to  transmit  detailed  and  aggregated  results  of  intra-EU  and 
extra-EU  trade  statistics  to  Eurostat  on  a  monthly  basis.  Once  data  have  been  collected,  checked  and 
processed by the Member States, they must be forwarded to Eurostat in an electronic form, which meets 
precise  format  and  technical  specifications  according  to  rules  specified  in  the  current  valid  working 
paper Doc  MET 400. 
813. These  rules  are  not  part  of  the  Acquis  Communautaire  but  a  so  called  ‘gentlemen’s  agreement’ 
between Eurostat and the Member States approved by the ITGS Steering Group. They are updated when 
necessary.  It  is recommended  that  NSAs  apply the  transmission  format  and  rules  as  defined  in Doc 
MET  400,  valid  for  a  given  reference  year  and  thus  to  implement  all  amendments  of  the  rules  in  the 
national compilation systems when agreed by the Steering Group. 

10.2  Aggregated data 
814. National statistical authorities shall transmit to Eurostat aggregated monthly results no later than 
40  calendar  days  after  the  end  of  the  reference  month.  The  file  shall  be  transmitted  by  EDAMIS 
(Stadium) using the dataset called 'COMEXT_AGG_M'. This file shall contain the aggregated intra-EU 
results and the aggregated extra-EU results together. 
815. The following information is required: 

  Reference period; 
  Reporting country; 
  Flow: exports and imports; 
  Partner zone: 

○  For  the  Euro  area's  Member  States:  'European  Union',  'Extra-EU',  'Euro  area'  and  'Extra-

euro area'; 

○  For the others: 'European Union' and 'Extra-EU' only. 

  Product : 

○  For the Euro area's Member States: 

—  Total trade for the 'European Union' and 'Euro area' partners; 
—  Total trade and a breakdown by SITC rev. 4 1-digit codes for the 'Extra-EU' and 'Extra-

Euro area' partners. 

○  For the others: 

—  Total trade for the 'European Union' partner; 
—  Total trade and a breakdown by SITC rev. 4 1-digit codes for the Extra-EU' partner. 

  Statistical  value  expressed  in  millions  of  euros  for  the  Euro  area's  Member  States  and  in 

millions of national currency units for the others. 

816. Aggregated results shall cover 100 % of the trade of the reference period and, therefore, might be: 

  either entirely or partly estimated from time series or 

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  derived from detailed results processed already within the 40 day deadline and completed by 

estimates of missing intra-EU trade. 

817. It is recommended that NSAs closely monitor that the aggregated results do not deviate from the 
totals of the final detailed results transmitted to Eurostat afterwards. 
818. Revisions on aggregated results are generally not essential, because the detailed results transmitted 
afterwards  will  be  used  for  the  succeeding  trade  data  analysis.  However,  in  exceptional  cases  when 
there  is  a  considerable  delay  in  transmitting  the  detailed  results,  revised  aggregated  results  may  be 
helpful for a better estimation of the missing information. 
819. Some national statistical authorities might wish that Eurostat would not publish the data prior to its 
publication at national level. In consequence, they might delay the transmission of aggregated data for 
this reason. However, the deadline for the transmission of aggregated data of 40 days after the end of 
the reference month (prescribed in Regulation (EC) No 638/2004) is binding in its entirety and directly 
applicable in all Member States. 
820. Therefore, NSAs are encouraged to avoid the conflict between national instructions and the legal 
EU  obligations  for  data  transmission.  Nevertheless,  Member  States  should  be  aware  of  the  fact  that 
Eurostat does not use the data under embargo until their dissemination is allowed and thus receipt date 
might be delayed. 
821. Eurostat  press  release  on  external  trade  is  published  on  average  48  days  after  the  end  of  the 
reference period and a publication calendar is accessible on the internet. NSAs are encouraged to adapt 
their publication timetable if they wish to publish trade figures earlier than Eurostat. 

10.3  Detailed data 
822. NSAs  are  required  to  transmit  the  first  detailed  intra-EU  trade  statistics  results  to  Eurostat  no 
later than 70 calendar days after the end of the reference month for intra-EU trade and no later than 40 
calendar days after the end of the reference month for extra-EU trade. In addition, when monthly results 
already transmitted to Eurostat are subject to revisions, the NSAs are required to transmit the revised 
results as well. 
823. The  format  of  intra-EU  and  extra-EU  files  is  identical  and  is  specified  in  the  Doc MET 400  in 
force.  The  files  shall  be  transmitted  by  EDAMIS  (Stadium)  to  Eurostat:  the  datasets  for  the  first 
transmission of results and of revisions are called 'COMEXT_INTRA_M' and 'COMEXT_EXTRA_M'. 
The following information is requested: 

Table 13: Sections of Doc MET 400 

Section No 

Type of trade 

Contents 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

EXTRA 

EXTRA 

EXTRA 

EXTRA 

Reference period 

Threshold indicator 

Reporting country 

Flow 

CN product or TARIC (real code) 

Partner country (real code) 

Other partner country  

MS where the customs declaration is lodged 

MS of destination/MS of actual export 

Statistical procedure  

Preference 

INTRA/EXTRA 

Mode of transport at the frontier 

EXTRA 

EXTRA 

EXTRA 

Container 

Nationality of the means of transport 

Internal mode of transport 

INTRA/EXTRA 

Nature of transaction 

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Section No 

Type of trade 

Contents 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

INTRA/EXTRA 

Confidentiality flag 

CN product (public code) 

SITC product code (public code) 

Partner countries — confidentiality flag 

Value confidentiality flag 

Quantity confidentiality flag 

Supplementary units confidentiality flag 

Statistical value 

Quantity expressed in net mass 

Quantity expressed in supplementary units 

Supplementary unit code 

SITC product code (real code) 

824. NSAs  are  required  to  ensure  that  results  cover  100  %  of  the  trade  of  the  reference  period. 
Therefore, it is essential that Member States include estimates relating to trade below the threshold and 
relating  to  the  late  or  non-response  in  intra-EU  trade  and  adjustments  on  delayed  and  incomplete 
customs declaration in extra-EU trade. 
825. The methods applied for the estimations should be described in the annual 'Quality Report'. NSAs 
are  required  to  transmit  the  records  on  estimates  to  Eurostat  with  at  least  a  breakdown  by  partner 
country and commodity code at two digit level of the CN. The estimates are flagged according to the 
threshold  indicator  (section  2  in  Doc  MET  400).  It  is  recommended  that  NSAs  compile  distinct 
estimates for trade below threshold and estimates for non/late response and keep this distinction in the 
data transmissions to Eurostat by using the threshold indicators 3 (trade below the exemption threshold) 
and  4  (non/late-response)  instead  of  indicator  8  (no  distinction  between  trade  below  threshold  and 
non/late response). 
826. When  estimates  for  missing  intra-EU  trade  are  compiled  at  CN8  level,  it  is recommended  that 
NSAs estimate and transmit to Eurostat not only the statistical value but as well the net mass and the 
supplementary quantity wherever relevant.  

10.3.1  Transmission of revised data 
827. Revised data sets sent to Eurostat shall: 

refer to individual months and 

 
  concern all the data on the INTRA/EXTRA file and 
 

replace the results previously transmitted in the INTRA/EXTRA files. 

828. NSAs are required to transmit revised results no later than the month following the availability of 
revised data. 
829. It is recommended that NSAs send the final revision for all the months of year N no later than 
October  N+1.  If  there  is  a  need  of  a  later  revision  for  one  or  more  previous  periods,  NSAs  are 
encouraged to contact Eurostat for the necessary arrangements. 
830. Revisions of data referring to previous years must be sent according to the Doc MET 400 in force 
for that year and using the codes (commodity and country) applied during the year the revision refers to. 
831. The timetable for planned revisions should be established and the public should be informed about 
the revisions when they have occurred. 

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832. It  is  recommended  that  the  NSAs  send  a  pre-announcement(1)  to  Eurostat  of  revisions  of  a 
certain  size  between  two  subsequent  data  transmissions  to  Eurostat.  The  criteria  used  to  decide  if  a 
revision is large enough to pre-announce are based on both the value of the change and the percentage 
change in the original figure. 
833. The pre-announcement of the revision should indicate: 

 
 
 
 

the main reasons for the revisions; 
the expected release date and format; 
the variables and periods covered; 
the impact on related statistics (for example Balance of Payments statistics).  

834. When a pre-announcement is necessary for revisions that occur as part of the routine monthly data 
delivery cycle it is recommended that NSAs send the pre-announcement up to 1 week before the data 
delivery itself or at the latest on the day the data is sent. For revisions that require pre-announcement 
and that are known in advance, for example those that might occur because of a change in methodology, 
it is recommended that NSAs send the pre-announcement up to 1 month before the data delivery. 
835. The pre-announcement should be sent to Member States usual contact within the data production 
team at Eurostat. 
836. The  pre-announcement  may  be  made  using  the  pre-announcement  form  provided  by  Eurostat. 
Member  States  may  choose  to  send  the  information  in  another  format  but  it  must  contain  all  the 
information required by the template. 
837. When sending the pre-announcement Member States are asked to: 

 
 

indicate in the email that a pre-announcement of a level 2 statistical revision is being made; 
indicate in the space for 'Sender comment' in EDAMIS that data being sent includes a revision 
relating to the pre-announcement previously sent and give the date of the pre-announcement e-
mail. 

838. Eurostat  publish  monthly  metadata  reports  highlighting  different  levels  of  revision,  showing  the 
value  and  percentage  change  at  the  total  level  for  community  data  published  on  the  Easy  Comext 
website.  The  reports  show  revision  between  subsequent  data  transmissions  and  between  the  first  data 
transmission and the most recent. 
839. The actual relative and absolute thresholds used to indicate the revisions level of trade types (intra-
EU and extra-EU) and trade flows (imports and exports) are reviewed each year. For revisions sent in 
2015 (for any reference year) the thresholds are as defined Table 14: Determination of revision level 

Table 14: Determination of revision levels 

Type of revision 

Level 1 

Level 2 

Subsequent revisions 
(between subsequent 
submissions) 

Cumulative revisions 
(between the first and the last 
available submissions) 

The threshold would equal the 
function: 

The threshold would equal the 
function: 

y + 37,5x =< 318 
with a revision rate x (measured in 
percentage points) and a revision 
value y (measured in million EUR). 

y + 30x =< 955 
with a revision rate x (measured in 
percentage points) and a revision 
value y (measured in million EUR). 

The threshold would equal the 
function: 

The threshold would equal the 
function: 

y + 41,67x =< 500 
with a revision rate x (measured in 
percentage points) and a revision 
value y (measured in million EUR). 

y + 30x =< 900 
with a revision rate x (measured in 
percentage points) and a revision 
value y (measured in million EUR). 

(1)  At the Intrastat/Extrastat Committee, held on 21-22 November 2012, Member States agreed on the thresholds to be used to classify the size 
of  revisions  to  ITGS  data  and  the  actions  to  be  taken  depending  on  the  size  of  the  revision  (for  more  details  see  MET  1165  -  Revised 
proposal for revisions.doc). 

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840. The  absolute  threshold  is  reviewed  annually  to  take  account  of  the  trade  evolution  using  the 
following function:  

New threshold = (1 + Average trade growth) x Previous threshold 
The  new  threshold  for  the  year  N  will  be  agreed  with  the  Member  States  at  the  Steering  Group 
meeting, usually in November N-1. 

Example 77  
If, in 2013, trade increased by 10 %, the new threshold for the year 2014 calculated for EUR 900 million will be: 
(1+0.1) x EUR 900 million = EUR 990 million. 

841. The  NSAs  are  required  to  inform  the  public  about  the  major  revisions  and  when  they  have 
occurred. 

10.4  Trade by business characteristics 

Intra-EU trade 
Regulation (EC) No 638/2004 of the European Parliament and of the Council, Article 12(4) 

Commission Regulation (EC) No 1982/2004, Article 13a 

Extra-EU trade 
Regulation (EC) No 471/2009 of the European Parliament and of the Council, Article 6(2) 

Commission Regulation (EU) No 113/2010, Article 15 

842. The  NSAs  are  required  to  transmit  to  Eurostat  annual  statistics  on  intra-EU  trade  by  business 
characteristics, namely the economic activity carried out by the enterprises and the size-class measured 
in terms of number of employees within 18 months of the end of the reference year. 
843. The  NSAs  are  required  to  transmit  to  Eurostat  annual  statistics  on  extra-EU  trade  by  business 
characteristics.  The  statistics  are  required  to  be  transmitted  within  18  months  of  the  end  of  the 
reference year. 

10.5  Trade broken down by invoicing currency 

Extra-EU trade 
Regulation (EC) 471/2009 of the European Parliament and of the Council, Article 6(3) 

Commission Regulation (EU) No 113/2010, Article 16 

844. Every  two  years  the  NSAs  are  required  to  compile  annual  statistics  on  trade  broken  down  by 
invoicing  currency.  The  first  reference  year  defined  by  the  regulation  was  2010.  The  Member  States 
shall provide the requested data sets every second year: 2012, 2014, 2016, etc. 
845. The  NSAs  are  required  to  compile  the  statistics  using  a  representative  sample  of  records  on 
imports and exports from customs declarations which contain the data on the invoicing currency. If the 
invoicing currency for exports is not available on the customs declaration, the NSAs are required to 
carry out a survey in order to collect the corresponding data. 
846. The  NSAs  are  required  to  transmit  the  data  to  Eurostat  within  three  months  of  the  end  of  the 
reference year. 

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Glossary   

Glossary 

Balance of Payments 

Balance sheet 

CIF-type value 

Combined Nomenclature 

Community goods 

Continental shelf 

Country of origin 

Customs authorities  

Customs decision 

Customs declaration 

The  statistical  system 
transactions 
occurring during specific time periods between an economy and the 
rest of the world can be summarised in a systematic way. 

through  which  economic 

Balance sheet is a summary of the financial balances where assets, 
liabilities and ownership equity are listed as of a specific date, such 
as  the  end  of  a  company’s  financial  year.  A  standard  company 
balance  sheet  has  three  parts:  assets,  liabilities  and  ownership 
equity.  The  main  categories  of  assets  are  usually  listed  first,  and 
typically in order of liquidity. Assets are followed by the liabilities. 

Valuation principle when the value includes the transaction value of 
the  goods,  the value of  services  performed  to deliver  goods  to  the 
border  of  the  exporting  country  and  the  value  of  the  services 
performed  to  deliver  the  goods  from  the  border  of  the  exporting 
country to the border of the importing country. 

A  systematic  list  of  goods  descriptions  based  on  the  Harmonised 
System,  serving  for  the  purposes  of  the  Common  Customs  Tariff, 
external trade statistics, and other EU policies. 

(i)  Goods  entirely  obtained  in  the  customs  territory  of  the 
Community, without addition of goods from non-member countries 
or  territories  which  are  not  part  of  the  customs  territory  of  the 
Community. 
(ii) Goods from non-member countries or territories which are not 
part  of  the  customs  territory  of  the  Community,  which  have  been 
released for free circulation in a Member State. 
(iii)  Goods  obtained  in  the  customs  territory  of  the  Community 
either  from  the  goods  referred  to  exclusively  in  point  (ii)  or  from 
the goods referred to in points (i) and (ii). 

Continental  shelf  comprises  the  seabed  and  subsoil  of  the 
submarine areas that extend beyond its territorial sea throughout the 
natural  prolongation  of  its  land  territory  to  the  outer  edge  of  the 
continental margin, or to a distance of 200 nautical miles from the 
baselines from which the breadth of the territorial sea is measured 
where the outer edge of the continental margin does not extend up 
to  that  distance.  The  continental  shelf  can  spread  out  beyond  the 
exclusive  economic  zone  of  a  country  depending  on  the  seabed 
topography. 

The  country  where  the  goods  originate.  Goods,  which  are  wholly 
obtained or produced in a country, originate in that country. Goods, 
whose production involved more than one country, shall be deemed 
to  originate  in  the  country  where  they  underwent  their  last, 
substantial,  economically  justified  processing  or  they  underwent 
processing resulting in the manufacture of a new product. 

The authorities in Member States responsible inter alia for applying 
customs rules. 

Any official act by customs authorities relating to accepted customs 
declarations and having legal effect on one or more persons. 

The  act  whereby  a  person  indicates  in  the  prescribed  form  and 
manner a wish to place goods under one of the customs procedures 
provided for by the CCC. 

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Glossary   

Customs procedure 

Customs procedures with economic 
impact 

Customs procedure codes 

Customs union 

Customs warehousing 

Delivery terms 

Economic benefits 

EORI number 

Establishment 

The CCC provides for 8 customs procedures: 
—  release for free circulation, 
—  transit,  
—  customs warehousing, 
—  inward processing, 
—  processing under customs control, 
—  temporary importation, 
—  outward processing, 
—  exportation. 

The following customs procedures require an authorisation (and in 
some situations an evaluation of their economic impact): 
—  customs warehousing, 
—  inward processing, 
—  processing under customs control, 
—  temporary importation, 
—  outward processing. 

A  system  of  four-digit  codes,  composed  of  a  two-digit  code 
representing  the  procedure  requested,  followed  by  a  second  two-
digit code representing the previous procedure. This code has to be 
entered  in  SAD box 37  and  is  used  in  statistics  to  define  the 
coverage of exports and imports.  

The merger of two or more customs territories with the effect that 
customs  duties  and  non-tariff  barriers  are  eliminated  between  the 
members  of  the  union  for  substantially  all  trade,  and  a  common 
customs  tariff  and  common  rules  for  non-tariff  barriers  are 
introduced for substantially all trade with non-member countries. 

Customs procedure allowing the storage of non-Community goods 
without  subjecting  them  to  import  duties  or  commercial  policy 
measures and Community goods with a view to applying measures 
normally requiring the export of such goods. 

Those  provisions  of  the  sales  contract  which  lay  down  the 
obligations  of  the  seller  and  the  buyer  respectively,  in  accordance 
with the Incoterms of the International Chamber of Commerce. 

Increased wealth or ability to satisfy needs and wants with respect 
to production, distribution, and consumption of goods and services 

Economic Operator Registration and Identification number, unique 
throughout  the  EU,  assigned  by  a  customs  authority  in  a  Member 
State  to  companies  or  persons.  The  number  is  used  as  a  customs 
identifier in all customs matters, e.g. customs declarations. 

Persons  or  corporations  are  said  to  be  resident/established  in  a 
country  when  they  have  a  centre  of  economic  interest  on  the 
economic  territory  of  that  country.  Having  a  centre  of  economic 
interest  means  that  a  corporation  engages  for  an  extended  period 
(one year or more) in economic activities on this territory. 

Estimates of missing intra-EU trade  Estimated  value  (and  possibly  quantity)  of  the  trade  below  the 
exemption threshold and of the non/late response. These estimates 
are flagged with the threshold indicator 3, 4 or 8 in Doc MET 400 
data files. 

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Estimates of net mass in intra-EU 
trade 

Estimates of statistical value in intra-
EU trade 

Exclusive economic zone 

Export (in customs terms) 

Export duties 

Exporter 

Exports/Dispatches (in statistical 
terms) 

Financial intermediary 

Glossary   

Estimates  of  the  net  mass  not  collected  from  PSIs  because  of 
simplification  provisions  (net  mass  not  mandatory  for  CN8  codes 
with  a  supplementary  unit).  These  estimates  are  flagged  with  the 
threshold indicator 5 in Doc MET 400 data files. 

The statistical value may not be collected from all PSIs because of 
simplification provisions (exemption of all PSIs or of only the ones 
above  the  optional  variable  threshold).  Therefore  the  legislation 
requires  the  statistical  value  to  be  estimated.  These  estimates  are 
transmitted under the threshold indicators 1 or 2 in Doc MET 400 
data files. 

The exclusive economic zone is an area beyond and adjacent to the 
territorial  sea.  The  exclusive  economic  zone  shall  not  extend 
beyond  200  nautical  miles  from  the  baselines  from  which  the 
breadth of the territorial sea is measured. 

The  customs  procedure  for  taking  Community  goods  out  of  the 
customs  territory  in  order  to  ensure  compliance  with  export 
restrictions. 

Customs  duty  payable  on  the  export  of  goods,  for  instance  export 
charges introduced under the common agricultural policy.  

The person on whose behalf the export declaration is made and who 
is  the  owner  of  the  goods  or  has  a  similar  right  of  disposal  over 
them. 
Under  other  regulations  it  is  the  person  who  is  a  partner  of  the 
export contract, the holder of an export licence or who is entitled to 
export refunds 

Operation/movement  of  goods  which  subtract  the  goods  from  the 
stock  of  material  resources  of  a  Member  State  by  leaving  its 
statistical territory. 
Within  the  context  of  NA,  exports/dispatches  of  goods  consist  of 
transactions (sales, barter, gifts) from residents to non-residents.  

Financial  intermediation  is  the  activity  in  which  a  financial 
corporation  (e.g.  a  bank)  acquires  financial  assets  and  at  the  same 
time incurs liabilities on the market. The assets and liabilities of the 
financial  intermediaries  have  different  characteristics  with  respect 
to their maturity, scale, and risk. Financial intermediaries transform 
and/or  repackage 
the  financial 
intermediation process.  
A corporation is a purely financial intermediary when it undertakes 
no other (non-financial) activities.  

the  funds  and 

like 

the 

in 

Financial leasing 

FOB-type value 

Free zone, free warehouse 

A  financial  lease  is  an  arrangement  where  the  lessor  is  the  legal 
owner of an asset but the lessee is the economic owner as the latter 
bears  the  operating  risks  and  receives  the  economic  benefits  from 
using the asset in a productive activity. In return, the lessor accepts 
another package of risks and rewards from the lessee, in the form of 
repayments associated with a loan. 

Valuation principle when the value includes the transaction value of 
the  goods  and the  value of  services performed  to deliver goods  to 
the border of the exporting country. 

A  territory  or  premises  situated  in  the  customs  territory  where 
import  duties  and  commercial  policy  measures  are  suspended  for 
non-Community goods, and Community goods can already benefit 

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Glossary   

Goods 

High seas 

Hire purchase  

Import duties 

Incidental expenses 

Imports (in customs terms) 

from measures requiring their export. 

All movable property, including electricity. 

High  seas  are  defined  as  all  other  territories  beyond  exclusive 
economic  zone  (200 NM)  and  beyond  continental  shelf.  The  high 
seas  can  be  referred  as  to  ‘international  waters’,  ‘high  seas’  or 
‘Area’ as well.  
From statistical point of view, it was recommended to consider the 
area  in  high  seas  which  exclusive  rights  for  exploitation  was 
attributed to the Member State, to consider as the statistical territory 
of that Member State. 

A hire purchase arrangement exists when durable goods are sold to 
a  purchaser  in  return  for  agreed  future  payments.  The  buyer  takes 
possession  of  the  goods  immediately,  though  legally  they  remain 
the  property  of  the  lessor  as  collateral/guarantee  until  all  agreed 
payments have been made by the lessee. 

importation,  autonomous 

Customs  duties  payable  on 
tariff 
suspensions  and  tariff  quotas,  preferential  arrangements,  anti-
dumping,  countervailing,  safeguard  and  retaliatory  duties,  as  well 
as import charges laid down under the common agricultural policy 
and specific arrangements for processed agricultural products 

The  expenditure  spent  on  the  services  rendered  in  the  delivery  of 
goods  to  the  border of  the  exporting or  importing  country  such  as 
loading/unloading of the goods, transportation or insurance. 

Goods  placed  under  a  suspensive  procedure  and  goods  that  have 
been  released  for  free  circulation  under  the  inward  processing 
drawback system. 

Imports/Arrivals (in statistical terms)  Operation/movement of goods which add the goods to the stock of 
material  resources  of  a  Member  State  by  entering  its  economic 
territory. 
Within the context of NA, imports of goods consist of transactions 
(purchases,  barter,  receipt of  gifts)  in  goods  from  non-residents  to 
residents. 

Intrastat register 

Invoice value 

Register  of  intra-EU  operators  containing  at  least  the  consignors, 
upon  dispatch,  and  the  consignees,  upon  arrival  based  on  lists  of 
taxable  persons  who  have  declared  that,  during  the  period  in 
question,  they  have  supplied  goods  to  other  Member  States  or 
acquired goods from other Member States, provided by national tax 
administrations. 

Represents  the  amount  actually  invoiced  and  charged  to  the 
customer;  it  may/may  not  include  incidental  expenses  if  they 
represent payments made by the buyer to the seller. 

Member State of arrival 

Member State in which goods arrive from another Member State. 

Member State of consignment 

Partner  Member  State  on  arrival;  the  presumed  Member  State  of 
dispatch  in  cases  where  goods  enter  directly  the  Member  State  of 
arrival from another Member State. 
Where,  before  reaching  the  Member  State  of  arrival,  goods  have 
entered one or more Member States in transit and have been subject 
in  those  States  to  halts  or  legal  operations  not  inherent  in  their 
transport  (e.g.  change  of  ownership),  the  Member  State  of 
consignment  shall  be  taken  as  the  last  Member  State  where  such 

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Glossary   

Member State of destination 

Member State of dispatch 

Merchanting  

Mode of transport 

halts or operations occurred. 

Partner Member State on dispatch; the last Member State to which 
it  is  known,  at  the  time  of  dispatch,  that  the  goods  are  to  be 
dispatched. 

Member State from which goods are dispatched to a destination in 
another Member State. 

Purchases of goods by a resident of the reporting economy from a 
non-resident and the subsequent resale of the same goods to another 
non-resident without the goods entering the reporting economy. 

Type of the active  means of transport by which the goods reach a 
point (e.g. border of a Member State, place of departure etc.).  

National Statistical Authority (in 
ITGS context) 

The  national  statistical  institutes  and  other  bodies  responsible  in 
each Member State for producing ITGS. 

National Statistical Institute 

Nature of transaction 

Operating (also operational) risks 

Operational leasing 

Origin of goods 

Outward processing 

Provider of statistical information 

Quality checks 

Quality control 

Quantity of the goods 

Quasi-transit 

The national statistical authority designated by each Member State 
as the body having the responsibility for coordinating all activities 
at national level for the development, production and dissemination 
of European statistics. 

The  different  characteristics  (purchase/sale,  work  under  contract, 
etc.)  which  are  deemed  to  be  useful  in  distinguishing  one 
transaction from another. 

According to the Basel II regulations operational risk is the risk of 
loss  resulting  from  inadequate  or  failed  internal  processes,  people 
and systems, or from external events. 

An  operational  lease  is  one  where  the  legal  owner  is  also  the 
economic  owner  and  accepts  the  operating  risks  and  receives  the 
economic benefits from the asset by charging for the use of it, in a 
productive activity. 

trade 
The  ‘economic’  nationality  of  goods 
determined to calculate duties and/or equivalent charges or to apply 
any customs restrictions or obligations. 

international 

in 

A customs procedure allowing the export of Community goods for 
processing  abroad  and  the  re-import  of  the  processed  products 
under total or partial duty relief. 

Any  businesses,  other  ‘institutional’  bodies  (such  as  public  and 
non-profit  institutions,  schools,  hospitals)  and  individual  persons 
who are providing statistical information. 

Verification  that  data  fulfil  the  definition  and  follow  the  defined 
rules. 

A  mechanism  and  procedures  for  the  management  of  the  data 
quality such  as  validity and  credibility  checks::,  assessment  of  the 
compilation methods and practices etc. 

(a)  The  net  mass,  which  means  the  actual  mass  of  the  goods 
excluding all packaging; 
(b) The quantity in supplementary units as detailed in the CN. 

Operation  when  goods  are  imported  by  non-residents  into  the 
reporting  economy  from  outside 
the  EU  and  subsequently 
dispatched  to  another  Member  State  as  well  as  when  the  goods 
exported from a Member State to a non-member country are cleared 

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for export in another Member State. 

Re-exportation (in customs terms) 

Customs  treatment  of non-Community goods  that are  taken out of 
the customs territory of the EU. 

Glossary   

Re-exports (in statistical terms) 

Reference period 

Re-imports (in statistical terms) 

Sea products 

Simple circulation between Member 
States 

Single Administrative Document 

Single authorisation 

Single authorisation for simplified 
procedures 

Operation when foreign goods (goods produced in other economies 
and  previously 
imported)  are  exported  with  no  substantial 
transformation  from  the  state  in  which  they  were  previously 
imported. 

The  time  period  for  which  statistical  results  are  collected  or 
calculated and to which, as a result, these values refer. 

Operation  when  domestic  goods  (goods  produced  in  an  economy 
and  subsequently  exported)  are  imported  from  another  economy 
and did not undergo substantial transformations there. 

Fishery products, minerals, salvage and other products which have 
not yet been landed by seagoing vessels. 

Operation/movements  of  Community  goods  when  the  goods  are 
dispatched from one Member State to another and on the way to the 
Member  State  of  destination,  travel  directly  through  another 
Member State or stop for reasons related only to the transport of the 
goods. 

This  is  a  multi-copy  form  which  is  used  throughout  the  EU  and 
EFTA  countries  for  the  control  of  imports,  exports  and  goods  in 
transit. 
The  document  covers  the  placement  of  any  goods  under  any 
customs  procedure  (Export, 
the  new 
computerised  transit  system  (NCTS)  is  not  yet  used,  warehouses, 
temporary  import,  inward  and  outward  processing,  etc.)  whatever 
the mode of transport used. 

transit  where 

import, 

An  authorisation  involving  customs  administrations  in  more  than 
one Member State for one of the following procedures:  
—  the  simplified  declaration  procedure  pursuant  to  Article  76(1) 

of the CCC; 

—  the  local  clearance  procedure  pursuant  to  Article  76(1)  of  the 

CCC;  

—  customs  procedures  with  economic 

impact  pursuant 

to 

Article 84(1)(b) of the CCC; 

—  end-use pursuant to Article 21(1) of the CCC. 
If an operator is authorised to use more than one of the procedures 
referred  to  in  the  above  mentioned  points  then  Integrated 
authorisation is issued. It may also take the form of an integrated 
single authorisation where more than one customs administration is 
involved. 

A  scheme  based  on  single  authorisation  that  enables  economic 
operators  to  be  authorised  in  one  Member  State  for  simplified 
declaration procedures and for   the  local  clearance  procedure  for 
all  their  import  and  export  freight  operations  throughout  the  EU. 
This  enables  economic  operators  to  centralise  the  accounting  and 
payment  of  customs  duties  for  all  transactions  in  the  authorising 
Member  State,  although  the  physical  control  and  release  of  goods 
may take place in another Member State. 

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Glossary   

Spacecraft 

Specific goods or movements 

Statistical business register(s) 

Statistical procedure 

Satellites  and  other  vehicles  which  are  able  to  travel  outside  the 
earth’s 
(e.g. 
for 
communications,  earth  observation,  meteorology,  navigation, 
planetary exploration and transportation of humans and cargo). 

atmosphere, 

purposes 

different 

used 

Goods or movements which, by their very nature, call for specific 
provisions, and in particular: 
—  industrial plants, 
—  vessels and aircraft, 
—  sea products, 
—  goods delivered to vessels and aircraft, 
—  staggered consignments, 
—  military goods, 
—  goods to or from offshore installations, 
—  spacecraft, 
—  motor vehicle and aircraft parts,  
—  waste products. 

Register(s)  of  all  enterprises  carrying  on  economic  activities 
contributing to the gross domestic product of a Member State, and 
their local units, the legal units of which those enterprises consist, 
truncated enterprise groups and multinational enterprise groups and 
all-resident enterprise groups. 
The register is established for statistical purposes, as a tool for the 
preparation and coordination of surveys, as a source of information 
for  the  statistical  analysis  of  the  business  population  and  its 
demography,  for  the  use  of  administrative  data,  and  for  the 
identification and construction of statistical units. 

The  different  characteristics  which  are  deemed  to  be  useful  in 
distinguishing  different  types  of  arrivals/dispatches  for  statistical 
purposes. 

Statistical territory 

The territory with respect to which data are being collected. 

Statistical value 

TARIC 

Taxable amount 

Territorial enclaves 

The  value  of  the  goods  at  the  time  and  place  the  goods  cross  the 
border  of  the  exporting/importing  Member  State  which  contains 
solely and entirely the costs of transport and insurance performed to 
deliver the goods from the place of their departure to the border of 
the exporting/importing Member State. 

Integrated tariff of the Community, held in a Commission database 
containing  the  EU  import  and  export  measures  applicable  to 
specific  goods,  such  as  tariff  suspensions,  tariff  quotas,  tariff 
preferences, 
restrictions, 
anti-dumping  duties,  quantitative 
embargoes, export. 

The  value  to  be  determined  for  taxation  purposes  in  accordance 
with the VAT Directive. 

Demarcated  areas  of  land  within  geographical  boundaries  of  other 
countries  and  which  are  used  by  the  government  for  diplomatic, 
military,  scientific  or  other  purposes  (e.g.  embassies,  consulates, 
military  bases,  scientific  stations,  information  or  immigration 
offices, aid agencies, etc.). 

Territorial sea (or territorial waters)  Every State has the right to establish the breadth of its territorial sea 
up  to  a  limit  not  exceeding  12 nautical  miles,  measured  from 

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Glossary   

baselines  determined  in  accordance  with  this  Convention.  This  is 
the  territory  included  in  the  EU  customs  territory  and  in  this  way 
makes part of statistical territory of the Member State. 

Trade systems 

Transit 

Union Customs Code 

VAT registration (as an entity) 

data-compilation 

ITGS 
the 
systems 
inclusion/exclusion  of  some  parts  of  the  economic  territory  of  a 
country in/from the statistical territory of that country. 

through 

defined 

Operation/movements  of  goods  when  the  goods  are  transported 
through the reporting economy on the way to their final destination 
without any halt or with a halt only inherent to the transport. 

Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of 
the  Council  setting  the  general  rules  and  procedures  applicable  to 
goods brought into or out of the customs territory of the EU. 
This  new  code  aims  to  facilitate  trade  by  simplifying  and 
computerising customs procedures and ensuring the interoperability 
between  the  IT  systems  of  the  28  customs  administrations,  while 
ensuring a high level of safety and security at the external borders.  

An entity, usually non-resident taxable person, which is obliged to 
register  for  VAT  in  a  Member  State  when  effectuating  taxable 
transaction in that Member State. 

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Annexes   

ANNEX 1 — Summary of the legal 
requirements, recommendations and 
encouragements 

Wording of requirements, recommendations and 
encouragements 

No of § in the 
Guide 

References to the 
legislation and 
other documents 

Applied 
from 
year 

2. THE FRAMEWORK 

REQUIREMENTS 

L1.  National  tax  administrations  are  required  to  provide 
statistically relevant information to the NSA at least once a 
month. 

L2.  National Customs are required to provide NSA with any 
information  related  to  intra-EU  trade  but  declared  on 
customs declarations at least once a month. 

L3.  National authorities which are responsible for maintaining 
vessels  and  aircraft  registers  are  required  to  provide 
NSAs with all information available in the registers. 

L4.  NSAs  are  required 

to  estimate  missing  data  on 
movements  of  non-Community  goods  between  Member 
States  if  they  are  not  recorded  using  the  standard  data 
source — the Intrastat or custom declaration. 

182 

183 

203 

Reg. No 638/2004, 
Art. 8(2) 
Reg. No 1982/2004, 
Art. 5 and 6 

Reg. No 638/2004, 
Art. 5(2) 

Reg. No 1982/2004, 
Art. 17(4) 
Reg. No 113/2010, 
Art. 19(4) 

2005 

2005 

2010 

187, 214, 444  Reg. No 638/2004, 

2005 

Art. 12(2) 

L5.  NSAs  are  required  to  estimate  missing  intra-EU  trade  of 

230 

non-taxable legal persons. 

Reg. No 638/2004, 
Art. 12(2) 

L6.  NSAs  are  required  to  estimate  the  trade  of  foreign 
established PSIs on the basis of their fiscal VAT returns if 
they do not declare for Intrastat in spite of all the efforts of 
the national authorities. 

L7.  National  statistical  institutes  are  required  to  link  the 
statistical  business  register  with  the  register  of  intra-  and 
extra-Community operators. 

L8.  The tax administration is required to provide the national 
statistical  authority  with  contact  and 
identification 
information  about  persons  who  have  declared  intra-EU 
acquisitions  and  supplies  of  goods:  name  of  the  taxable 
person,  address  including  post  code  and  an  identification 
number. 

L26.  National Customs are required to provide NSAs with any 
available information to identify the person who carries out 
dispatches and  arrivals of goods under inward processing 
or processing under customs control. 

L27.  NSAs are required to create the conditions enabling PSIs 
to  use  automatic  data  processing  and  electronic  data 
transmission systems. 

L28.  NSAs are required to establish the penalty system under 
which  any  PSI  not  fulfilling  his/her  obligations  to  provide 
Intrastat information is liable to the penalties. 

L29.  The  tax  administration  is  required  to  inform  VAT 
registered operators on their possible obligation to provide 
Intrastat information. 

L30.  NSAs are required to set up and manage Intrastat register 

245 

of intra-Community operators. 

2005 

2005 

238 

Reg. No 638/2004, 
Art. 12(2)  

246 

Reg. No 177/2008 

2009 

256 

Reg. No 638/2004, 
Art. 8(2) 

2005 

188 

279 

220 

233 

Reg. No 638/2004, 
Art. 5(2a) 

2015 

Reg. No 638/2004, 
Art. 5(4) 

Reg. No 638/2004, 
Art. 7(3) 

Reg. No 638/2004, 
Art. 8(3) 

Reg. No 638/2004, 
Art. 8(1) 

2005 

2005 

2005 

2005 

Compilers guide on European statistics on international trade in goods 

175 

 
 
 
L31.  National Customs are required to provide NSAs customs 
declarations  lodged  with  them  at  the  latest  the  month 
following the month of acceptance. 

287 

Reg. No 471/2009, 
Art. 7(1) 

2010 

Annexes   

It is recommended that NSAs instruct trade operators to 
correctly fill in Intrastat declarations, provide them with the 
necessary manuals and maintain a helpdesk. 

175, 337, 412, 
790 

RECOMMENDATIONS 

R1. 

R2. 

It  is  recommended  that  NSAs  update  as  frequently  as 
possible,  at  least  once  per  month,  the  information  about 
the liability of the companies to report for Intrastat. 

R23.  It  is  recommended  that  NSAs  revise  data,  which  are 
considered  final,  where  the  revision  is  significant  for  the 
interpretation of the data. 

R29.  It  is  recommended  that  NSAs  estimate  the  total  trade 
below  the  exemption  threshold  by  using  the  most  reliable 
data sources — current month’s or historical administrative 
data (VIES or VAT) — available at the time the estimation 
process should be launched. 

R30.  It is recommended that NSAs estimate the total trade of 
PSIs late in submitting their Intrastat declarations by using 
the  most  reliable  data  sources  —  current  month’s  or 
historical  administrative  data  (VAT  or  VIES),  current 
month’s or historical Intrastat data — available at the time 
the estimation process should be launched. 

R31.  It is recommended that NSAs allocate the estimated total 
trade  below  the  exemption  threshold  by  product  and 
partner  Member  State  by  using  data  collected  from  the 
most similar traders above the exemption threshold. ‘Most 
similar  traders’  should  be  understood  as  traders  with  a 
most  similar  activity  or/and  of  most  similar  size.  ‘Traders 
with  a  most  similar  activity’  means  ‘traders  with  the  same 
NACE activity code or with a NACE activity code as similar 
as  possible’.  ‘Traders  of  most  similar  size’  means  ‘just-
above-threshold  traders’.  As  regards  the  allocation  by 
partner  Member  State,  an  alternative  to  the  use  of  most 
similar  traders’  data  would  consist  in  applying  the  pattern 
captured from VIES data. 

R32.  As  regards  the  PSIs  late  in  submitting  their  Intrastat 
declarations,  it  is  recommended  that  NSAs  allocate  the 
estimated total trade by product and partner Member State 
by using their historical Intrastat data or, if not available or 
not  relevant,  by  using  Intrastat  data  collected  from  the 
most  similar  traders.  ‘Most  similar  traders’  should  be 
understood as traders with a most similar activity or/and of 
most  similar  size.  ‘Traders  with  a  most  similar  activity’ 
means ‘traders with the same NACE activity code or with a 
NACE  activity  code  as  similar  as  possible’.  ‘Traders  of 
most  similar  size’  means  ‘traders  with  most  similar  trade 
value  or  turnover’.  As  regards  the  allocation  by  partner 
Member  State,  an  alternative  to  the  use  of  the  PSI’s 
historical  Intrastat  data  or  of  similar  traders’  data  would 
consist in applying the pattern captured from VIES data. 

R33.  It  is  recommended  that,  to  the  extent  possible,  NSAs 
avoid  estimating  the  main  PSIs’  trade  by  taking  any 
necessary  measures  to  get  their  Intrastat  declarations  in 
due time. 

ENCOURAGEMENTS 

256 

282 

258 

259 

260 

261 

257 

E1.  Member  States  are  encouraged 

the 
cooperation  of  national  statistical  authorities  with  tax  and 
customs  administrations 
through  establishing  working 
groups and other forums for discussions  and exchange of 
information. 

formalise 

to 

39, 40, 41, 124, 
137, 254,637, 
695 

2014 

2014 

New 
2015 

New 
2016 

New 
2016 

New 
2016 

New 
2016 

New 
2016 

2014 

E2.  NSAs are encouraged to establish procedures in order to 
check  the  records  with  CN  code  7108 20 00  (monetary 

71, 74 

Reg. No 1982/2004, 
Annex I, points (a) and (b) 

2014 

Compilers guide on European statistics on international trade in goods 

176 

 
 
 
 
 
 
 
 
 
 
 
 
Annexes   

gold)  and  to  distinguish  the  coins  in  circulation  traded  as 
collectibles. 

Reg. No 113/2010, 
Annex I, points (a) and (b) 

E3.  NSAs are encouraged to introduce special procedures in 
order  to  detect  movements  of  goods  between  a  Member 
State  and  its  territorial  enclaves  established  in  non-
member countries and to eliminate these movements from 
the scope of statistics. 

83, 84 

Reg. No 113/2010, 
Annex I, point (d) 

2014 

195, 290, 301  SASP Guidelines,  

2014 

provisions on statistics  

201, 592 

289 

292 

307 

271 

137 

Reg. No 113/2010, 
Art. 15(4) 

E4.  Customs  administrations  are  encouraged  to  grant  the 
SASP  authorisation 
the  NSA 
concerned  has  agreed;  close  cooperation  between 
institutions involved should be ensured. 

traders  only  when 

for 

E5.  NSAs  in  Member  States  involved  are  encouraged  to 
strengthen  multilateral  cooperation  including  exchange  of 
any  kind  of  information  on  trade  in  vessels  and  aircraft, 
even at transaction level, among them whenever possible. 

E6.  NSAs  are  encouraged  to  ensure  that  the  time  lag  for 
providing the supplementary declaration set by the national 
customs  provisions  is  not  in  contradiction  with  statistical 
requirements. 

E7.  NSAs  are  encouraged  to  request  their  national  Customs 
to include the indication of Member State of destination on 
imports  or  Member  State  of  actual  export  on  exports  in 
SASP. 

E8.  NSAs are encouraged to acquire the EORI register along 

with trade data from Customs on a regular basis. 

E9.  NSAs are encouraged to analyse the differences between 
data  on  partner  country  in  Intrastat  and  VIES  at  PSI  level 
after methodological adjustment. 

E42.  NSAs  are  encouraged 

tax 
administrations  how  distance  sales  are  recorded  on  the 
national  VAT  return  and  to  find  solutions  to  ensure  full 
coverage of this type of trade. 

to  analyse  with 

their 

E43.  NSAs  are  encouraged  to  define  rules  how  PSIs  should 

283 

submit corrective Intrastat declaration. 

E50.  NSAs  are  encouraged  to  regularly  assess  the  quality  of 
the administrative data — VAT and VIES data — in terms 
of accuracy, timeliness and, where possible, comparability 
with Intrastat data — in the view of:  
a) identifying the most appropriate  estimation methods for 
trade below threshold and non/late response; 
b)  measuring  how  far  VIES  data  can  be  used  to  allocate 
trade  by  partner 
the  estimates 
Member State; 
c) measuring how far the administrative data can be used 
to control the quality of Intrastat data. 

for  missing 

intra-EU 

E51.  NSAs  are  encouraged  to  monitor  the  accuracy  of  the 
non/late  response  estimates  at  product  and  partner  level 
by  comparison  with  real  data  when  Intrastat  declarations 
are  submitted.  They  should  improve  their  estimation 
method in the case this monitoring reveals quality issues. 

COMPILATION RULES 

C1. 

Inward  processing  activity  (under  a  customs  procedure) 
irrespective  of  whether  this  is  carried  out  in  the  free 
circulation area, in a customs warehouse or in a free zone 
shall be included in ITGS. 

C2.  Community  goods  stored  in  customs  warehouses  and  in 
type  II  free  zones  shall  be  considered  as  virtually  staying 
in the free circulation area. 

C3.  Postage  stamps  and  similar  stamps 

(e.g.  highway 
vignettes, road tax discs, motorway toll repayment stickers 
and  the  like),  provided  that  they  are  the  subject  of  a 
commercial  transaction,  in  the  same  way  as  un-issued 
bank notes not in circulation, shall be included in intra-EU 

250 

262 

66 

66 

74 

2014 

2014 

2014 

2014 

2014 

New 
2015 

New 
2015 

New 
2016 

New 
2016 

2014 

2014 

2014 

Compilers guide on European statistics on international trade in goods 

177 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annexes   

and extra-EU trade statistics. 

C4.  The  reference  period  for  movements  of  goods  for  or 
following temporary use shall be the calendar month when 
the  event  breaking  the  conditions  of  the  provision  took 
place. 

C5.  The  partner  country  code  QV  or  QW  (countries  and 
territories  not  specified)  shall  be  used  for  goods  received 
or sent abroad by international organisations. 

C6.  An  operation  should  be  treated  as  processing  if  the 
commodity  code  changes  as  a  result  of  activities  such  as 
manufacturing,  construction,  assembling, 
improvement, 
renovation, etc. 

78, 330 

86 

104 

C7.  Processing  activities  on  a  processor’s  own  account  shall 

107 

be registered under NoT code 1. 

Reg. No 1982/2004, 
Annex I, point (c) 
Reg. No 113/2010,  
Annex I, point (c) 

Reg. No 1982/2004, 
Annex III 
Reg. No 113/2010, 
Annex II 

C8. 

If no change of ownership between the owner of the goods 
and  the  processor  occurs,  NoT  code  4  and  5  shall  be 
used. 

107 

C9.  The negative value of waste without market value shall be 

142, 144 

Doc MET 400 

adjusted close to zero or to 1 unit of value. 

C10.  Trade  in  periodicals  under  direct  subscription  should  be 

considered as trade in services. 

C11.  The  reference  period  for  Call  off  and  Consignment  stock 
transactions should be defined as the calendar month for 
which the same transaction is recorded for fiscal purposes. 

151 

165 

C12.  If  the  aid  supplies  are  provided  free  of  charge,  the  NoT 

168 

code ‘3’ shall be declared. 

IMTS: Concepts and 
definitions 

L9.  NSAs  are  required  to  ensure  that  results  transmitted  to 

257, 825 

Eurostat cover 100 % of the trade of the reference period. 

3. THE DATA 

REQUIREMENTS 

L10.  NSAs  are  required  to  transmit  collected  data  to  Eurostat 
at  eight  digit  level  of  the  CN  commodity  code  except  for 
extra-EU imports where the commodity should be recorded 
at 10 digit TARIC level. 

338, 340 

L11.  NSAs  are  required  to  collect  the  taxable  amount  from  all 

380 

PSIs. 

L12.  NSAs  are  required  to  communicate  to  Eurostat  the 
estimation  methodology  of  the  value  of  electricity  and  gas 
before its application. 

400, 669 

L13.  NSAs  are  required  to  estimate  the  statistical  value  of 

411 

transactions for which it is not collected. 

Reg. No 638/2004, 
Art. 12(2) 
Reg. No 471/2009, 
Art. 8(1) 

Reg. No 638/2004, 
Art. 12(1)(b) 
Reg. No 471/2009, 
Art. 8(1) 

Reg. No 638/2004, 
Art. 9(1)(f) 
Reg. No 1982/2004 
Art. 8(1) 

Reg. No 1982/2004, 
Art. 23(3) 
Reg. No 113/2010, 
Art. 24(2) 

Reg. No 1982/2004, 
Art. 25(4) 

L14.  NSAs  are  required  not  to  adjust  extra-EU  trade  data  for 
credit  notes  issued  in  relation  to  discounts  granted  at  the 
end of a certain period or for good results. 

L15.  NSAs  are  required  to  carry  out  a  survey  and  collect 
information  on  invoicing  currency  for  exports  directly  from 
traders  whenever  the  data  is  not  available  at  Customs. 
NSAs are required to organise a survey in such a way that 
accurate results are provided. 

423 

Reg. No 113/2010, 
Art. 4(1) 

430, 846 

Reg. No 113/2010, 
Art. 16(5) 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2005 

2005 

2005 

2005 

2010 

2005 

2005 

2010 

L16.  NSAs are required to estimate the net mass when it is not 
collected from PSIs due to simplification of reporting. 

435 

Reg. No 1982/2004, 
Art. 25(5) 

2010 

L17.  NSAs  are  required  to  use  customs  procedure  codes  first 

450 

Reg. No 471/2009, 

2010 

Compilers guide on European statistics on international trade in goods 

178 

 
 
 
 
 
 
 
 
 
subdivision for defining the correct coverage of ITGS. 

Art. 5(1)(i) 

Annexes   

L18.  NSAs are required to establish the necessary routines to 
identify and exclude trade flows which are out of the scope 
of extra-EU trade statistics. 

L19.  NSAs  are  required  to  compile  information  on  preferential 
treatment  of  imported  goods.  Customs  are  required  to 
transmit  to  NSAs  the  information  on  their  actually  applied 
preferential treatment. 

L32.  The  competent  national  authorities  are  required  to 
provide access to data in EORI database at the request of 
NSA. 

R3. 

R4. 

R5. 

R6. 

RECOMMENDATIONS 

It  is  recommended  that  when  using  additional  data 
sources  for  specific  movements,  if  possible  NSAs  assign 
to an economic operator the identification number which is 
linked to the VAT ID number system. 

It  is  recommended  that  NSAs  estimate  the  net  mass  at 
CN  subheading  level  for  those  CN  codes  for  which 
information is not collected from PSIs. 

It  is  recommended  that  NSAs  establish  a  correlation 
table linking customs procedures to special (and if needed 
to general) trade systems and to statistical procedures. 

is 

recommended 

transmit  all 
It 
transactions with all customs procedures applicable to the 
NSAs,  allowing 
for  full  statistical  control  of  relevant 
transactions. 

that  Customs 

ENCOURAGEMENTS 

E10.  NSAs are encouraged to make the submission of Intrastat 
declarations separately for individual branches of a PSI the 
subject of prior approval by the national authorities. 

E11.  NSAs  are  encouraged  to  closely  monitor  the  changes  in 
TARIC codes during the year and when necessary modify 
data validation procedures. 

459 

Reg. No 113/2010,  
Annex I 

Reg. No 471/2009, 
Art. 6(1)(f) 
Reg. No 92/2010, 
Art. 2(2)(p) 

Reg. No 113/2010, 
Art. 15(4) 

485, 492 

307 

321 

434 

460 

460 

319 

340 

E12.  NSAs are encouraged to set thresholds which determine 
when  PSIs  should  transmit  to  them  corrections  related  to 
credit notes which are of statistical relevance. 

284, 410 

E14.  NSAs  are  encouraged  to  use  the  second  subdivision  of 
customs  procedure  code  when  it  allows  to  better  identify 
trade flows for exclusion. 

E15.  NSAs are encouraged to contact the national Customs in 
order  to  gain  a  clear  understanding  of  the  meaning  of  the 
use  of  a  CPC  in  the  context  of  national  clearance 
specificities. 

E16.  NSAs  of  Member  States  involved  in  intergovernmental 
production  programmes  are  encouraged  to  agree  for 
which projects NoT code 7 should be applied and all PSIs 
concerned should be advised accordingly. 

E17.  NSAs are encouraged to use the delivery terms whenever 
available on customs declarations for correct calculation of 
statistical value and CIF/FOB adjustments. 

E56.  Where NSAs collect the statistical value and other optional 
information within Intrastat they are encouraged to collect 
it  only  from  the  most  important  traders  by  defining 
thresholds  only  above  which  PSIs  are  obliged  to  provide 
this additional information [former E13 and E33]. 

450 

451 

478 

522 

411, 750 

COMPILATION RULES 

C13.  The  reference  period  for  goods  not  reported  on  a  VAT 
return as an intra-EU acquisition or supply shall be defined 
as the calendar month during which the dispatch or arrival 
of the goods takes place. 

328 

C14.  Simplified codes for military goods should be used only in 

345 

2010 

2005 

2010 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2016 

2014 

2014 

Compilers guide on European statistics on international trade in goods 

179 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
exceptional cases; the real CN code is preferred. 

C15.  The Member State of purchase  should be recorded if the 

360 

Member State of consignment is unknown. 

C16.  Information  on  Member  State  of  destination  or  Member 
State  of  actual  export  shall  be  transmitted  to  Eurostat 
according to the rules defined in paragraph 379. 

C17.  The  code  of  the  Member  State  where  the  customs 
declaration  was  lodged  shall  be  used  to  define  Member 
States  of  destination/actual  export,  where  the  NSA  can 
neither  derive  the  correct  code  from  any  information  at  its 
disposal, nor can it decide to use code QV. 

379 

Doc MET 400 

379 

Reg. No 1982/2004, 
Art. 8(1) 

Reg. No 1982/2004, 
Art. 8(1) 

Reg. No 1982/2004, 
Art. 8(3) 

Reg. No 1982/2004, 
Art. 8(1) 

Reg. No 1982/2004, 
Art. 8(1) 
Reg. No 113/2010, 
Art. 4(3) 

C18.  Any duties (e.g. VAT or excise) shall not be included in the 

382 

taxable amount. 

C19.  Whenever  the  taxable  amount  does  not  have  to  be 
established  for  taxation  purposes,  NSAs  shall  collect  the 
invoice  value  instead,  or  failing  this,  the  value  shall  be 
estimated. The estimated value shall be the amount which 
would  have  been  invoiced  in  the  event  of  a  purchase  or 
sale under normal market conditions. 

C20.  PSIs  when  estimating  the  taxable  amount  should  follow 
the  same  principles  applied  for  determining  the  customs 
value  according  to  Article  29  (et  seq)  of  the  Council 
Regulation (EEC) No 2913/92 

383, 385 

386 

C21.  PSIs  should  separate  the  values  of  the  goods  and 
services  where  an  invoice  includes  both  and  declare  only 
the value of the goods (as an estimate, if necessary). 

387, 399 

C22.  The taxable amount (or failing that invoice value) shall be 

expressed in the national currency units. 

C23.  PSIs  shall indicate the open market value of goods when 
goods are delivered without an invoice or with a pro-forma 
invoice and other deliveries/replacements free of charge. 

C24.  PSIs  shall  report  the  total  value  of  the  goods  in  their 
unprocessed state for transactions involving goods sent for 
processing.  Regarding  transactions  following  processing, 
the total value of the processed goods shall be reported. 

C25.  The  transaction  when  goods  move  between  two  Member 
States, but the transfer of ownership does not concern any 
party  in  the  reporting  Member  State  shall  be  recorded  by 
PSIs using NoT code 9. 

C26.  NoT  code  2  shall  be  used  for  returned  goods  only  when 

the original goods movement was recorded with code 1. 

C27.  Return  of  goods  for  which  the  original  transaction  was 
reported  with  NoT  codes  3,  7,  8  and  9  shall  be  declared 
again with the same transaction codes. 

C29.  PSI  should  make  suitable  estimations 

C28.  Return  of  goods  recorded  under  NoT  code  4  and  side 
products of the processing shall be reported under code 5. 
to 
determine the proper NoT codes according to the share of 
the  different  country  sources  and  destinations.  If  such 
estimation  is  not  possible,  the  application  of  NoT  code  42 
and 52 is preferred. 

in  order 

388 

396 

402 

465 

467 

468 

468, 471 

473 

C30.  The goods transported by private courier services shall be 
recorded under transport code 5 (Postal consignment) only 
if the active means of transport is unknown. 

C31.  The  system  of  codes  for  region  of  origin,  when  collected, 
should  be  defined  in  such  a  way  that  it  is  possible  to 
measure the re-exports of goods of non-national origin. 

C32.  The  regions  should  be  defined  in  accordance  with  the 
administrative subdivision of the country in line with NUTS 
nomenclature. 

500 

519 

519 

Annexes   

2014 

2010 

2014 

2005 

2005 

2014 

2014 

2005 

2005 

2005 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

Compilers guide on European statistics on international trade in goods 

180 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C33.  The  same  rules  as  for  Intrastat  should  be  applied  when 
collecting the region of origin/destination for national needs 
in extra-EU trade statistics. 

520 

2014 

Annexes   

4. SPECIFIC GOODS OR MOVEMENTS 

REQUIREMENTS 

L33.  NSAs  are  required  to  record  only  the  physical  flows  of 
electricity and gas in intra-EU and extra-EU trade statistics. 

668 

Reg. No 638/2004, 
Art. 3 
Reg. No 1982/2004, 
Art. 23(1) 
Reg. No 471/2009, 
Art. 3 
Reg. No 113/2010, 
Art. 24(1) 

RECOMMENDATIONS 

R9. 

It is recommended that NSAs introduce, at national level, 
the obligation to complete an Intrastat declaration for trade 
transactions  involving  changes  of  economic  ownership, 
whatever the contractual arrangements. 

R10.  It  is  recommended  that  NSAs  agree  on  a  regular 
information  exchange  on  entries  into  and  removals  from 
the  ships  and  aircraft  registers  with  competent  national 
authorities. 

R24. It is recommended that NSAs establish methodologies for 
the estimations of transit trade of gas where the collection 
of data is not possible. 

R25.  It is recommended that NSAs compare ITGS quantitative 
data with the data of the energy statistics, grid operators or 
any  other  available  quantitative  data  in  order  to  verify 
whether  further  reconciliation  is  needed  and  to  identify 
exact reasons of discrepancies. 

R34.  It  is  recommended  that  NSAs  acquaint  themselves  with 
information  on  how  their  national  legislation  defines  the 
accounting standards, in particular those related to leasing 
arrangements, as they can be very helpful in determining a 
change in economic ownership [former E20]. 

R35.  It  is  recommended  that  NSAs  use  Intrastat  system  for 
collection  of  data  on  intra-EU  supplies  to  vessels  and 
aircraft only in case the Customs is not providing  with the 
necessary data. 

ENCOURAGEMENTS 

E18.  The competent national authorities listed in the chapter 
98 of the CN are encouraged to require prior authorisation 
of  PSI  to  use  simplified  reporting  of  an  industrial  plant 
through submission of a written application. 

E19.  NSAs  are  encouraged  to  coordinate  among  themselves 
the application of simplification for staggered consignments 
in order to avoid mirror discrepancies. 

E21.  NSAs  are  encouraged  to  establish  a  specific  procedure 
for  the  CN  codes  of  vessels/aircraft  falling  under  the 
specific  goods  or  movements  provisions  in  order  to 
examine  the  transactions  and  to  verify  their  correct 
treatment in ITGS. 

E22.  NSAs  are  encouraged  to  examine  the  possibility  to  use 
VAT  data  about  intra-EU  acquisitions  of  new  vessels  and 
aircraft in order to identify statistically relevant transactions. 

E23.  NSAs  are  encouraged  to  implement  at  least  ad  hoc 
surveys  to  collect  data  directly  from  entities  involved  in 
vessels/aircraft  transactions  in  order  to  integrate  possible 
missing data. 

E24.  Member  States  are  encouraged  to  enhance  cooperation 
of all compilers involved (ITGS, ITSS, BoP and NA) when 

582 

583 

701 

705 

555 

615 

532 

544 

580 

581 

590 

591 

2005 

2006 

2014 

2014 

New 
2016 

New 
2015 

2015 

New 
2016 

2014 

2014 

2014 

2014 

2014 

2014 

Compilers guide on European statistics on international trade in goods 

181 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
recording the transactions in vessels/aircraft. 

E25.  NSAs are encouraged to apply the simplified reporting on 
motor vehicle and aircraft parts only in a conservative way. 

E26.  NSAs  are  encouraged  to  establish  an  appropriate  data 
collection system for sea products and to combine various 
data  sources  in  a  comprehensive  manner  so  that  double 
counting or missing trade flows are avoided. 

E27.  NSAs are encouraged to be well aware of which national 
acts  define  the  information  falling  under  military  or  state 
secrecy and their content. 

E44.  NSAs are encouraged to analyse the recording practices 
in  Customs  of  the  goods  moving  to  and  from  offshore 
installations in order to ensure complete coverage of trade 
statistics and to avoid double counting. 

E45.  NSAs  are  encouraged 

to  develop 

the  necessary 
knowledge about functioning of electricity and gas markets 
at  the  national  and  the  EU  levels  in  order  to  be  able  to 
correctly  develop  methodologies  for  the  collection  of  the 
statistical data. 

E46.  NSAs are encouraged to analyse with tax administrations 
the  national  provisions  concerning  recording  of  gas  and 
electricity  transactions  on  VAT  returns  and  to  evaluate  its 
possible reuse for ITGS purposes. 

E47.  NSAs  are  encouraged  to  use  for  the  estimation  of 
statistical  value  of  electricity  and  gas  long-term  contract 
prices  and  other  available  information  which  correctly 
reflect  the  value  of  electricity  and  gas  on  the  particular 
market.. 

E48.  NSAs  are  encouraged  to  consult  transmission  system 
operators, who could estimate the share of transit trade in 
the total flows of electricity and gas.  

E49.  NSAs are encouraged to identify alternative data sources 
for  quality  checks  and  compilation  of  ITGS  in  gas  and 
electricity regarding physical flows, prices or values. 

E52.  NSAs  are  encouraged  to  manage  the  application  of 
simplified  reporting  for  industrial  plant  in  the  way  which 
minimises the asymmetries in the trade in goods with other 
Member States. 

E53.  NSAs  are  encouraged 

to  analyse  national  VAT 
regulations  in  order  to  clear  define  the  scope  of  goods 
which can benefit from simplifications. 

E54.  NSAs are encouraged to establish a control system which 
would  eliminate  the  risk  of  double  counting  of  data  from 
two sources (customs and Intrastat declarations). 

E55.  NSAs are encouraged to analyse the recording practices 
in  Customs  of  supplies  to  vessels  and  aircraft  in  order  to 
identify  whether  simplifications  applied  are  not 
in 
contradiction with statistical requirements. 

C34.  If a vessel/aircraft is legally owned by a natural person who 
does not use it for commercial purposes (e.g. yachts), then 
the natural person should be considered as the economic 
owner of the vessel/aircraft. 

COMPILATION RULES 

601 

656 

708 

637 

674 

695 

701 

701 

704 

535 

608 

616 

623 

0 

C35.  The holder of the fishing licence should be considered as 

559 

the economic owner of the fishing vessel. 

C36.  If  the  vessel/aircraft  is  new,  a  transaction  between  the 
manufacturer  and  the  first  economic  owner  shall  be 
reported. 

C37.  The processing activities linked with construction of a new 
vessel/aircraft  shall  be  reported  according  to  standard 
ITGS rules  

561 

562, 575 

Annexes   

2014 

2014 

2014 

New 
2015 

New 
2015 

New 
2015 

New 
2016 

New 
2015 

New 
2015 

New 
2016 

New 
2016 

New 
2016 

New 
2016 

2014 

2014 

2014 

2014 

Compilers guide on European statistics on international trade in goods 

182 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C38.  If 

the 

processing 

significantly 
operation 
improved/changed 
transaction 
the  vessel/aircraft, 
between  the  processor  and  the  economic  owner  shall  be 
reported. 

has 

the 

C39.  If  a  rise  in  value  of  a  vessel/aircraft  due  to  processing  is 
capitalised  in  the  business  accounts  of  the  economic 
owner, the processing shall be reported in ITGS. 

C40.  When  recording  the  series  of  interlinked  transactions  only 
the transfer of economic ownership between the initial and 
final  economic  owner  shall  be  reported  following  the 
overall economic effect of the operation. 

C41.  The  partner  country  shall  be  the  Member  State  or  non-
the 
member  country  where 
vessel/aircraft  who  is  transferring  the  ownership/to  whom 
the ownership is transferred, is established. 

the  economic  owner  of 

C42.  The  partner  country  in  case  of  arrival/import  of  a  new 
vessel/aircraft  shall  be  the  Member  State/non-member 
country of construction. 

C43.  The partner country for vessels/aircraft sent for processing 
shall be the Member State/non-member country where the 
processor is established. 

C44.  Member  States  undertaking  the  processing  shall  record 
the 
the  Member  State/non-member  country  where 
economic  owner  of 
the  vessel/aircraft  undergoing 
processing is established. 

C45.  In case of partial sales of the vessel/aircraft which result in 
the transfer of economic ownership, the full value shall be 
reported. 

563 

563 

567 

569 

571 

572 

572 

574 

C46.  Given  that  the  voyage  charter  has  been  verified,  this 

596 

arrangement shall not be included in ITGS. 

C47.  Given 

that 

the 

time  charter  has  been  verified, 

this 

596 

arrangement shall not be included in ITGS. 

C48.  Given  that  the  wet  lease  contract  of  an  aircraft  has  been 

verified, this arrangement shall not be included in ITGS. 

C49.  Given  that  the  financial  leasing  contract  of  an  aircraft  has 
been verified, this arrangement shall be included in ITGS. 
C50.  Given  that  the  operational  leasing  contract  of  an  aircraft 
has been verified, this arrangement  shall not be included 
in ITGS. 

C51.  The  investment  goods  for  the  construction  or  technical 
installation  and  goods 
the  offshore 
improvement  of 
acquired  or  produced  by  the  offshore  installation  shall  be 
recorded with appropriate CN codes. 

C52.  Military  goods  shall  be  included  in  intra-EU  and  extra-EU 
trade  statistics  and  standard  statistical  methods  and  rules 
shall be applied. 

C54.  Since  the  coastal  states  have  the  right  to  authorize  and 
regulate  drilling  on  the  their  continental  shelf  where  these 
rights  are  allocated  to  a  Member  State,  for  statistical 
recording  the  statistical  territory  of  that  Member  State 
should be extended to the continental shelf. 

C55.  The  reporting  Member  State  and  partner  country  Member 
States  for  the  investment  goods  for  the  construction  or 
technical improvement of the offshore installation or goods 
acquired  or  produced  by  the  offshore  installation  should 
be determined according to rules valid for goods delivered 
to offshore installation. 

C56.  The substance of the transaction, not a title of the contract, 
shall  be  considered  in  order  to  identify  the  economic 
owner of the vessels and aircraft [former R7]. 

598 

598 

598 

647 

706 

633 

647 

Annexes   

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

New 
2015 

New 
2015 

548, 593, 595 

2015 

Compilers guide on European statistics on international trade in goods 

183 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C57.  When  the  list  of  indicative  criteria  as  referred  to  in 
paragraph 551 is used to decide on the economic owner of 
a  vessel/aircraft  as  many  criteria  as  possible,  depending 
on  the  availability  of  information,  shall  be  evaluated 
[former R8]. 

C58.  When  the  business  accounts  are  used  to  decide  on  the 
economic  owner  and  national  acts  define  the  accounting 
standards, 
leasing 
arrangements, in line with the substance of IAS17 then the 
intention  of  an  entity  to  include/exclude  vessel/aircraft  as 
an asset in/from its balance sheet shall indicate that there 
is a transfer of economic ownership. 

in  particular 

related 

those 

to 

552 

554 

5. PARTICULAR TRADE FLOWS 

REQUIREMENTS 

L34.  NSAs are required to ensure that any goods in transit are 

711 

not recorded in ITGS. 

Reg. No 638/2004, 
Art. 3  
Reg. No 471/2009, 
Art. 3 

RECOMMENDATIONS 

R11.  It  is  recommended  that  NSAs  do  not  collect  information 
on  arrivals  in  case  of  quasi-export  from  traders  or  from 
declarants,  whenever  the  information  provided  in  the 
customs  declaration  is  sufficient  to  derive  an  adequate 
arrival record in Intrastat. 

ENCOURAGEMENTS 

E28.  NSAs  are  encouraged  to  inform  the  PSIs  about  their 
Intrastat  reporting  obligations  where  customs  clearance 
does  not  take  place  in  the  Member  State  of  actual  export 
or final destination. 

E29.  NSAs  are  encouraged  to  use  customs  information  on  all 
goods declared for customs procedures 42 and 63 at least 
for completeness checks i.e. whether goods were declared 
later as dispatches on the Intrastat declaration and on the 
VIES declaration. 

E30.  NSAs  are  encouraged  to  use  data  from  the  customs 
declarations  for  compiling  the  missing  Intrastat  arrivals  in 
case of quasi-export. 

COMPILATION RULES 

C53.  Whenever 

the  export  declaration  does  not  contain 
information  on  the  Member  State  of  actual  export,  the 
Member  State  of  dispatch  should  be  derived  from  SAD-
box 2, otherwise the simplified country code QV should be 
used. 

740 

736 

737 

740 

742 

6. THRESHOLDS WITHIN INTRASTAT SYSTEM 

REQUIREMENTS 

L20.  NSAs are required to transmit data on the statistical value 
to  Eurostat  although  the  collection  of  the  statistical  value 
from companies remains optional. 

L21.  NSAs  are  required  to  send  the  information  on  the 
thresholds  applied  by  them  to  Eurostat  no  later  than 
31 October  of  the  year  preceding  the  year  to  which  they 
apply. 

L22.  NSAs  are  required  to  transmit  estimates  of  trade  below 
the  exemption  threshold,  and  late  and  non-response  at 
least at chapter level and by partner country. 

L35.  Member States are required to determine the exemption 
threshold each year in annual values in such way that that 
at least 97% of the total dispatches and at least 93% of the 
total  arrivals,  expressed  in  value,  of  the  relevant  Member 
State’s taxable persons is provided. 

751 

761 

Reg. No 638/2004, 
Art. 12(1) 

Reg. No 638/2004, 
Art. 10(6) 

762, 826 

Reg. No 1982/2004, 
Art. 25(3) 

752 

Reg. No 638/2004, 
Art. 10 

Annexes   

2015 

New 
2015 

2005 

2006 

2014 

2014 

2014 

2014 

2014 

2005 

2005 

2005 

2005 

Compilers guide on European statistics on international trade in goods 

184 

 
 
 
 
 
 
 
 
 
 
 
L36. Member  States  are  required  when  applying  simplification 
threshold  to  determine  it  in  such  way  that  that  a  maximum 
6%  of  the  total  dispatches  and  arrivals  is  affected  by  the 
simplification. 

764, 752 

Reg. No 1982/2004, 
Art. 13(3a) 

2005 

Annexes   

754 

755 

2014 

2014 

756 

Reg. No 1982/2004, 
Art. 13(1) 

2014 

757, 767 

2014 

R12.  It 

is  recommended  that  NSAs  set 

RECOMMENDATIONS 
the  exemption 
threshold  in  line  with  certain  quality  requirements,  i.e. 
NSAs  should  examine  whether  the  exemption  of  the  PSIs 
below  the  threshold  will  lead  to  a  considerable  lack  of 
information  or  to  biased  information  as  regards  the  flow, 
the  trade  with  certain  partner  Member  States  and  certain 
commodities. 

R13.  It  is  recommended  that  NSAs  determine  the  exemption 
threshold in such a way that the largest number of traders 
is  exempted  from  providing  information  to  the  Intrastat 
system, to  reduce burden, and by simultaneously keeping 
the quality of the collected information. 

R14.  It  is  recommended  that  NSAs  when  calculating  the  total 
trade use cumulative total value based on the most recent 
data available at the time of calculation of thresholds over 
a  period  of  at  least  12  months  taking  into  account 
additional information provided in the paragraph 756. 

R15.  It 

is  recommended  that  NSAs  use 

the  procedure 
described  in  paragraph  757  for  the  determination  of  the 
level of the exemption threshold and in paragraph  767 for 
the simplification threshold. 

E31.  NSAs  are  encouraged  not  to  calculate  the  exemption 
threshold  exactly  to  the  point,  as  a  ‘safety  margin’  should 
be left for the remaining non-response and the fluctuations 
in the economic activity. 

ENCOURAGEMENTS 

E32.  NSAs are encouraged to provide PSIs with a possibility of 
transactions. 
simplified 
However,  Member  States  must  ensure 
the 
simplification  is  not  abused  and  that  the  quality  of  the 
statistical results is not damaged as a result. 

reporting  on  small 

individual 

that 

758 

773 

7. THRESHOLDS APPLICABLE IN EXTRA-EU TRADE 

ENCOURAGEMENTS 

E34.  NSAs  are  encouraged  to  apply  the  simplification  for 
compilation of extra-EU trade statistics only where it would 
not  lead  to  negative  effects  on  the  availability  of  data  at 
detailed level. The statistical value where the ‘value of the 
goods’  is  not  available  should  be  used  as  criterion  for 
application of the simplification. 

E35.  Customs are encouraged to actively involve NSAs in the 
threshold 

the  postal  consignment 

fixing 

process  of 
applicable in Customs. 

778 

784 

L37.  NSAs  are 

required 
questionnaire annually. 

to  provide  completed  quality 

791 

8. QUALITY 

REQUIREMENTS 

Reg. No 638/2004, 
Art. 13(2) 
Reg. No 1982/2004, 
Art. 26(3) 
Reg. No 471/2009, 
Art. 9(2) 
Reg. No 92/2010, 
Art. 3(3) 

2014 

2014 

2014 

2014 

2005 

2010 

Compilers guide on European statistics on international trade in goods 

185 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RECOMMENDATIONS 

resources,  NSAs 

R16.  It  is  recommended  that,  within  the  limit  of  available 
the 
human 
asymmetries  related  to  the  main  partner  countries  and 
major/key  products  and  react  as  quickly  as  possible  to 
unexpectedly  high  or  new  asymmetries  by  checking  the 
accuracy  and  completeness  of  the  available  national 
statistical data sources. 

regularly  monitor 

ENCOURAGEMENTS 

E36.  NSAs are encouraged, within the limit of available human 
resources,  to  periodically  conduct  bilateral  or  multilateral 
reconciliation exercises for major/key products and to take 
any measures to ensure the success of such exercises. In 
particular,  this  means  that  any  necessary  information  — 
data  and  metadata  —  should  be  made  available  to  the 
partner(s) within the legal limits. 

9. CONFIDENTIALITY 

REQUIREMENTS 

L38.  NSAs are required to transmit to Eurostat data which are 

confidential. 

L39.  NSAs  are  required  to  apply  active  confidentiality  when 
compiling  and  transmitting  intra-EU  and  extra-EU  trade 
statistics by business characteristics. 

L40.  NSAs  are  required  to  apply  passive  confidentiality  when 
compiling  and  transmitting  monthly  intra-EU  and  extra-EU 
trade statistics.   

L41.  NSAs  are  required  to  suppress  confidential  data  in  such 
way that they may be published at least at chapter level of 
the CN provided confidentiality is thereby ensured. 

R17.  It  is  recommended  that  the  NSAs  grant  confidentiality 
only for a limited time (e.g. the request has to be renewed 
periodically/annually) and only for as few data elements as 
possible (value or quantity, product or partner). 

RECOMMENDATIONS 

R18.  It 

is  recommended 

that  NSAs  establish  national 
instructions which clarify application form and procedures, 
decision  making  process  and  time  limits  to  keep  the  data 
confidential. 

R19.  It is recommended that NSAs suppress a product in such 
a  way  that  as  much  information  as  possible  on  the 
commodity 
the 
confidentiality of the PSI. 

is  published  whilst  still  guaranteeing 

E37.  NSAs  are  encouraged  to  define  the  rules  used  in  the 

evaluation of a request for confidentiality. 

E38.  NSAs  are  encouraged  to  use  confidentiality  flag  '2' 

instead of '1' whenever possible. 

ENCOURAGEMENTS 

Annexes   

793 

2014 

794 

2014 

Reg. No 638/2004, 
Art. 12(1) 

Reg. No 1982/2004, 
Art. 13a(8) 
Reg. No 113/2010, 
Art. 15(9) 

Reg. No 638/2004, 
Art. 11 
Reg. No 471/2009, 
Art. 10, second 
subparagraph 

Reg. No 1982/2004, 
Art. 25(7) 
Reg. No 92/2010, 
Art. 2(5) 

810 

797 

798 

805 

804 

804 

807 

809 

810 

2005 

2010 

2005 

2010 

2005 

2010 

2014 

2014 

2014 

2014 

2014 

2010 

10. DATA TRANSMISSION 

REQUIREMENTS 

L23.  NSAs  are  required  to  transmit  the  first  detailed  trade 
statistics results to Eurostat no later than 70 calendar days 
after the end of the reference month for intra-EU trade and 
no  later  than  40  calendar  days  after  the  end  of  the 
reference month for extra-EU trade. Trade broken down by 
invoicing currency shall be transmitted within three months 
of  the  end  of  the  reference  year.  Statistics  on  trade  by 

823, 843, 844, 
847 

Reg. No 638/2004, 
Art. 12(1) 
Reg. No 1982/2004, 
Art. 13a(7) 
Reg. No 471/2009, 
Art. 8(1) 
Reg. No 113/2010, 

Compilers guide on European statistics on international trade in goods 

186 

 
 
 
 
 
 
 
 
 
 
 
 
business  characteristics  shall  be  transmitted  within  18 
months of the end of the reference year. 

L24.  NSAs  are  required  to  transmit  the  revised  results  when 
monthly results already transmitted to Eurostat are subject 
to revisions. 

L25.  NSAs  are  required  to  transmit  revised  results  no  later 
than the month following the availability of revised data. 

823 

829 

L42.  NSAs  are  required  to  inform  the  public  about  the  major 

842 

revision when they have occurred. 

L43.  NSAs are required to transmit estimates of extra-EU trade 
from delayed or incomplete customs declaration at least at 
chapter level and by partner country. 

R20.  It  is  recommended  that  NSAs  closely  monitor  that  the 
aggregated  results  do  not  deviate  from  the  totals  of  the 
final detailed results transmitted to Eurostat afterwards. 

RECOMMENDATIONS 

R21.  It  is  recommended  that  NSAs  apply  the  transmission 
format  and  rules  as  defined  in  Doc  MET  400  valid  for  a 
given 
implement  all 
amendments  of  the  rules  in  the  national  compilation 
systems when agreed by the ITGS Steering Group. 

reference  year  and 

thus 

to 

826 

818 

814 

R22.  It  is  recommended  that  NSAs  send  the  final  revision  for 
all the months of year N no later than October N+1. 

830 

R26.  It is recommended that NSAs send a pre-announcement 
to  Eurostat  of  revisions  of  a  certain  size  between  two 
subsequent  data  transmissions  if  possible  up  to  1  month 
before the data delivery, otherwise up to 1 week before the 
data  delivery  itself  or  at  the  latest  on  the  day  the  data  is 
sent. 

R27.  When estimates for missing intra-EU trade are compiled at 
CN8 level, it is recommended that NSAs to estimate and 
transmit to Eurostat not only the statistical value but as well 
the  net  mass  and  the  supplementary  quantity  wherever 
relevant. 

R28.  It is recommended that NSAs  compile distinct estimates 
for  trade  below  threshold  and  estimates  for  non/late 
response  and  keep 
the  data 
transmissions to Eurostat by using the threshold indicators 
3  (trade  below  the  exemption  threshold)  and  4  (non/late-
response)  instead  of  indicator  8  (no  distinction  between 
trade below threshold and non/late response). 

this  distinction 

in 

ENCOURAGEMENTS 

E39.  NSAs  are  encouraged  to  avoid  the  conflict  between 
national  instructions  for  data  dissemination  and  the  legal 
EU obligations for data transmission. 

E40.  NSAs are encouraged to adapt their publication timetable 

if they wish to publish trade figures earlier than Eurostat. 

E41.  NSAs  are  encouraged 

the 
necessary  arrangements  if  there  is  a  need  to  revise  data 
for one or more previous periods after the final yearly data 
has been transmitted. 

to  contact  Eurostat 

for 

833, 835 

827 

826 

821 

822 

830 

Art. 15(8) and 16(4) 

Reg. No 1982/2004, 
Art. 25(8) 
Reg. No 471/2009, 
Art. 8(1) 

Reg. No 1982/2004, 
Art. 25(8) 
Reg. No 113/2010, 
Art. 26(3) 

Commission 
Recommendation 
COM(2005)217 

Reg. No 92/2010, 
Art. 2(3) 

Annexes   

2005 

2010 

2012 

2010 

2014 

2014 

2014 

2013 

New 
2016 

New 
2016 

2014 

2014 

2014 

Compilers guide on European statistics on international trade in goods 

187 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annexes   

ANNEX 2  —  Contact  details  of  the  competent 
national authorities 

Member State 

National authorities involved in ITGS 

Belgium 

Bulgaria 

National Bank of Belgium 
National Accounts Institute 
Boulevard de Berlaimont 14 
1000 Bruxelles 
www.nbb.be 

Customs and Excise 
North Galaxy 
K. Albert II Laan, 33 
1030 Brussels 
http://fiscus.fgov.be/interfdanl  

National Statistical Institute 
Division ‘Foreign Trade Statistics’ 
2, P. Volov Str. 
1038 Sofia 
www.nsi.bg 

National Revenue Agency 
Intrastat Directorate 
Bul. Dondukov 52 
Sofia 
www.nra.bg 

National Customs Agency 
47, Rakovski str 
1202 Sofia 
http://customs.bg 

Czech Republic  Czech Statistical Office 

External Trade Statistics Department 
Na padesátém 3261/81 
100 82 Praha 10 - Strasnice 
www.czso.cz 

General Directorate of Customs 
Budějovická   
140 96 Praha 4 
www.cs.mfcr.cz 

Denmark 

Germany 

Estonia 

Ireland 

Statistics Denmark 
External Trade and Balance of 
Payments Section 
Sejrøgade 11 
2100 Copenhagen 
www.dst.dk 

Federal Statistical Office (Destatis) 
Foreign Trade Division 
Gustav-Stresemann-Ring 11 
65189 Wiesbaden 
www.destatis.de 

Statistics Estonia 
Foreign Trade Statistics Service 
Tatari 51 
10134 Tallinn 
www.stat.ee 

Central Statistics Office 
External Trade  
Ardee Rd. Rathmines 
Dublin 6 
www.cso.ie 

Revenue Commissioners 
Customs Division 
Government Offices 
St Conlan's Road 
Nenagh, Co. Tipperary 
www.revenue.ie 

SKAT 
Østbanegade 123 
2100 Copenhagen 
www.skat.dk 

Federal Ministry of Finance 
Am Propsthof 78a 
53121 Bonn 
www.zoll.de 

Estonian Tax and Customs Board 
Lõõtsa 8a 
15176 Tallinn 
www.emta.ee 

Revenue Commissioners 
VIES, Intrastat, Mutual Assistance Office 
Government Offices, Millennium Centre 
Dundalk, Co. Louth 
www.revenue.ie 

Compilers guide on European statistics on international trade in goods 

188 

 
 
 
Annexes   

General Secretariat of Tax and Customs 
Karagiorgi Servias 10 
105 62 Athens 
www.gsis.gr 

Member State 

National authorities involved in ITGS 

Hellenic Statistical Authority (ELSTAT)  
General Directorate of Statistical 
Surveys 
Division of Statistics on Trade and 
Services - External Trade Section 
Pireos 46 & Eponiton 
18510 Pireas 
www.statistics.gr 

State Revenue Agency 
Customs and Excise Department 
Avenida Llano Castellano, 17 
28071 Madrid 
www.aeat.es 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Directorate General of Customs and Excise 
Department of Statistics and Economic Studies 
11, rue des Deux Communes 
93558 Montreuil Cedex 
www.douane.gouv.fr 

Croatian Bureau of Statistics 
External Trade in Goods Statistics Dept. 
Ilica 3 
10000 Zagreb 
www.dzs.hr 

Customs Directorate 
Alexandera von Humboldta 4a 
10000 Zagreb 
www.carina.hr 

National Statistical Institute 
Statistics on Foreign Trade and 
Enterprise International Activities 
Division 
Via Cesare Balbo 16 
00184 Rome 
www.istat.it 

Statistical Service of Cyprus 
Foreign Trade Section 
Michalaki Karaoli Str. 
1444 Nicosia 
www.mof.gov.cy/cystat 

Customs and Excise Department 
M. Karaoli & Gr. Afxentiou corner 
1096 Nicosia 
www.mof.gov.cy/customs 

Central Statistical Bureau of Latvia 
Foreign trade statistics data collection 
and processing section 
Foreign trade statistics methodology, 
analysis and dissemination section 
Lāčplēša street   
1301 Riga 
www.csb.gov.lv 

Customs Agency 
Via Mario Carucci, 71 
00143 Rome 
www.agenziadogane.gov.it 

VAT Service 
Intrastat Section 
39 Themistoklis Dervis Str. 
1066 Nicosia 
www.mof.gov.cy/vat 

State Revenue Service 
Talejas iela 1 
1978 Riga 
www.vid.gov.lv 

Lithuania 

Statistics Lithuania 
Foreign Trade Statistics Division 
29 Gedimino Av. 
01500 Vilnius 
www.stat.gov.lt 

Customs Department under the Ministry 
of Finance of the Republic of Lithuania 
A. Jakšto str.  
01105 Vilnius 
www.cust.lt 

Compilers guide on European statistics on international trade in goods 

189 

 
 
 
Annexes   

Member State 

National authorities involved in ITGS 

Luxembourg 

STATEC 
External Trade Unit 
13, rue Erasme 
1468 Luxembourg 
www.statec.lu 

Customs and Excises Directorate 
22, rue de la Bitbourg 
1273 Luxembourg 
www.do.etat.lu 

Hungarian Central Statistical Office 
Foreign Trade Statistics Department 
Keleti Károly Str. 5–7 
1024 Budapest 
www.ksh.hu 

National Tax and Customs 
Administration of Hungary 
Széchenyi u. 2 
1054 Budapest 
www.vam.hu 

Hungary 

Malta 

Netherlands 

National Statistics Office 
Lascaris 
VLT 2000 Valletta 
www.nso.gov.mt 

Department of Customs 
Custom House 
Lascaris Wharf 
VLT 1920 Valletta 
http://finance.gov.mt 

Statistics Netherlands 
CBS-weg 11 
6412 EX Heerlen 
www.cbs.nl 

Austria 

Statistics Austria 
Foreign trade 
Guglgasse 13 
1110 Vienna 
www.statistik.at 

Poland 

Portugal 

Romania 

Slovenia 

Central Statistical Office 
Foreign Trade Section 
1. Niepodległości     
00-925 Warsaw 
www.stat.gov.pl 

National Statistical Institute 
International Trade, Industry and 
Construction 
Av. Antonio José de Almeida 
1000-043 Lisbon 
www.ine.pt 

National Institute of Statistics 
Foreign Trade Department 
No.16, Libertăţii Avenue, District 5 
050706 Bucharest 
www.insse.ro 

Statistical Office of the Republic of 
Slovenia 
External Trade Statistics 
Litostrojska cesta 54 
1000 Ljubljana 
www.stat.si 

VAT Department 
16, Centre Point Building 
Triq ta' Paris 
Birkirkara BKR 4633 
www.vat.gov.mt 

Customs Administration of the 
Netherlands 
Postbus 3070 
6401 DN Heerlen 
www.belastingdienst.nl 

Federal Ministry of Finance 
Directorate General Customs and 
International & Organisational Tax 
Issues 
Johannesgasse 5 
1010 Vienna 
https://www.bmf.gv.at 

Ministry of Finance 
Customs Service 
ul. Świętokrzyska    
00-916 Warsaw 
www.mf.gov.pl 

Tax and Customs Authority 
Praça do Comércio 
1100-016 Lisbon 
www.e-financas.gov.pt 

National Authority of Customs 
Str. Matei Millo 13, sector 1 
010144 Bucharest 
www.customs.ro 

Customs Administration of the Republic 
of Slovenia 
Šmartinska cesta    
1523 Ljubljana 
www.carina.gov.si 

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Member State 

National authorities involved in ITGS 

Slovakia 

Finland 

Sweden 

Statistical Office of the Slovak Republic 
Department of External Trade Statistics 
Miletičova   
824 67 Bratislava 
www.statistics.sk 

Financial Directorate of the Slovak 
Republic 
Customs Section 
Mierová 23 
815 11 Bratislava 
www.financnasprava.sk 

National Board of Customs 
Foreign Trade and Taxation Statistics Unit 
Erottajankatu 2 
FI-00101 Helsinki 
www.tulli.fi 

Statistics Sweden (SCB) 
Foreign Trade & Industry indicators 
Box 24 300 
104 51 Stockholm 
www.scb.se 

Swedish Customs 
Alströmergatan 39 
Box 12 854 
112 98 Stockholm 
www.tullverket.se 

United Kingdom  HM Revenue & Customs — Trade 

Statistics 
Alexander House 
21 Victoria Avenue 
SS99 1AA Southend on Sea 
www.uktradeinfo.com 

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ANNEX 3 — Allocation of customs procedure to 
type of trade and statistical procedure 

A.  General remarks 
Information provided in this annex concerning customs provisions refers to the legal situation as for end 
of 2011. 
DG TAXUD  has  issued  SAD  Guidelines(1)  to  ‘ensure  uniform  implementation  and  a  common 
understanding  of  the  legislation  concerning  the  SAD  on  the  part  of  Member  States'  customs 
administrations  and  traders.’  The  guidelines  on  CPC  (SAD box  37 (1),  however,  do  not  necessarily 
contain  all  legally  valid  customs  procedures  and  their  combinations.  The  aim  of  the  present  annex, 
however,  is  to  include  the  combinations  most  frequently  actually  used  by  national  Customs  to 
correctly allocate the respective trade to the appropriate statistical regime. Therefore, where necessary, a 
comment is made in the allocation-table under the respective CPC. 
As  CPC  may  sometimes  reflect  national  customs  practices,  NSI  need  to  assess  to  what  extent  a  CPC 
reflects EU provisions or purely national provisions. 

Instructions for the use of this annex 

B. 
CPCs result from customs provisions and are laid down in Annex 38 of Commission Regulation (EEC) 
No 2454/93.  The  CPCs  refer  not  only  to  different  aspects  of  customs  procedures  but  also  to  VAT  and 
excise duties. While a majority of codes cover imports or exports relevant for  extra-EU trade statistics; 
some concern also intra-EU goods movements to or from the EU's VAT-exempt fiscal territories. Only a 
few codes refer to movements not to be collected under intra- or extra-EU trade statistics. 
This annex and the allocation of CPCs to statistical procedures are not applicable where rules on specific 
goods  or  movements  have  set  up  different  rules  for  the  compilation  of  trade  re-defining  some 
imports/arrivals  and  exports/dispatches  independently  from  the  customs  procedures  and  physical 
movements of these goods. 

Example 78  
Machinery equipment is exported under customs export (CPC '1000') from a Member State to an offshore installation This movement has to be 
assessed with respect to goods delivered to offshore installations and might, where applicable, fall under extra-EU trade, intra-EU trade or even 
be out of scope of trade statistics. 

C.  SAD Box 37 — 1st subdivision 
Box 37: Procedure — First subdivision 

The  codes  to  be  entered  in  this  subdivision  are  four-digit  codes,  composed  of  a  two-digit  code 
representing  the  procedure  requested,  followed  by  a  second  two-digit  code  representing  the  previous 
procedure. The list of two-digit codes is given below. 

‘Previous procedure’ means the procedure under which the goods were placed before being placed under 
the procedure requested. 

It  should  be  noted  that  where  the  previous  procedure  is  a  warehousing  procedure  or  temporary 
importation, or where the goods have come from a free zone, the relevant code should be used only where 
the  goods  have  not  been  placed  under  a  customs  procedure  with  economic  impact  (inward  processing, 
outward processing or processing under customs control). 

For  example:  re-export  of  goods  imported  under  the  customs  inward  processing  procedure  (suspension 
system)  and  subsequently  placed  under  the  customs  warehousing  procedure  =  3151  (not  3171).  (First 
operation = 5100; second operation = 7151: re-export = 3151). 

(1)  http://ec.europa.eu/taxation_customs/customs/procedural_aspects/general/sad/article_5268_en.htm 

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Similarly,  where  goods  previously  temporarily  exported  are  re-imported,  placing  under  one  of  the 
abovementioned  suspensive  procedures  is  to  be  regarded  as  simple  importation  under  that  procedure. 
Indication  of  the  ‘re-importation’  aspect  is  to  be  given  only  when  the  goods  are  released  for  free 
circulation. 

For example: entry for home use with simultaneous entry for free circulation of goods exported under the 
customs  outward  processing  procedure  and  placed  under  a  customs  warehousing  procedure  on  re-
importation = 6121 (not 6171). (First operation: temporary export for outward processing = 2100; second 
operation:  storage  in  customs  warehouse  =  7121;  third  operation:  entry  for  home  use  +  entry  for  free 
circulation = 6121). 

The  codes  marked  in  the  list  below  with  the  letter  (a)  cannot  be  used  as  the  first  two  digits  of  the 
procedure code, but only to indicate the previous procedure. 

For example: 4054 = entry for free circulation and home use of goods previously placed under the Inward 
processing — suspension system in another Member State 

D.  SAD Box 1 — 1st subdivision 
The meaning of a given CPC must also to be assessed in relation to the content of SAD-box 1, 
1st subdivision which contains information on the declaration type. 

Box 1: Declaration — First subdivision 

EX 

IM 

EU 

CO 

For trade with countries and territories situated outside of the customs territory of the Community 
other than the EFTA countries 
For placing goods under a customs procedure […] 
To confer on goods a customs-approved treatment or use […] 
For dispatch of non-Community goods in the context of trade between Member States 

For trade with countries and territories situated outside of the customs territory of the Community 
other than the EFTA 
For placing goods under a customs procedure […] 
For placing non-Community goods under a customs procedure […] 

In the context of trade with EFTA countries   
For placing goods under a customs procedure […] 
To confer on goods a customs-approved treatment or use […] 

In  respect  of  Community  goods  subject  to  specific  measures  during  the  transitional  period 
following the accession of new Member States 
Placing of goods under the customs warehousing procedure in order to obtain payment of special 
export refunds prior to exportation or manufacturing under customs supervision and under customs 
control prior to exportation and payment of export refunds. 
In respect of Community goods in the context of trade between parts of the customs territory of the 
Community  to  which  the  provisions  of  Directive  77/388/EEC  are  applicable  and  parts  of  that 
territory to which those provisions do not apply, or in the context of trade between parts of that 
territory where those provisions do not apply. 

Where appropriate, an explicit reference to one of the above codes is made in the CPC-allocation table. 

E.  SAD box 37 — 2nd subdivision 
This  information  shall,  on  the  customs  declaration,  concretely  specify  an  EU  or  a  national  procedure; 
where applicable, a code composed of an alphabetic character followed by two alpha-numeric characters 
must be used. 
The first character of which identifies a category of measures in the following manner: 

Inward processing  
Outward processing  
Relief  

Axx 
Bxx 
Cxx 

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Temporary import  
Agricultural products 
Other  
Codes for national use are possible as well 

Dxx 
Exx 
Fxx 

Although the information in SAD-box 37(2) could be relevant to decide if a given CPC is to be included 
in extra- or intra-EU trade statistics, it needs to be stressed that this box might also contain a national code 
or,  where  several  codes  would  be  applicable,  only  one  (!)  code  might  be  entered  due  to  format 
restrictions; as a ‘workaround’ the other codes might appear in SAD-box 44. 
Non-exhaustive overview on relevant EU codes: 
e.g.  identification of exclusion of ‘repair’ under customs outward processing 
—  Compensating products returning after repair under guarantee: 
—  Compensating products returning after replacement under guarantee: 
—  Goods imported for inward processing exported for repair under outward processing: 
—  Goods imported for inward processing exported for replacement under guarantee: 

B02 
B03 
B51 
B52 

e.g.  identification of exclusion of ‘advertising material’ where duty relief is granted 

—  Advertising material imported for trade promotion purpose: 

C31 

Note:  The  information  encoded  in  the  respective  3-digit  codes  is  likely  to  be  applicable  only  in  the 
clearance cases referred to (e.g. goods sent abroad for or returning after repair but which are not covered 
by a customs outward processing procedure will not have the respective code in SAD-box 37(2). 

Legend to the tables 

F. 
Statistical procedures 
1 — normal imports or exports, 
2 — imports or exports covered by the customs inward processing procedure, 
3 — imports or exports covered by the customs outward processing procedure, 
9 — imports or exports not recorded from customs declarations. 

Column headings 
A:  The four digits CPC of the customs declaration; 

or the explanation on the requested procedure (1st + 2nd digit) 

B:  The previous procedure (3rd + 4th digit) 
C:  Explanation of the previous procedure 
Indication whether CPC falls under extra-EU trade 
D: 
E: 
Indication whether CPC falls under intra-EU trade 
F:  CPC falls neither under Extra nor under intra-EU trade 
G: 
H:  Explanation/additional information 

Indication of statistical procedure in extra-EU trade statistics 

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G.  Allocation table for Imports/Arrivals 

ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

'0x' 

Imports of goods under '0x' is used only in case of non-payment of VAT/excise duties 

'01' 

Imports relating in general to release for free circulation (payment of duties) with 
—  a subsequent redispatch to a ‘VAT exempt’ part of the EU's customs territory or 
—  a dispatch to a country with which the EU forms a customs union 

0100  00 =>  no previous procedure 

0121  21 =>  export under the outward 

processing procedure 

x  —  — 

   1 

x  —  — 

   3 

0141  41 =>  goods were under the inward 

processing procedure 
(drawback) 
0151  51 =>  goods were under the inward 

processing procedure (sus-
pension) 

   —  —  x 

   —  Excluded: Reg. No 113/2010, Annex I, 

point (k) — to avoid double counting 

   —  —  x 

   —  See CPC 0141 

0153  53 =>  goods were previously under 

'temporary admission' 

x  —  — 

   1 

0154  54 =>  goods were, in another Member 

State, under the inward 
processing procedure 
(suspension) 
0171  71 =>  goods came from a customs 
warehouse 
0178  78 =>  goods came from a free zone 

comparable to a (customs ware-
house) 

   —  x  — 

   —  Excluded: Reg. No 113/2010, Annex I, 

point (k) 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 

x  —  — 

   1 

x  —  — 

   1 

0191  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

0192  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs con-
trol’  

   —  —  x 

   —  See CPC 0151 

   —  x  — 

   —  See CPC 0154 

'02' 

Imports relating to free circulation but with application of the inward processing procedure (drawback 
system) (See code 41) [remark: code '02' not included in the DG TAXUD SAD guidelines]  

0200  00 =>  no previous procedure 

0271  71 =>  goods came from a customs 
warehouse 
0278  78 =>  goods came from a free zone 

x  —  — 

   2 

x  —  — 

   2 

x  —  — 

   2 

 '07'  

Imports relating to free circulation but with placing the goods under a tax/excise warehouse 

0700  00 =>  no previous procedure 

0721  21 =>  export under the outward proc-

essing procedure 

0741  41 =>  goods were under the inward 

processing procedure 
(drawback) 

x  —  — 

   1 

x  —  — 

   3 

   —  —  x 

   —  Excluded: Reg. No 113/2010, Annex I, 

point (k) 

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ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

0751  51 =>  goods were under the inward 

processing procedure (suspen-
sion) 

   —  —  x 

   —  See CPC 0741 

0753  53 =>  goods were previously under 

0754 

'temporary admission' 
54 =>  goods were, in another Member 
State, under the inward 
processing procedure 
(suspension) 
0771  71 =>  goods came from a customs 
warehouse 
0778  78 =>  goods came from a free zone 

0791  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

0792  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs con-
trol’  

 '4x' 

Imports into free circulation 

x  —  — 

   1 

  —  x  — 

  —  Excluded: Reg. No 113/2010, Annex I, 

point (k) 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 

x  —  — 

   1 

x  —  — 

   1 

   —  —  x 

   —  See CPC 0751 

   —  x  — 

   —  See CPC 0754 

 '40' 

Imports  relating  to  release  for  free  circulation  and  home  use  (~  payment  of  customs  duties,  VAT  and 
excise duties) 

4000  00 =>  no previous procedure 

x  —  — 

   1 

4010  10 =>  goods return after permanent ex-

port 

x  —  — 

   1  Remark: CPC '4010' not included in the 

DG TAXUD SAD-guidelines. 

4041  41 =>  goods were under the inward 

processing procedure 
(drawback) 
4051  51 =>  goods were under the inward 

processing procedure (suspen-
sion) 

   —  —  x 

   —  Excluded: Reg. No 113/2010, Annex I, 

point (k) 

   —  —  x 

   —  See CPC 4041 

4053  53 =>  goods were under the temporary 

admission procedure 

x  —  — 

   1 

4054  54 =>  goods were, in another Member 

State, under the inward 
processing procedure 
(suspension) 
4071  71 =>  goods came from a customs 
warehouse 
4078  78 =>  goods came from a free zone 

comparable to a (customs ware-
house) 

   —  x  — 

   —  Excluded: Reg. No 113/2010, Annex I, 

point (k) 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 

x  —  — 

   1 

x  —  — 

   1 

4091  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

4092  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs con-
trol’  

   —  —  x 

   —  See CPC 4051 

   —  x  — 

   —  See CPC 4054 

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ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

 '41' 

Imports relating to release for free circulation and home use but with application of the customs 
inward processing procedure (drawback system) 

4100  00 =>  no previous procedure 

x  —  — 

   2 

4121  21 =>  export under the outward proc-

essing procedure 

x  —  — 

   2  See also CPC 2141 

Outward processing was an intermediate 
action within the inward processing 
activity. 

4141  41 =>  goods were under the inward 

processing procedure 
(drawback) 
4151  51 =>  goods were under the inward 

processing procedure (suspen-
sion) 

4153  53 =>  goods were under the temporary 

admission procedure 

4154  54 =>  goods were, in another Member 

State, under the inward 
processing procedure 
(suspension) 
4171  71 =>  goods came from a customs 
warehouse 
4178  78 =>  goods came from a free zone 

4191  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

4192  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs 
control’  

   —  —  x 

   —  To avoid double counting. 

   —  —  x 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 

x  —  — 

   2 

   —  x  — 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3); 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 

x  —  — 

   2 

x  —  — 

   2 

   —  —  x 

   —  See CPC 4151 

   —  x  — 

   —  See CPC 4154 

 '42' 

42xx 

Imports  relating  to  free  circulation  and  home  use,  however,  with  VAT-exempt  supply  to  another 
Member State 
xx =>  All previous procedure as under CPCs 40xx; 

Compared to code 40, imports under CPCs 42 are, after their release for free circulation, immediately 
dispatched to another Member State under a VAT exemption scheme; 

For allocation to a trade type and a statistical procedure, see the respective 40xx-codes. 

 '43' 

43xx 

Imports relating to free circulation and home use of goods for which specific transition measures 
following the accession of a new Member State apply (e.g. residual customs duties or agricultural levies) 
xx =>  All applicable previous procedure as under CPCs 40xx; where applicable, trade is to be allocated to 

INTRA-EU trade. 

 '45' 

Imports relating to free circulation and home use, however with placement under a VAT warehouse (-
> no payment of VAT or excises duties) 

45xx 

xx =>  All previous procedure as under CPCs 40xx  

 '48' 

Imports for free circulation of goods as so-called prior importation, under the customs outward 
processing procedure; 
Note:  Code  '48'  concerns  most  likely  cases  of  repair;  this  would  need  to  be  assessed  by  NSIs  to  exclude  the  flow  from 
statistics! However, where this code refers to replacements of faulty goods the transaction would need to be included. 

4800  00 =>  no previous procedure 

4871  71 =>  goods came from a customs 
warehouse 

x  —  — 

   3 

x  —  — 

   3 

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ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

4878  78 =>  goods came from a free zone 

x  —  — 

   3 

 '49'  Entry for home use 

—  of Community goods as arrival from a ‘VAT-exempt’ part of the EU's customs territory 
—  of goods in the context of trade with third countries with which the EU has formed a customs 

union 

4900  00 =>  no previous procedure 

   x  —  — 

   1 

Imports under customs union provisions, 
e.g. Andorra; ‘IM’ in SAD-box 1(1) 

4901  01 =>  goods were previously imported 

for free circulation with 
subsequent redispatch to a ‘VAT 
exempt’ part of the EU's customs 
territory 

4910  10 =>  goods imported after permanent 

export as normal export of 
Community goods to a third 
country 

goods imported after dispatch of 
Community goods to a ‘VAT-
exempt’ part of the EU's customs 
territory 

   —  x 

   —  Arrival of Community goods from ‘VAT-
exempt’ EU customs territory, e.g. 
Canary Islands (SPAIN); ‘CO’ in SAD-
box 1(1) 

   —  x  — 

   — 

   x  —  — 

   1  Previous export to a third country: ‘EX’ or 

‘EU’ in SAD-box 1(1) 

x  — 

   —  Previous intra-EU dispatch: ‘CO’ in SAD-

box 1(1) 

4971  71 =>  goods came from a customs 
warehouse 

   x  —  — 

   1  See CPC 4900; 

Allocation to EXTRA-EU trade as only 
non-Community goods can be placed 
under the customs warehousing 
procedure. 

4978  78 =>  goods came from a free zone 

   x  —  — 

   1  See CPC 4971 

 '51' 

Imports relating to the customs inward processing procedure (suspension system)  
(=Temporary import of dutiable goods with suspension of EU's trade measures/duties for processing and 
subsequent re-exportation) 

5100  00 =>  no previous procedure 

   x  —  — 

   2 

5111  11 =>  prior export of compensating 

products, before placing of the 
imported goods under the inward 
processing procedure 

   x  —  — 

   2 

5121  21 =>  export under the outward 

processing procedure 

   x  —  — 

   2  See also CPC 2151 

Outward processing was an intermediate 
action within the inward processing 
activity. 

5122  22 =>  export under economic 

processing aspects 

5141  41 =>  goods were previously released 

for free circulation and home 
under the inward processing 
procedure (drawback system)  

   x  —  — 

   2  Although the previous export was under 

economic processing aspects, trade shall 
be allocated to '2'  

   —  —  x 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 

5151  51 =>  goods were under the inward 

processing procedure 

   —  —  x 

   —  See CPC 5141 

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ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

(suspension) 

5153  53 =>  goods were under the temporary 

admission procedure 

   x  —  — 

   2 

5154  54 =>  goods were, in another Member 

State, under the inward 
processing procedure 
(suspension) 
5171  71 =>  goods came from a customs 
warehouse 

5178  78 =>  goods came from a free zone 

(comparable to a customs 
warehouse) 

5191  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

5192  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs 
control’  

   —  x  — 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 

   x  —  — 

   2 

   x  —  — 

   2 

   —  —  x 

   —  See CPC 5141 

   —  x  — 

   —  See CPC 5154 

 '53'  Temporary admission  

(Temporary import for the authorised use with suspension of EU trade measures under the obligation for later 
re-exportation in an unaltered state) 

53xx 

xx =>  all possible previous procedures 

   —  —  x 

5354  54 =>  goods were, in another Member 

State, under the inward 
processing procedure 
(suspension) 

   —  —  x 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 

   —  Although arrival is under the scope of 
INTRA-EU trade (Reg. No 638/2004, 
Art. 3), the goods should be excluded as 
‘temporary use’ (Reg. No 1982/2004, 
Annex I, point (c)  

5392  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs 
control’  

   —  —  x 

   — 

 '6x'  Re-importation for free circulation 

For re-importation, in principle the same logic applies as for comparable codes 4xxx; the difference being that 
under  re-importation  the  goods  were,  except  for  so-called  returned  goods,  previously  exported  with  view  to 
later re-importation; therefore code 6x must have a previous ‘export’ procedure)  

'61'  Re-imports relating to free circulation and home use (=> payment of VAT and excise duties) 
6110  10 =>  goods imported after permanent 

   1  Returned goods in the sense of customs 

   x  —  — 

provisions (CCC, Art. 185) 

export as normal export of 
Community goods to a third 
country 
6121  21 =>  export under the outward 

processing procedure 
6122  22 =>  export under economic 

processing aspects 

   x  —  — 

   3 

   x  —  — 

   1  Code '22' relates to exports for economic 
processing; such exports are not covered 
by a customs outward processing 
procedure. 

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Annexes   

ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

6123  23 =>  goods were temporarily exported 

for return in the unaltered state 

   —  —  x 

   — 

6171  71 =>  goods came from a customs 
warehouse 

   —  —  x 

   —  CPC '6171' can logically only refer to 
goods re-imported after a temporary 
export '23xx'  

6178  78 =>  goods came from a free zone 

(comparable to a customs 
warehouse) 

   —  —  x 

   —  See CPC 6171 

'63'  Re-imports  relating  to  free  circulation  and  home  use,  however  with  VAT-exempt  supply  to  another 

Member State 
xx =>  All previous procedures as under 61xx 

63xx 

Compared to 61, imports under 63 are, after their release for free circulation, immediately dispatched 
to another Member State under a VAT exemption scheme; 

For allocation to a trade type and a statistical procedure, c.f. the respective 61xx-codes; see also 42. 

'68'  Re-imports  relating  to  free  circulation  and  home  use,  however,  with  placement  under  a  VAT 

warehouse 
(-> no payment of VAT or excises duties); 
Code 68 is similar to code 45, the difference being that code 68 is related to re-importation after (temporary) 
exportation.  

6821  21 =>  export under the outward 

processing procedure 

   x  —  — 

   3 

6871  71 =>  goods came from a customs 
warehouse 

   —  —  x 

   —  CPC '6871' can logically only refer to 
goods re-imported after a temporary 
export under CPC '23xx'  

6878  78 =>  goods came from a free zone 

(comparable to a customs 
warehouse) 

   —  —  x 

   —  See CPC 6871 

'71' 

Imports by placement of goods under the customs warehousing procedure 

7100  00 =>  no previous procedure 

7110  10 =>  goods return after permanent 

export 

   —  —  x 

   — 

   —  —  x 

   — 

7121  21 =>  export was under the outward 

processing procedure 

   —  —  x 

   — 

7123  23 =>  goods were temporarily exported 

for return in the unaltered state 

   —  —  x 

   — 

7151  51 =>  goods were under the inward 

processing procedure 
(suspension) 

   —  —  x 

   —  No cross border movement; the goods 
only change their procedural customs 
status within the same Member State; 
final re-exportation would then be under 
CPC '3151'. 

7153  53 =>  goods were under the temporary 

admission procedure 

   —  —  x 

   — 

7154  54 =>  goods were, in another Member 

State, under the inward 
processing procedure 
(suspension) 

7191  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

   —  x  — 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 
See also CPC '3154' 

   —  —  x 

   See CPC '7151' 

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Annexes   

ALLOCATION TABLE MPORTS/ARRIVALS (MOST COMMON CPCS) 

CPC  Meaning of ‘previous procedure’ code 

  Trade type 

Statistical procedure in extra-EU trade 

4-digit 

3rd + 4th digit 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

7192  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs 
control’  

   —  x  — 

   —  See CPC 7154 

'78'   Entry of goods for a Free Zone subject to type II controls (~ similar to a customs warehouse)  

78xx 

xx =>  all previous procedure as 71xx 

'91'  Placing of goods under the procedure of processing under customs control 

Import for processing of good with view to obtaining, under customs supervision, goods that have a lower 
duty rate; the obtained goods are then (usually) cleared for free circulation  

9100  00 =>  no previous procedure 

   x  —  — 

   1 

9151  51 =>  goods were previously under the 

customs inward processing 
procedure  
9171  71 =>  goods came from a customs 
warehouse 
9178  78 =>  goods came from a free zone 

(comparable to a customs 
warehouse) 

   —  —  x 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 

   x  —  — 

   1 

   x  —  — 

   1 

9191  91 =>  goods were under the procedure 

of ‘processing under customs 
control’  

9192  92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs 
control’  

   —  —  x 

   —  To avoid double counting. 

   —  x  — 

   —  Not under the scope of EXTRA-EU trade 

(Reg. No 471/2009, Art. 3) 
Arrival is under the scope of INTRA-EU 
trade (Reg. No 638/2004, Art. 3) 

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Annexes   

H.  Allocation table for Exports/Dispatches 

ALLOCATION TABLE EXPORTS/DISPATCHES (MOST COMMON CPCS) 

CPC 

4-digit 

Meaning of ‘previous procedure’ 
code 

3rd + 4th digit 

  Trade type 

Statistical procedure in extra-EU trade 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

'10' 

1000 

Permanent export of Community goods 
—  export to non-member countries or 
—  a dispatch to a ‘VAT-exempt’ part of the EU's customs territory 
00 =>  no previous procedure 

   x  —  — 

   1  Exports to third countries; ‘EX’, ‘EU’ in 

SAD-box 1(1) 
into  a  victualling 
Note:  The  entry 
warehouse 
(1000F63)  shall  not  be 
recorded.  Only  when  the  goods  finally 
leave such warehouse (e.g. 1000F64) to 
be  taken  on  board  a  ship  or  aircraft,  the 
relevance of the exit is to be considered 
for trade statistics. 
For the customs victualling movement, in 
for 
principle 
specific  movements  would  apply  (as 
goods  delivered 
to  vessels  and 
aircraft,  Reg. No 1982/2004,  Art.  19  or 
Reg. No 113/2010, Art. 20. 

the  statistical  provisions 

   —  x  — 

   — 

Intra-EU dispatch to a ‘VAT-exempt’ part 
of the EU's customs territory, e.g. Canary 
Islands (SPAIN); ‘CO’ in SAD-box 1(1) 

x  —  — 

   1 

x  —  — 

   2 

x  —  — 

   1 

x  —  — 

   1 

x  —  — 

   2 

x  —  — 

   1 

x  —  — 

   1 

1001 

1002 

1007 

1040 

1041 

1042 

1045 

01 =>  goods released for free 

circulation with simultaneous 
redispatch to a ‘VAT-exempt’ 
part of the EU's customs 
territory 

02 =>  goods were under the inward 
processing procedure 
(drawback system) 

07 =>  goods were released to free 

circulation but placed under a 
tax/excise warehouse 

40 =>  goods were previously released 

for free circulation 

41 =>  goods were under the inward 
processing procedure 
(drawback system) 

42 =>  goods were previously released 

for free circulation with a VAT-
except supply to another 
Member State 

45 =>  goods were previously released 

for free circulation but placed 
under a VAT warehouse (-> no 
payment of VAT or excises 
duties) 

1049 

49 => 

./. 

x 

1  CPC 1049 is not possible; however, 
some MSs seem to use this code for 
certain trade with Turkey in the sense of 
CPC 1040. 

1061 

61 =>  goods were previously re-

imported and released for free 
circulation 

x  —  — 

   1 

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Annexes   

ALLOCATION TABLE EXPORTS/DISPATCHES (MOST COMMON CPCS) 

CPC 

4-digit 

Meaning of ‘previous procedure’ 
code 

3rd + 4th digit 

  Trade type 

Statistical procedure in extra-EU trade 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

1063 

1076 

1078 

'11' 

1100 

63 =>  goods were previously re-

imported and released for free 
circulation with a VAT-except 
supply to another Member State 

76 =>  goods were previously placed 

under the customs warehousing 
procedure in order to obtain 
payment of special export 
refunds prior to exportation 

78 =>  goods were previously placed 
under the free zone 
arrangement with view to their 
permanent export 

x  —  — 

   1 

x 

1  See  CPC  7600  and  Example  1  on  the 

general trade system. 

x  —  — 

   1  See CPCs '78xx' 

The entry into free zone was with view to 
repayment/remission of duties. 

Special cases of export as processed goods under the customs inward processing (suspension) 
system (so-called prior exportation) 
00 =>  no previous procedure 

x  —  — 

   2 

'2x' 

Temporary exports 

 '21' 

2100 
2101 

2107 

2140 

2141 

2145 

2151 

2154 

Temporary exports under the customs outward processing procedure  
(-> partial duty relief on re-importation) 

00 =>  no previous procedure 

01 =>  goods released for free 

circulation with simultaneous 
redispatch to a ‘VAT-exempt’ 
part of the EU's customs 
territory 

07 =>  goods were released for free 

circulation but put under a 
tax/excise warehouse 

40 =>  goods were previously released 

for free circulation 

41 =>  goods were under the inward 
processing procedure 
(drawback system) 

45 =>  goods were previously released 

for free circulation but placed 
under a VAT warehouse (-> no 
payment of VAT or excises 
duties) 

51 =>  goods were under the inward 
processing procedure 
(suspension) 

54 =>  goods were, in another Member 
State, under the inward 
processing procedure 
(suspension) 

x  —  — 

   3 

x  —  — 

   3 

x  —  — 

   3 

x  —  — 

   3  CPC 2140 in the meaning of CPC 2100. 

x  —  — 

   2  Not Stat. reg. '3' as the outward 

processing is an intermediate action 
within an ongoing inward processing 
activity. 

x  —  — 

   3 

x  —  — 

   2  See CPC 2141 

x 

(x)  — 

   2  See CPC 2141;  

Remark INTRA: the previous arrival in 
the MS of export is also under the scope 
of INTRA-EU (Reg. No 638/2004, Art. 3) 

 '22' 

Temporary exports for processing, other than under the customs outward processing procedure 
(e.g. economic processing) 

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Annexes   

ALLOCATION TABLE EXPORTS/DISPATCHES (MOST COMMON CPCS) 

CPC 

4-digit 

Meaning of ‘previous procedure’ 
code 

3rd + 4th digit 

  Trade type 

Statistical procedure in extra-EU trade 

a
r
t
x
E

a
r
t
n

I

e
n
o
N

'—' = out of scope 
(CPC is only for explanation) 

A 

B 

C 

  D  E  F 

  G 

H 

2200 

00 =>  no previous procedure 

x  —  — 

   1 

 '23' 

Temporary export for return in the unaltered state 

23xx 

xx =>  any possible previous 

procedure 

   —  —  x 

   —  Excluded: Reg. No 113/2010, Annex I, 

point (c) 

x  —  — 

   2 

x  —  — 

   2 

   —  —  x 

   — 

x 

(x)  — 

   2  Remark  INTRA:  where  applicable,  the 
previous  arrival  in  the  MS  of  export 
would  be  under  the  scope  of  INTRA-EU 
trade  (Reg. No  638/2004,  Art. 3);  if  the 
previous  arrival  was  linked  to  entry  in  a 
customs  warehouse,  the  INTRA-arrival 
indicator would be CPC '7154'  

   —  —  x 

   — 

   —  —  x 

   — 

x  —  — 

   1 

x 

(x)  — 

   1  See CPC 3154 

 '31'  Re-exports of non-Community goods 
3141 

41 =>  goods were under the inward 
processing procedure 
(drawback system) 

51 =>  goods were under the inward 
processing procedure 
(suspension) 

53 =>  goods were under temporary 

admission 

54 =>  goods were, in another Member 
State, under the inward 
processing procedure 
(suspension) 

71 =>  goods were previously in a 
customs warehouse 

78 =>  goods were previously in a free 

zone 

91 =>  goods were under the 

procedure of ‘processing under 
customs control’  

92 =>  goods were, in another Member 

State, under the procedure of 
‘processing under customs 
control’  

3151 

3153 

3154 

3171 

3178 

3191 

3192 

'76' 

7600 

Placing of goods under the customs warehousing procedure in order to obtain payment of special 
export refunds prior to exportation 
00 =>  no previous procedure 

   —  See CPC 1076 and Example 1 on the 

x 

general trade system. 

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ANNEX 4  —  Reconciliation  table  between 
ITGS and BoP statistics 

1. Goods for processing (no change of ownership) 

Annexes   

1.1  Goods  sent  abroad  for  processing  which  return  after  the  processing  to  the  reporting  Member  State  (initial 
Member State of dispatch) 
Intra-EU trade 

BPM5 

Extra-EU trade 

Included on a gross basis 
Reg. No 1982/2004, Art. 8(1) and Annex 
III; 
Identified by NoT code 4 and 5. 
Included on a gross basis 
Reg. No 113/2010, Art. 4(3) and Annex 
II; 
Identified by NoT code 4 and 5. 

Included on a gross basis under the sub-
item ‘Goods for processing’ 
Par. 197 

BPM6 

Excluded from goods (no change of 
ownership) 
Par. 10.22(f) 
Recorded as manufacturing services on 
physical inputs owned by others included 
(par. 10.62) 
Gross values … can be identified as 
supplementary items (par. 10.67) 

1.2  Goods  sent  abroad  for  processing  which  do  not  return  to  the  reporting  MS  (country  A),  but  are  sold  to 
resident of the processing economy (country B)(1)

or to non-member country (country C)(2). 

Intra-EU trade 

Extra-EU trade 

Included on gross basis 
Reg. No 1982/2004, Art. 8(1) and Annex 
III ; 
Identified  by  NoT  code  42  in  country  A 
and 42/52 in country B. 
Included on gross basis 
Reg.  No  113/2010,  Art. 4(3)  and  Annex 
II; 
Identified  by  NoT  code  42  in  country  A 
and 42/52 in country  

BPM5 

Included  under  the  sub-item  ‘Goods  for 
processing’,  but  fictitious  backward  flow 
has  to  be  imputed;  export  of  goods  under 
general  merchandise  has  to  be  recorded 
too. 

BPM6 

BPM6  introduces  the  term  ‘Goods  sold 
abroad after processing’ 

1.3 Goods acquired from other economies for processing abroad 

Intra-EU trade 

Excluded 

Extra-EU trade 

Excluded 

BPM5 

BPM6 

Treatment not specified 

Included 
Par. 10.65(b) 
for 
Purchases  of  materials  necessary 
processing  made 
ordering 
party/principal abroad have to be recorded 
as imports under ‘General merchandise’. 

the 

by 

1.4 Additions and alterations to ships and aircraft (the same operation as 1.1) 

Intra-EU trade 

Extra-EU trade 

Included on a gross basis 
Reg.  No  1982/2004,  Art. 17(2)  (c)  and 
Annex III 
Identified by NoT code 4 and 5 
Included on a gross basis 
Reg.  No113/2010,  Art. 19(2)  (c)  and 
Annex II. 
Identified by NoT code 4 and 5 

BPM5 

BPM6 

Included on a gross basis 
Recorded  under  the  sub-item  ‘Goods  for 
processing’. 
Par. 197 

from  goods  (no  change  of 

Excluded 
ownership) 
Recorded  as  manufacturing  services  on 
physical inputs owned by others included 
Par. 10.62 

(1)  According  to  BPM5,  these  goods  should  be  excluded  from  sub-item  ‘goods  for  processing’  and  should  be  recorded  under  ‘exports  of 
general merchandise’ (with a value corrected to include the value of processing). The payment for the processing has to be entered as a 
debit under ‘services/merchanting and other trade related services’ (BPM5 par. 199). 

(2)  According to BPM5, these goods should be excluded from sub-item ‘goods for processing’ and should also be excluded from the exports of 
goods  from  country  A  to  country  B.  From  country  A  to  country  B  only  a  payment  for  the  processing  has  to  be  entered  (under 
‘services/merchanting’).  These  goods  should  be  recorded  as  exports  of  goods  under  general  merchandise  from  country  A  to  country  C 
including the value of processing (BPM5 par.199, BoP Textbook paras. 186-188). 

Compilers guide on European statistics on international trade in goods 

205 

 
 
 
 
                                                           
2. Repairs on goods (goods for and after repair and the associated replacement parts) 

Annexes   

Intra-EU trade

a)  Excluded 

Reg. No 1982/2004, Annex I, point (h) 

Extra-EU trade

a)  Excluded 

Reg. No 113/2010, Annex I, point (h) 

BPM5 

BPM6 

Included  on  a  net  basis;  recorded  under 
the sub-item ‘Repairs of goods’. 
Par. 200  
Excluded  from  goods,  recorded  under 
services 
Paras. 10.59 and 10.60 
No  adjustment 
excludes correctly. 

is  necessary, 

ITGS 

if 

a) Collected by some Member States for NA purposes 

3.  Goods  procured  in  ports  by  carriers  (fuels,  provisions,  supplies  delivered/bought  to/by  non-resident vessels  or 
aircraft) 

Intra-EU trade

b) 

Extra-EU trade

b) 

Included  in  dispatches,  not  recorded 
in arrivals 
Goods  delivered  on  the  territory  of  the 
reporting  Member  State  to  non-resident 
carriers 
Reg. No 1982/2004, Art. 19 
Identified by product codes 9930 XX 00 

Included  only  in  exports,  not  recorded 
in imports. 
Goods  delivered  on  the  territory  of  the 
reporting  Member  State  to  non-resident 
carriers 
Reg. No 113/2010, Art.20 
May  be 
9930 XX 00, 
applies. 

identified  by  product  code 
national  Customs 

if 

BPM5

c) 

BPM6

c) 

Included in both flows 
Recorded under sub-item ‘Goods procured 
in ports by carriers’ 
Paras. 156 and 201 
Recorded as imports if bought by residents 
abroad, as exports if sold to non-residents 
in the compiling economy. 

Included in both flows 
as part of ‘General merchandise’ (no more 
recorded as the sub-item) 
‘Ports’ are defined widely. 
Goods  provided  to  operators  of  road  and 
rail  transport  services  have  also  to  be 
included. 
Par. 10.17(d) 

b) Only export recorded; partner country allocated according to 
residency of economic owner 

c) Included in ‘Goods’ as a sub-item. 

4. Transfer of ownership of movable equipment not tied to a fix location 

4.1 Transfer of economic ownership of vessels and aircraft 

Intra-EU trade

d) 

Extra-EU trade

d) 

Included 
Reg. No 1982/2004, Art. 17(2) (a) and 
(b) 
Included 
Reg. No 113/2010, Art. 19(2) (a) and (b) 

BPM5

e) 

BPM6

e) 

Included  in  sub-item  ‘General  Merchan-
dise’.  
Par. 208 
Included  in  sub-item  ‘General  Merchan-
dise’ 
Par. 4.136 
The  principle  was  established  by  BPM5 
par.  81;  the  operator  is  not  confirmed  as 
the owner. 

d)  Exception  from physical  movement  principle.  List  of  exclusions is 
not  applicable  and  thus  duration  of  the  leasing  does  not  affect  the 
decision. 

e) Included even if not crossing frontiers. 

4.2 Transfer of ownership of railway rolling stock, oil drilling rigs and production platforms 

Intra-EU trade

f) 

when 

Included 
acquisition/supply for VAT. 
Excluded when temporary movement. 

declared 

as 

BPM5

g) 

Included  in  sub-item  ‘General  Merchan-
dise’ 
Par. 208 

Extra-EU trade

f) 

Included when declared for Customs. 
Excluded when temporary movement 

BPM6

g) 

Included 

f) May be covered by the provisions on specific goods or movements. 

g) Included even if not crossing frontiers. 

4.3 Satellites, spacecraft 

Intra-EU trade

h) 

Included,  but  only  if  just  constructed 
and initially launched. 
Reg. No 1982/2004, Art. 22 
Recorded  at  ex-works  value,  as  a 
transaction  between  MS  of  construction 
of the finished spacecraft and MS of the 

BPM5 

Included 
Both  when 
if 
ownership is transferred while the satellite 
is in orbit. 

launched  and 

initially 

Compilers guide on European statistics on international trade in goods 

206 

 
 
 
 
Annexes   

Included 
Both  when 
if 
ownership is transferred while the satellite 
is in orbit. 

launched  and 

initially 

Extra-EU trade

h) 

new owner. 
Included,  but  only  if  just  constructed 
and initially launched. 
Reg. No 113/2010,Art.23 
Recorded  at  ex-works  value,  as  a 
transaction  between  MS/country  of 
construction  of  the  finished  spacecraft 
and MS/country of the new owner. 

BPM6 

h) Transfers of owner-ship of satellites in orbit are excluded from 
ITGS. 

5. Sea products 
Fish  and  other  marine  products  caught  by  a  non-resident  ship  and  sold  in  the  compiling  economy,  or  caught  by  a 
resident ship and sold directly abroad 

Intra-EU trade

i) 

BPM5

j) 

Included 
Reg. No 1982/2004, Art. 21 
Sea  products  are  deemed  to  belong  to 
the  MS  where  the  taxable  person  who 
exercises  the  economic  ownership  of 
the vessel is established. 

flying 

the  case  of  ships 

Included  in  sub-item  ‘General  Merchan-
dise’ 
Par. 208. 
In 
flags  of 
convenience, the country of registry differs 
from  the  country  of  residence  of  the 
operator  or  owner.  The  activity  has  to  be 
attributed  to  the  country  of  residence  of 
the operating enterprise. 
Par. 81 
Included  in  sub-item  ‘General  Merchan-
dise’ 
Par. 10.16 (e) 

i) 

j) 

BPM6

Extra-EU trade

Included 
Reg. No 113/2010, 
Art. 22 
Sea  products  are  deemed  to  belong  to 
the MS where the person who exercises 
the economic ownership of the vessel is 
established 
i) Covered by the provisions on specific goods or movements 
6. Goods purchased or sold by embassies (as non-residents) for their own use in the economy in which they are 
located 
Intra-EU trade 

j) Included even if not crossing frontiers. 

BPM5

k) 

Excluded 
Reg. No 1982/2004, Annex I, point (d) 
Goods  never  cross  borders,  do  not 
leave  or  enter  the  reporting  Member 
State. 

Included  under  goods  if  identified  (Par. 
208), otherwise included under ‘Services / 
Government services’. 
Par. 266. 

Extra-EU trade 

Excluded 
Reg. No 113/2010, Annex I, point (d) 
Goods  never  cross  borders,  do  not 
leave  or  enter  the  reporting  Member 
State. 

BPM6

k) 

Excluded 
Acquisition  of  goods  and  services  by 
embassies 
under 
‘Services/Government goods and services 
n.i.e.’ 
Paras. 10.175 and 10.176  

classified 

are 

6.1 Goods bought from or sold to international institutions (as non-residents) located in the reporting country. 

k) Included even if not crossing frontiers. 

Intra-EU trade 

Extra-EU trade 

Excluded 
Reg. No 1982/2004, Annex I, point (d) 
Goods  never  cross  borders,  do  not 
leave  or  enter  the  reporting  Member 
State. 

BPM5 

Excluded 
Reg. No 113/2010, Annex I, point (d) 
Goods  never  cross  borders,  do  not 
leave  or  enter  the  reporting  Member 
State. 

BPM6 

Included  under  goods  if  identified  (par. 
208), otherwise included under ‘Services / 
Government services’. 
Par. 266 

Excluded 
Acquisition  of  goods  and  services  by 
embassies 
under 
‘Services/Government goods and services 
n.i.e. ’ 
Paras. 10.175 and 10.176 

classified 

are 

7.  Goods  consigned  to  embassies  (shipments  by  a  specific  economy  to  its  diplomatic  establishments  located 
outside the territory of the economy) 

Intra-EU trade 

Excluded 
Reg. No 1982/2004, Annex I, point (d) 

Extra-EU trade 

Excluded 

BPM5

l) 

BPM6

l) 

Excluded 
Par. 209. 

Excluded 

Compilers guide on European statistics on international trade in goods 

207 

 
 
 
 
 
Annexes   

Reg. No 113/2010, Annex I, point (d) 

Par. 10.22(c) 

l) List of exclusions, no change of ownership 

8. Government imports and exports of goods 

Intra-EU trade 

Included 

Extra-EU trade 

Included 

BPM5

m) 

BPM60

m) 

Included 
Par. 215 

Included 
Par. 10.22(c) 

m) Special types of goods 

9. Goods dispatched to national armed forces stationed outside the statistical territory of the reporting MSs 

Intra-EU trade 

Excluded 
Reg. No 1982/2004, Annex I, point (d) 

Extra-EU trade 

Excluded 
Reg. No 113/2010, Annex I, point (d) 

BPM5

n) 

BPM6

n) 

Excluded 
Par. 209. 

Excluded 
Par. 10.17(o) 

10. Goods delivered to and from offshore installations 

Intra-EU trade 

Included 
Reg. No 1982/2004, Art. 20 

Extra-EU trade 

Included 
Reg. No 113/2010, Art. 21 

11. Returned exports and imports of goods 

Intra-EU trade 

Included 
Reg. No 1982/2004, Annex III 
Identified by NoT code 21 

Extra-EU trade 

Included 
Reg. No 113/2010, Annex II 
Identified by NoT code 21 

n) List of exclusions, no change of ownership 

BPM5

o) 

in 

Included 
Merchandise’ 
Par. 208. 

BPM6

o) 

Included 

sub-item 

‘General 

o) Included even if not crossing frontiers 

BPM5

p) 

Excluded 
Par. 209 
Deductions  from  imports  and  exports  of 
general merchandise have to be made. 
Par. 210 

BPM6

p) 

Excluded 
Par. 10.22 (i) 

p) List of exclusions, no change of ownership. 

12. Goods that are lost or destroyed during the shipment 

12.1 Goods that are lost or destroyed 

Intra-EU trade 

Included or not, depending on whether 
the  loss  takes  place  before  or  after 
crossing  frontiers  of  reporting  Member 
State. 

BPM5 

Extra-EU trade 

Included or not, depending on whether 
the  loss  takes  place  before  or  after 
crossing  frontiers  of  reporting  Member 
State. 

BPM6 

Included  whenever  there  is  a  change  of 
ownership.  These  accidents  cannot  be 
recorded by ITGS. 
In practice, only big losses (e.g. sinking of 
tankers) can be taken into account.  

Included  or  excluded  depending  on  the 
change of ownership 
Par. 10.17 (m) 

12.1 Goods that are lost or destroyed inside the customs frontier of the exporting economy 

Intra-EU trade 

Excluded 

Extra-EU trade 

Excluded 

BPM5

q) 

BPM6

q) 

Included, if there is change of ownership 
Par. 209. 

Included, if there is change of ownership. 
Par. 10.17(m) 

q) List of exclusions, no change of ownership 

12.2 Goods that are lost or destroyed inside the customs frontier of the importing economy 

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208 

 
 
 
 
 
 
 
 
 
Intra-EU trade 

Included 

BPM5 

Annexes   

Included, if there is change of ownership. 
Par. 209. 
They  have  to  be  deducted  from  trade 
figures of both economies, if the loss took 
place before change of ownership. 

Extra-EU trade 

Included 

BPM6 

Included, if there is change of ownership. 

12.3  Goods  that  are  lost  or  destroyed  between  the  custom  frontiers  of  exporting  (country  A)  and  importing 
economies (country B) 

Intra-EU trade 

Included  in  dispatches  of  country  A, 
excluded from arrivals of country B 

BPM5

r) 

Included, if there is change of ownership. 
Par. 209 
If  the  loss  took  place  prior  to  the  change 
of  ownership, 
to  be 
deducted from country A exports. If it took 
place  after  the  change  of  ownership,  the 
value  has  to  be  added  to  country  B 
imports. 

the  value  has 

Extra-EU trade 

Included 
excluded from Imports of Country B 

in  exports  of  country  A, 

BPM6

r) 

Included, if there is change of ownership. 

r) Included even if not crossing frontiers. 

13. Transit trade 
13.1 Direct transit trade 
‘Real’ transit; goods merely passing through a MS, entering the customs border of a MS, not cleared by its customs 
authorities directly sent to another MS for customs clearance. 

Intra-EU trade 

Extra-EU trade 

Excluded 
Reg. No 638/2004, Art. 3 

Excluded 
Reg. No 471/2009, Art. 3 

BPM5

s) 

BPM6

s) 

Excluded 
Par. 209 

Excluded 
Par. 10.22 (a) 

s) List of exclusions, no change of ownership. 

13.2 Quasi-transit trade (‘Disguised’ direct transit trade) 
Intra-EU trade 

Included 
Goods which enter the EU are released 
for  free  circulation  at  the  compiling 
economy  and  are  then  transferred  to 
another MS. A dispatch declaration has 
to  be  filed  in  that  MS.  Goods  originate 
in one MS but leave the EU through the 
territory  of  another  MS  where  customs 
procedures  are  carried  out.  An  arrival 
has  to  be  included  in  intra-EU  trade 
data  reported  to  Eurostat  (Community 
concept). 

BPM5 

Included 
The  recording,  which  is  an  exception  to 
the  change  of  ownership  principle,  is 
recommended to avoid underestimation of 
imports from non-member countries at EU 
level. 

Extra-EU trade 

Included 
Where  the  import/export  declaration  is 
lodged at the external border of the EU, 
MS  of  entry/exit  shall  report  for  extra-
EU trade statistics. 

BPM6 

Included 
BoP Vademecum, November 2009, pages 
19 and 20, ‘Quasi-transit adjustment’ 

13.3 Re-exports are the goods that were previously imported into the compiling economy and that are later exported 
in the same condition as previously imported 

Intra-EU trade 

Included 
Not identified by any specific NoT code 

BPM5 

Extra-EU trade 

Included 
Not identified by any specific NoT code 

BPM6 

should  be 

Included in ‘General merchandise’ 
shown 
Where  possible 
separately  as  a  supplementary 
item, 
particularly in economies where re-exports 
make up a significant part of exports‘. 
Paras. 10.37 and 10.39 

14.  Goods  entering/leaving  customs  warehouses,  free  zones,  free  distribution  centres  (facilities  which  can  hold 
merchandise under customs control) 

Compilers guide on European statistics on international trade in goods 

209 

 
 
 
 
 
 
Intra-EU trade 

Not applicable 

BPM5 

Annexes   

the 

ITGS-goods 

Included in case of change of ownership 
Par. 222 
Included if the owner is a resident of MS. 
If 
is  based  on 
general trade, imports/exports on account 
of  non-residents  must  be  excluded.  If  the 
ITGS-goods  item  is  based  on  special 
trade  statistics, 
/  exports  of 
imports 
residents must be added. 

item 

BPM6 

Included in case of change of ownership 
Included  if  the  owner  is  a  resident  of  a 
MS. 
Par. 10.25 

Extra-EU trade 

if  goods 

or  move 

leaving  customs 
to  be  cleared 
free 
inward,  processing  and 

Excluded  if  goods  remain  inside  the 
warehouses 
between 
warehouses. 
Included 
warehouse 
circulation, 
processing under customs control. 
Included 
in 
customs  free  zones  for  processing  and 
then  re-exported,  as  well  as  re-import 
after  customs  outward  processing 
procedure. 

if  goods  are 

imported 

for 

15. Merchanting — goods purchased and resold by  a resident of the compiling country, but  not 
entering the compiling country 
15.1 Goods traded between residents and non-residents which never cross borders (or are stored in free zones), if 
the transaction is finalised in the same recording period 
Intra-EU trade 

Excluded 

BPM5 

Excluded 
Par. 212 
Recorded  (net)  under  ‘Services  /  Other 
/  Merchanting  and 
business  services 
other trade related services’ 
Par. 262 

Extra-EU trade 

Excluded 

BPM6 

Included  in  goods  as  a  sub-item  ‘Net 
exports of Goods under merchanting’ 
Par. 10.41 
Acquisition  of  goods 
negative exports. 
Sale  of  goods  is  recorded  as  positive 
exports (par. 10.44). 
Difference  between  sales  and  purchases 
is  recorded  as  an  item  ‘Net  exports  of 
goods under merchanting. 

is  recorded  as 

15.2  Goods  traded  between  residents  and  non-residents  which  never  cross  borders  (or  are  stored  in  free 
zones), if the goods are acquired in one reporting period and sold in a later period = Stocks of goods located abroad 
Intra-EU trade 

Excluded 

BPM5

t) 

Included 
Par. 213 
These  goods  have  to  be  recorded  in  the 
BoP of the temporary owner as imports of 
goods (stocks of goods located abroad), 
The  same  amount  has  to  be  deducted 
from  imports  in  the  period  in  which  the 
goods are finally sold. 

Extra-EU trade 

Excluded 

BPM6

t) 

If the goods are the object of merchanting, 
the  distinction  between  15.1  and  15.2  is 
no longer relevant 

t) Change of ownership of goods but not crossing frontiers. 

15.3 Imports: Purchase of goods for own use that remain abroad (not object of merchanting). 

Exports: sales of goods (that remain in the economy) to a non-resident 

Intra-EU trade 

Excluded 

Extra-EU trade 

Excluded 

BPM5 

BPM6 

Included 

Included 

16.  Means  of  payment  which  are  legal  tender,  and  securities,  issued  banknotes  and  securities  and  coins  in 
circulation. 

Compilers guide on European statistics on international trade in goods 

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Annexes   

Intra-EU trade 

Excluded 
Reg. No 1982/2004, Annex I, point (b) 

BPM5 

Excluded 
Recorded in the Financial Account 

Extra-EU trade 

Excluded 
Reg. No 113/2010, Annex I, point (b) 

BPM6 

Excluded 

17. Paper money, coins, securities not in circulation, which are valued as commodities and not at face value 

Intra-EU trade 

Included 

Extra-EU trade 

Included 

BPM5 

BPM6 

Included 
Par. 215 

Included 
Par. 10.17 (a) 

18. Monetary gold 
Gold  exchanged  between  the  monetary  authorities  of  different  economies,  gold  held  as  reserve  assets  by  the 
monetary authorities 

Intra-EU trade

u)  Excluded 

Reg. No 1982/2004, Annex I, point (a) 

Extra-EU trade

u)  Excluded 

Reg. No 113/2010, Annex I, point (a) 

BPM5 

BPM6 

Excluded 
Par. 214 
Recorded  under  Financial  account 
Reserve assets 

Excluded 
Paras. 5.74 and 5.75 
Recorded  under  Financial  account 
Reserve assets. 

/ 

/ 

u) List of exclusions 

19. Non-monetary gold Imports and exports of gold: industrial gold and gold held as a store of value. 
Non-monetary gold includes also gold bought by private banks as reserve assets. 

Intra-EU trade 

Extra-EU trade 

BPM5

v) 

BPM6

v) 

Included 
Identified  by  CN  codes  7108 11 00, 
7108 12 00,  7108 13 00,  7108 13 10, 
7108 13 80 
Excluded  if  the  gold  is  stored  abroad 
and does not cross borders. 

Included 
Identified  by  CN  codes  7108 11 00, 
7108 12 00,  7108 13 00,  7108 13 10, 
7108 13 80 
Excluded  if  the  gold  is  stored  abroad 
and does not cross borders. 

Included 
Par. 202 
Recorded  as  a  separate  sub-item. 
Included even if it does not cross frontiers. 
Par.208 

Included 
Recorded  as  a  separate  sub  -item  ‘Non-
monetary gold’ Paras. 10.50 -10.54. 
‘In  many  cases  there  is  no  physical 
delivery  to  the  new  owner,  because  the 
gold is held at specialised bullion storage. 
However  change  of  ownership  is  the 
criterion  for  the  recording,  so  gold  sales 
and  purchases  should  be  recorded  even 
when  there  is  no  physical  movement’. 
Par. 10.53 
However  unallocated  non-monetary  gold 
accounts 
(see  Par  5.77)  should  be 
classified as financial assets. Par. 10.51 

v) Special types of goods 

20. Emergency aid for disaster areas (food and other humanitarian aid) 

Intra-EU trade 

Included 

BPM5

w) 

in 

‘General 

sub-item 

Included 
Merchandise’ 
An offsetting entry should be made in the 
Current Account/Current Transfers. 
Par. 291 

Extra-EU trade 

Included 

BPM6

w) 

Included 
Par. 10.17 (q) 

w) Goods treated as financial items 

21. Goods delivered under aid programs, without compensation 

Intra-EU trade 

Included 
Reg. No 1982/2004, Annex III 
Identified by NoT code 3 

BPM5 

Included  in  sub-item  ‘General  Merchan-
dise’ 
An offsetting entry should be made in the 
Current Account / Current Transfers. 
Par. 291 

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211 

 
 
 
 
 
 
Annexes   

Extra-EU trade 

Included 
Reg. No 113/2010, Annex II 
Identified by NoT code 3 

BPM6 

Included 
Par. 10.17 (q) 

22. Goods for and following temporary use (temporary exports and imports of goods that are not for sale) 

Intra-EU trade 

Extra-EU trade 

Excluded,  provided  that  the  expected 
duration  of  the  temporary  use  is  no 
longer than 24 months. 
Reg. No 1982/2004, Annex I, point (c) 

Excluded,  provided  that  the  expected 
duration  of  the  temporary  use  is  no 
longer than 24 months. 
Reg. No 113/2010, Annex I, point (c) 

BPM5 

Excluded 
Par. 209 

BPM6 

Excluded 
Par. 10.22 (e) 

23. Goods used as carriers of information (floppy disks, CD-ROMs, films, audio and videotapes) 

Intra-EU trade 

Extra-EU trade 

Excluded,  if  information  is  customised 
for particular client. 
Included, 
customised. 
Reg. No 1982/2004, Annex I, point (e) 

information 

not 

is 

if 

Excluded,  if  information  is  customised 
for particular client. 
Included, 
customised. 
Reg. No 113/2010, Annex I, point (e) 

information 

not 

is 

if 

BPM5 

Packaged,  non-customised  software,  CD-
ROMs, etc. are included and recorded in 
sub-item ‘General Merchandise’. 
Customised  carriers  of  information  are 
‘Services/ 
excluded  and  recorded  as 
computer and information services’ 

BPM6 

Included 
Par. 10.17 (c) and Table 10.4 

24. Goods not subject of commercial transaction 

24.1 Printed advertising material, commercial samples (Samples of no commercial value) 

Intra-EU trade

x) 

Excluded 
Reg. No 1982/2004, Annex I, point (g) 

Extra-EU trade

x)  Excluded 

Reg. No 113/2010, Annex I, point (g) 

BPM5 

BPM6 

Excluded 
Par. 209 

Excluded 
Par. 10.22(j) 

x) List of exclusions 

24.2 Other goods 
a) Decorations, prizes, medals 
b) Travel equipment for personal use 
c) Coffins, funerary urns, etc. 
d) Ballast 
e) Pharmaceutical products used at international sporting events 

Intra-EU trade

y) 

Practically excluded 

Extra-EU trade

y)  Excluded,  if  not  declared  for  customs 

purposes. 
Some  goods  identified  by  CN  codes 
9919 00 00 

BPM5

z) 

BPM6

z) 

Excluded 
Par. 209 

Excluded 

y) List of exclusions 
24.3 Migrants' effects (Items involved in moving house or heirlooms) 

z) List of exclusions, no change of ownership 

Intra-EU trade 

Practically excluded 

BPM5 

Included 
All  the  household  and  personal  effects  of 
migrants … transferred from the old to the 
new economy are included under ‘general 
merchandise’. 
Par. 353 
An  offsetting 
to  be 
recorded  under  ‘Capital  account/capital 
transfers/Other 
Migrants' 
transfers’. Par. 352 

transaction  has 

sectors/ 

Compilers guide on European statistics on international trade in goods 

212 

 
 
 
 
Extra-EU trade 

Excluded,  if  not  declared  for  customs 
purposes. 
Identified by CN codes 9905 00 00 and 
9919 00 00 

BPM6 

Annexes   

that 

accompanies 

Excluded 
‘Migrants'  personal  effects.  The  personal 
property 
people 
changing  residence  is  not  classified  as  a 
transaction because there is no change of 
ownership’. 
Par. 10.22(b) 
Adjustment may be necessary in extra-EU 
trade. 

24.4 Waste (Goods which have become unusable) 

Intra-EU trade

aa) 

Included 

Extra-EU trade

aa) 

Included 

BPM5 

BPM6 

Excluded 
Par. 209 

Excluded 
Par. 10.22 (h) 
Waste  and  scrap  with  positive  values  are 
included in ‘general merchandise’. 

aa) Quantity is recorded in case of waste with negative value. 

25. Shipments of gifts 

Intra-EU trade 

Excluded  if  sent  or  received  by  a 
person below Intrastat thresholds. 
Included  if  the  receiver  or  sender  is 
above Intrastat exemption thresholds. 

BPM5

bb) 

Extra-EU trade 

Excluded,  if  not  declared  for  customs 
purposes. 

BPM6

bb) 

26. Means of transport travelling in the course of their work, including spacecraft launchers at the time of 
launching 

bb) Special type of goods 

Intra-EU trade 

Excluded 
Reg. No 1982/2004, Annex I, point (i) 

Extra-EU trade 

Excluded 
Reg. No 113/2010, Annex I, point (i) 

27. Trade in goods between foreign affiliates 

BPM5 

Excluded 

BPM6 

Excluded 

Intra-EU trade 

Included, if the goods cross the border.   BPM5 

Extra-EU trade 

Included, if the goods cross the border.  BPM6 

Included  in  sub-item  ‘General  Merchan-
dise’ 
Par. 205  

Excluded, if no change of ownership. 
Par. 10.24 

28. Financial leasing (Lease arrangements made for capital goods for most or all of their expected economic life) 

Intra-EU trade 

Included 
Reg. No 1982/2004, Annex III 
Could be identified by NoT code 14. 

Extra-EU trade 

Included 
Reg. No 113/2010, Annex II 
Could be identified by NoT code 14. 

BPM5

cc) 

BPM6

cc) 

Included  in  sub-item  ‘General  Merchan-
dise’ 
Par. 206 
An offsetting entry should be made in the 
Financial Account. 

Included  in  sub-item  ‘General  Merchan-
dise’ 
Paras. 10.17(f) and 5.56 

cc) Exceptions to change of ownership rule 

29. Operational leasing (Leasing/rental of equipment other than ships and aircrafts) 

Intra-EU trade 

Excluded  if  shorter  than  24  months, 
otherwise included. 

BPM5

dd) 

Excluded 
Par. 209 
Recorded  under  Services/Other  Business 
Services/Operational leasing (Par. 263). 
Operational 
than  24 
months,  included  in  ITGS,  has  to  be 
excluded from BoP.  

leasing 

longer 

Extra-EU trade 

Excluded  if  shorter  than  24  months, 
otherwise included. 

BPM6

dd) 

Excluded 
Recorded  under  Services/Other  Business 

Compilers guide on European statistics on international trade in goods 

213 

 
 
 
 
 
 
 
 
Annexes   

Services/Technical,/Trader 
related  and 
other business services/Operating leasing 
Paras. 10.153-10.157 

dd) List of exclusions, no change of ownership 

30.  Goods  acquired  by  travellers  for  their  own  use  and  by  non-resident  workers  (which  are  not  VAT  registered 
entities) 

Intra-EU trade 

Practically excluded 

BPM5

ee) 

Extra-EU trade 

Excluded,  if  not  declared  for  customs 
purposes. 

BPM6

ee) 

Excluded 
Par. 212 
Recorded under ‘Services/Travel’ 

Excluded 
Par. 10.86 
Goods and services for own use acquired 
from an economy by non-residents during 
visits  to  that  economy  are  recorded  as 
‘Travel’ 

30.1 Sales of new means of transport to non-resident private individuals (tourists) 

ee) Exceptions to change of ownership rule 

Intra-EU trade 

Included 

Extra-EU trade 

Included 

BPM5

ff) 

BPM6

ff) 

Excluded  from  goods,  included  under 
‘Services/Travel’ 

travellers 

Included 
Paras.  10.20  and  10.90  Goods  acquired 
in  excess  of  customs 
by 
thresholds  and  included  in  statistics  are 
included  in  general  merchandise.  If  not 
included  in  customs  data  they  should  be 
included in travel. 
Care  is  needed  to  avoid  double  counting 
in extra-EU goods and travel. 

ff) Goods classified as services 

30.2 Sales of valuable goods to non-resident private individuals (tourists) 
a) Paintings, sculptures, recognised works of art and antiques. 
b) Jewellery, precious stones 

Intra-EU trade  Excluded 

BPM5 

Extra-EU trade 

Included, 
purposes. 

if  declared 

for  customs 

BPM6 

Included 
ESA95, Par. 3.150.e. 
Transactions in existing valuables with the 
Rest of the World have to be recorded as 
an import or export of goods. 
Adjustment required only in intra-EU trade 

thresholds  and 
included 
are 

Included 
Paras. 10.20 and 10.90 
Goods acquired by travellers in excess of 
customs 
in 
statistics 
general 
merchandise.  If  not  included  in  customs 
data they should be included in travel. No 
adjustment  in  goods  required  anymore. 
Care  is  needed  to  avoid  double  counting 
in extra-EU goods and travel. 

included 
in 

30.3 Shuttle trade (Goods for resale acquired by travellers while on visit) 
Intra-EU trade  Practically excluded 

BPM5 

Extra-EU trade 

Included, 
purposes. 

if  declared 

for  customs 

BPM6 

Included 
Par. 10.19 
Because  the  intent  of  this  travel  is  not  to 
acquire  goods  for  personal  use  but  to 
engage in a business. 

31. Newspapers and periodicals (not in bulk) sent on the basis of direct subscription 
Intra-EU trade  Excluded  if  sent  or  received  by  non-

BPM5 

taxable person. 
Included if the subscriber or sender is a 
taxable  person  and  the  PSI  is  over 

Excluded 
Par. 212 
Recorded under ‘Services / Computer and 
information services ’ 

Compilers guide on European statistics on international trade in goods 

214 

 
 
 
 
 
 
 
Intrastat exemption threshold. 

Extra-EU trade 

Included, 
purposes. 

if  declared 

for  customs 

BPM6 

Excluded 
Par. 10.146 
Recorded 
under 
telecommunications, 
information 
services’ 

services 

computer 

‘Services 

/ 
and 
Information 

/ 

Annexes   

32. Postal consignments (Goods dispatched through postal or courier services) 
Intra-EU trade  Excluded  if  sent  or  received  by  a  non-

BPM5 

Included 
Par. 215 

taxable person. 
Included if the receiver or the sender is 
a  taxable  person  and  PSI  is  above 
Intrastat exemption threshold. 

Extra-EU trade 

Included, 
purposes. 

if  declared 

for  customs 

BPM6 

Included 
Par. 10.17 (l) 

33. Supplies to construction sites 

33.1 Supplies of building materials 
Exports of building materials for works that are performed abroad by residents as part of a general construction con-
tract lasting less than one year. 
Intra-EU trade 

considered 

BPM5

gg) 

not 

as 

if 

Included, 
temporary movement. 
Reg. No 1982/2004, Annex III 
May be identified by NoT code 8. 

Excluded 
Par. 254 
Goods  imported  or  exported  by  the  (non-
resident)  contractor  for  use  in  the  project 
are  included  in  ‘Services/  Construction 
services/ Exports (credits)’. 
However  it  was  recommended  to  offset 
these goods by recording a corresponding 
debit in construction services. 

Extra-EU trade 

if 

considered 

not 

Included, 
temporary movement. 
Reg. No 113/2010, Annex II 
May be identified by NoT code 8. 

as 

BPM6

gg) 

Excluded 
Paras. 10.22 (d) and 10.103 
‘…  goods  sent  abroad  from  the  home 
base  for  use  in  a  construction  project  not 
undertaken  by  a  separate  entity;  these 
goods  are  not  included  in  exports  of 
general merchandise of the territory of the 
home base.’ 
Adjustment 
exports of goods. 

imports  and 

required 

in 

gg) Goods classified as services 

33.2 Supplies of building materials 
Imports of building material for works that are performed in the compiling economy by non-residents as part of a ge-
neral construction contract lasting less than one year. 
Intra-EU trade 

considered 

BPM5

hh) 

not 

as 

if 

Included, 
temporary movement. 
Reg. No 1982/2004, Annex III 
May be identified by NoT code 8. 

Excluded 
Par. 254 
Goods  imported  or  exported  by  the  non-
resident  contractor  for  use  in  the  project 
are  included  in  ‘Services/  Construction 
services/ Exports (credits)’. 
However  it  was  recommended  to  offset 
these goods by recording a corresponding 
credit in construction services. 

Extra-EU trade 

if 

considered 

not 

Included, 
temporary movement. 
Reg. No 113/2010, Annex II 
May be identified by NoT code 8. 

as 

BPM6

hh) 

Excluded 
Paras. 10.22 (d) and 10.103 
‘…  goods  sent  abroad  from  the  home 
base  for  use  in  a  construction  project  not 
undertaken  by  a  separate  entity;  these 
goods  are  not  included  in  exports  of  ge-
neral  merchandise  of  the  territory  of  the 
home base.’ 
Adjustment 
exports of goods. 

imports  and 

required 

in 

Compilers guide on European statistics on international trade in goods 

215 

 
 
 
 
hh) Goods classified as services 

Annexes   

33.3 Supplies of building materials 
Exports of building materials for works performed abroad by residents as part of general construction contract lasting 
more than one year (or performed by a subsidiary which is considered resident of the host economy). 
Intra-EU trade 

considered 

BPM5

not 

as 

ii) 

if 

Included, 
temporary movement. 
Reg. No 1982/2004, Annex III 
May be identified by NoT code 8. 

Included 
Par. 254 
Recorded under ‘General merchandise’. 
The  construction  activity  abroad 
recorded as a direct investment. 

is 

Extra-EU trade  Included, 

if 

not 

considered 

temporary movement. 
Reg. No 113/2010, Annex II 
May be identified by NoT code 8. 

as 

BPM6

ii) 

Included 
Par. 10.103 
Recorded under ‘General merchandise’. 
The  construction  activity  abroad 
recorded as a direct investment. 

is 

ii) Goods classified as services 

33.4 Goods locally acquired for construction undertaken by enterprises that are non-resident in the territory of the 
location of the work 

Intra-EU trade  Excluded 

No cross-border transaction 

Extra-EU trade  Excluded 

No cross-border transaction 

BPM5

jj) 

BPM6

jj) 

Excluded 
No cross-border transaction 

Excluded 
Paras. 10.23 (d) and 10.102 
Goods  are  included  under  ‘Construction 
services’. 

34. Illegal and smuggled goods (that otherwise are legal) 

jj) Goods classified as services 

Intra-EU trade  Excluded 

Extra-EU trade  Excluded 

35. Electricity, gas and water 

Intra-EU 
kk) 
trade

Extra-EU 
trade

kk) 

Included 
Reg. No 1982/2004, Art 23 
According  to  the  physical  movement  of 
the goods and not the ownership.  

Included 
Reg. No 113/2010, 
Art. 24 
According  to  the  physical  movement  of 
the goods and not the ownership. 

BPM5 

BPM6 

BPM5 

BPM6 

kk) Values might be estimated. 

35.1. Pipelines transport (Imports of natural gas for re-export) 

Intra-EU 
trade

ll) 

Extra-EU 
ll) 
trade

Included 
Reg. No 1982/2004, Art. 23 
According  to  the  physical  movement  of 
the goods and not the ownership.  

BPM5 

Included 
Reg. No 113/2010, Art. 24 
According  to  the  physical  movement  of 
the goods and not the ownership. 

BPM6 

Included 
Par. 215 

Included 
Paras.10.17 (i) and (j) 

Included 
Par. 215 

Included 
Par. 10.17 (b) 
Charges 
the 
invoiced  separately 
transmission,  transport,  or  distribution  of 
in 
these 
‘Services/Transport’ 

products 

included 

are 

for 

Included 
Same treatment as ITGS. This is similar to 
(point  13.2),  and 
quasi-transit 
therefore  also  here 
the  community 
concept should be followed. 

trade 

Included 
Par.10.17 (b)  
However,  charges  invoiced  separately  for 
the  transmission,  transport,  or  distribution 
of these products are included in services 
under transport 

ll) Values might be estimated. 

36. Livestock driven across frontiers 

Intra-EU 
trade

ll) 

Included as any other goods.  

BPM5

mm) 

Included 
Par. 215 

Compilers guide on European statistics on international trade in goods 

216 

 
 
 
 
 
 
 
 
Annexes   

Extra-EU 
ll) 
trade

Included as any other goods 

BPM6

mm) 

if 

there 

is  a  change  of 

Included, 
ownership 
Par. 10.1 

mm) Special types of goods 

37. High value capital goods 
The  production  of  high-value  capital  goods  such  as  ships,  heavy  machinery  and  other  equipment  may  take  several 
months  or  years  to  complete.  The  transaction  should  be  recorded  at  the  time  that  economic  ownership  is conveyed 
from the seller to the buyer.  

Intra-EU trade 

Included,  when  the  completed  capital 
good crosses borders. 
Extra-EU trade  Included,  when  the  completed  capital 
good crosses borders. 

BPM5

nn) 

BPM6

nn) 

Included 

Included,  at  the  moment  of  change  of 
ownership 
Par. 10.28. 
If change of ownership differs from time of 
payment,  accounts 
receivable/payable 
arise. 
Adjustment  needed  if  the  time  of  change 
of owner-ship is different from the time of 
final consignment. 

nn)  The  timing  in  data  sources  may  or  may  not  coincide  with  the 
change of ownership, for example payments data are on the basis 
of stage payments, while customs data are on the basis of the time 
that the completed item crosses the frontier 

Compilers guide on European statistics on international trade in goods 

217 

 
 
 
 
 
Index   

INDEX

A 

Additional data sources, 20, 24, 49, 139 
Advertising material, 31 
Aircraft register, 121 
Asset, 117 

B 

Balance of payments, 125 
Balance of Payments, 26, 35, 93, 102, 109, 122, 133, 

148, 156, 164 
Balance sheet, 115 
BoP. See Balance of Payments 
BPM6, 26, 28, 40 
Business register. See Statistical business register 

C 

Call off stock, 41 
Centralised clearance, 65, 76 
Chargeable event, 70 
Chartering, 123 

bareboat charter, 123 
time charter, 123 
voyage charter, 123 

Combined Nomenclature, 14, 26, 33, 71–72, 76, 88, 

124, 152 

Commercial samples, 31 
Compilation rules, 9 
Confidentiality, 139, 158–60 

active, 158 
passive, 139, 158 
Consignment stock, 41 
Container, 107 
Continental shelf, 128 
Country of origin, 75, 76, 104, 134, 150 
Credit note, 61, 85, 87 
Currency, 79, 86, 87, 165 
Customs administration. See Customs 
Customs decision, 48, 66 
Customs declaration, 14, 43, 47–51, 62–67, 71, 78, 

89, 92, 120, 126, 128, 137, 145–49, 151 
incomplete, 163 
oral, 36, 155 
postal declaration CN22 or CN23, 155 
simplified declaration, 48, 63 
supplementary declaration, 48, 63, 76 
T2M form, 132 
written or electronic, 36, 90, 154 

Customs legislation, 17 

Community Customs Code, 17, 48 

Modernised Customs Code, 17 
Union Customs Code, 17, 64, 76, 90, 127 

Customs procedure, 20, 89–91, 191–203 

customs warehouse, 23, 90, 93 
free zone, 23, 90 
inward processing, 21, 24, 32, 35, 70, 77, 84, 92, 

102 

outward processing, 24, 35, 86, 92 
processing under customs control, 21, 24, 32, 77, 

86 

re-exportation, 24, 78 
re-importation, 86 
release for free circulation, 22, 24, 145 
with economic impact, 191 

Customs Procedure Code, 90, 147, 191–203 
Customs tariffs, 71 
Customs territory, 21, 23, 43, 89, 107, 128, 132, 142, 

166, 192 

Customs union, 104 

D 
Declarant, 35, 63, 67, 90, 104 
Delivery of goods to vessels and aircraft, 21, 51, 72, 

76, 89, 124–27, 201 

Delivery terms, 79, 109–10, 150 
Distance sale, 36–39, 62 
Doc MET 400, 17, 35, 72, 74, 125, 140, 154, 161 
Double counting, 32, 53, 90, 91, 148 

E 

Economic activity, 52, 56, 165 
Economic benefits, 114 
Economic ownership, 41, 113, 126 
list of indicative criteria, 114 
transfer of, 50, 70, 115, 117, 120, 123, 133, 205 

Economic territory, 21, 27, 119, 167, 169, 173 
Electricity and gas, 21, 50, 62, 70, 133–39 
Encouragements, 9 
Enterprise group, 95 
EORI, 67–68 

number, 69 
ESA 2010, 122 
Establishment, 119 
Estimates of missing intra-EU trade, 46, 56, 57, 58, 

60, 162 
for below threshold trade, 151 
for late or non-response trade, 163 
for non-response, partial response, 151 
for trade below threshold, 163 

Estimates of net mass in intra-EU trade, 88 

Compilers guide on European statistics on international trade in goods 

218 

 
 
 
Index   

Estimates of statistical value in intra-EU trade, 85 
EU fiscal territory. See VAT territory 
Euro area, 161 
European Commission, 15, 160 

Eurostat, 18, 72, 78, 88, 91, 151, 156, 160 

Excise duties, 23, 62, 79, 89, 191, 194 
Exclusive economic zone, 43, 128 
Exporter, 67, 68, 77, 146 
Extra-EU trade statistics 

aggregated results, 161 
detailed results, 162 
scope of, 23 

F 
Financial compensation, 94 
Financial intermediary, 114 
Financial leasing, 27, 40, 61, 83, 95, 118 
Fishery products, 131 

G 

Generalised System of Preferences, 104 
Geonomenclature, 69, 73–74 
Goods 

Community goods, 21, 23, 45, 89, 141 
definition of, 21 
delivered with installation or assembly, 62, 83 
economic life of, 41 
for first aid in emergencies, 42 
free of charge, 31, 43, 78, 83, 86, 96, 111 
non-Community goods, 22, 52, 90, 142 
of commercial nature, 32, 155 
origin of, 75 
ownership of, 21, 27, 41, 145 
physical movement of, 22, 54, 75, 94, 133, 134, 

137 

possession of, 52 
returned, 38, 61, 70, 76, 84, 95, 198, 207 
transfer of, 36, 42, 97, 103 

Grid operator, 50, 137 

H 

Halt inherent in the transport, 74, 141 
Harmonised System, 71 
High seas, 128 
Hire purchase, 40, 122 
Humanitarian aid shipments, 42 

I 

Import duties, 23, 146 
IMTS, 9, 22, 23, 24, 40 
Incidental expenses, 79 
Incoterms. See Delivery terms 
Industrial plant, 21, 49, 72, 89, 111–12 
Institutional arrangement, 18 

Internal market, 15, 136 
International Accounting Standards, 115 
International Merchandise Trade Statistics, 21 
Intra-EU acquisitions and supplies, 22, 36, 57, 58, 70, 

129 

Intra-EU trade 

aggregated results, 161 
detailed results, 162 

Intra-EU trade asymmetries, 54, 122, 156 

reconciliation, 60, 145, 156 

Intra-EU trade statistics 

scope of, 21 

Intra-firm trade, 15, 95 
Intrastat 

declaration, 20, 22, 45, 49–55, 60–62, 69, 120, 

126, 128, 137 

legislation, 15 
register, 55–57, 57, 60 
reporting burden, 15, 150, 153 
simplified declaration, 46 
system, 14, 22, 45, 51, 57, 70, 88, 124, 132, 150 
Invoice, 30, 31, 59, 62, 70, 75, 79, 85, 87, 102, 142 

pro-forma, 83 

ITGS Steering Group, 9, 17, 161 

J 

Joint intergovernmental production programmes, 

102 

L 

Leasing 

dry lease, 123 
wet lease, 123 

Legislation, 16 

Acquis Communautaire, 16 
primary legislation. See Treaties 
regulations, directives. See Secondary legislation 

List of exclusions, 26, 117 

M 

Market value, 39, 42, 83 
Means of payment, 26 
Means of transport, 32, 133 

active, 106 
new, 52, 121 
Member State 

of actual export, 64, 77–78, 85, 148 
of arrival, 21, 52, 89, 103, 106, 108, 141, 145 
of consignment, 74–75, 141 
of destination, 21, 64, 74, 77, 85, 111, 141, 147 
of dispatch, 21, 89, 98, 106, 108, 141 

Military goods, 21, 51, 139–40 
Military secrecy, 51, 73, 139 
Mode of transport, 105–8, 150 

fixed transport installations, 106 

Compilers guide on European statistics on international trade in goods 

219 

 
 
 
Index   

postal consignment, 106, 155 

Monetary gold, 26 
Motor vehicle and aircraft parts, 124 

N 
NA. See National accounts 
NACE activity code, 59 
NACE rev. 2, 33 
National accounts, 125 
National Accounts, 93, 102, 118, 122, 133, 148, 156 
National authorities, 18 

Customs, 20, 48, 63, 104, 112, 154 
national statistical institute, 18 
tax administration, 20, 36, 46, 59, 69 

Nature of transaction, 33, 42, 60, 93–104, 152 
Newspapers and periodicals, 40 
Non-monetary gold, 26 
Non-taxable legal person, 53 
NUTS nomenclature, 109 

O 
Offshore installation, 21, 43, 51, 72, 89, 127–31, 191, 

207 

Operating risks, 114 
Operational leasing, 27, 41, 83, 118 

P 
Partner country, 28, 46, 59, 102, 118, 125, 126, 128, 

131, 143, 148, 159, 163 
Preferential treatment, 104–5 
Private individual, 37, 54, 62, 68 
Processing, 32, 33, 54, 58, 61, 69, 70, 79, 83, 86, 119, 

133 
of valuable waste, 39 
under contract, 33, 53, 75, 96 

Provider of statistical information, 49, 52–55, 59, 69, 

88, 132, 140, 142, 158, 213 
distance seller, 36 
economic operator, 18, 49, 150, 151 
non-established trader, 55 
tax groups, 55 
tax representative, 55, 95, 146 
Tax representative, 36 
taxable person, 52 
trader, 14, 20, 39, 42, 48, 52, 88, 91 
VAT registration, 95 

PSI. See Provider of statistical information 
Publication calendar, 162 

Q 

Quality 

assessment, 9 
checks, 56, 59, 60, 139, 143 
control, 59, 67 
framework, 156 

indicators, 88 
report, 156, 163 
requirements, 151, 152, 156 

Quality checks 

completness, 62 
credibility, 62, 170 
validity, 170 
Quality checks 
validity, 62 

Quality Handbook, 156 
Quantity, 120, 125, 131, 137, 152 

in net mass, 88 
in supplementary units, 88 
Quasi-transit, 67, 91, 145–49 

R 
Rebate and discount, 84, 87 
Receptacles, 41 
Re-exports, 109 
Reference period, 27, 42, 61, 70–71, 112, 120 
Region, 108–9, 150 
Repairs, 31, 33, 91, 102 
Requirements and recommendations, 9 
Revisions, 48, 162, 163 

S 

Sale on consignment, 95 
Salvage, 131 
Sea products, 21, 50, 131–32, 206 
Secondary legislation, 16 
basic regulations, 16 
delegated acts, 17 
implementing acts, 17 

Self-assessment, 66 
Services, 28, 30, 34, 39, 40, 62, 79, 83, 102, 133 
Ships register, 121 
Simple circulation between Member States, 21, 141 
SIMSTAT proposal, 15 
Single Administrative Document, 14, 48, 57, 76, 90, 

191 
guidelines, 105, 191, 194 

Single Authorisation, 22, 47, 52, 65, 77 
Single authorisation for simplified procedure, 48, 64, 

76 

Single Market. See Internal market 
Software, 30, 84 
Spacecraft, 21, 51, 132–33, 205 

launcher, 32, 51, 132 
statistical value of, 133 

Specific goods or movements, 20, 21, 39, 49, 54, 69, 

70, 74, 76, 89, 92, 111–40, 191, 205 

Spot market, 138 
Staggered consignments, 21, 49, 112–13 

reference period for, 70, 112 

Compilers guide on European statistics on international trade in goods 

220 

 
 
 
Index   

Statistical business register, 56, 68, 69 
Statistical procedure, 91–93 
Statistical territory, 22, 43, 106, 128 
Statistical threshold in extra-EU trade, 32, 154–55 

T 

TARIC, 72 
Tax period, 57 
Temporary use, 26 
Territorial enclaves, 27 
Territorial waters, 128 
Threshold system, 15 

coverage rate, 22, 151 
exemption threshold, 37, 40, 54, 55, 58, 150 
individual transaction threshold, 84, 88, 152 
optional variables threshold, 150 
simplification threshold, 88, 152 

Trade by business characteristics. See Trade by 

enterprise characteristics 

Trade by enterprise characteristics, 55, 67, 165 
Trade by invoicing currency, 87, 165 
Trade system 

general trade, 23, 24 
special trade, 23, 93, 128 

Transfer of ownership, 33, 83, 94, 205 
Transit, 90, 128, 137, 141, 208 
Treaties, 16 

Treaty of Lisbon, 17 
Treaty on European Union, 16 
Treaty on functioning of the European Union, 16 

Triangular trade, 59, 61, 76, 92, 142–45 

V 

Value added tax, 17 

VAT data, 22, 55, 57–60, 61, 121, 129, 151 
VAT Directive, 43, 52, 54, 125, 136 
VAT ID number, 46, 56, 67, 68, 69, 145 
VAT recapitulative statement, 20, 57, 60, 129, 137, 

145, 147 

VAT register, 20, 46, 56, 58 
VAT registration, 42, 53, 68 
VAT return, 20, 22, 37, 42, 46, 55, 56, 127, 137 
VAT territory, 43, 191 
VIES data, 46, 56, 60 

Value of goods, 35 

CIF-type value, 80, 85, 109 
customs value, 86 
FOB-type value, 80, 85, 109 
invoice value, 78–79, 109 
statistical value, 39, 85–87, 109, 120 
taxable amount, 38, 57, 78–79 
transaction value, 26 

VAT, 36 
Vessels and aircraft, 21, 32, 41, 43, 49, 71, 76, 89, 92, 

102, 113–24 

VIES declaration. See VAT recapitulative statement 

W 

Waste, 21, 39, 51, 83, 103 

disposal of, 39 

World Customs Organisation, 71 

Compilers guide on European statistics on international trade in goods 

221 

 
 
 
 
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