A trap that costs importers real money: Union goods can lose the benefit of the doubt. When EU goods move by sea (or through non-EU territory) between two points in the EU, customs doesn't automatically know they're EU goods. Without proof of Union status they can be treated as non-Union and charged import duty. The proof is a T2L (or T2LF). Nexport Logistics arranges that proof, or relies on the carrier's manifest status, so your Union goods stay Union goods, in the Nexportal platform.
T2L vs T2LF
- T2L proves goods have Union customs status (in free circulation in the EU customs territory).
- T2LF is the same proof, but for goods moving to or from a special fiscal territory of the EU (e.g. the Canary Islands, Åland): territories inside the customs union but outside the EU VAT area, so VAT may apply on arrival. On the export side these movements use a CO-A declaration; CO-A and T2LF go together.
Why you need it
The EU customs territory isn't one continuous landmass. Move Union goods by sea from, say, Rotterdam to another EU port, and the goods' Union status isn't presumed. You have to prove it, or they're handled as non-Union (duty, formalities). T2L/T2LF is that proof; it's also used to establish status for goods that have been in temporary storage or moved through a third country.
Now digital: the PoUS system
Paper T2L/T2LF is being replaced by the EU PoUS (Proof of Union Status) system, an electronic, EU-wide register where the proof is lodged and gets an MRN:
- Phase 1 (T2L / T2LF data): live since 1 March 2024. T2L/T2LF are created and validated electronically in PoUS.
- Phase 2 (Customs Goods Manifest, CGM / CGMF): live since 15 August 2025. The shipping manifest itself becomes a CGM/CGMF that can prove Union status digitally. (The Commission extended the transitional rules beyond that date, so authorised issuers may temporarily keep working outside PoUS.)
It's the customs-status equivalent of the wider move to EU customs IT systems.
The carrier shortcut: status code C on the manifest
A point that's often misunderstood: in practice a shipping line doesn't issue a T2L. It usually isn't the carrier's document; a T2L is lodged by a customs declarant (the exporter's representative) in PoUS. What the carrier can do is make a separate T2L unnecessary. A shipping company that sails regular, recognised routes between EU Member States can be an Authorised Issuer (toegelaten afgever) and use its cargo / customs goods manifest as the proof of status, marking each line with a status code:
- C: Union goods (the equivalent of a T2L);
- F: Union goods to/from a special fiscal territory (the equivalent of a T2LF);
- N: non-Union goods.
When the line is an authorised issuer, it self-validates the manifest and a separate T2L is not needed: the C on the manifest is the proof. So if a carrier tells you "we don't do a T2L, we have C-status on the manifest," that's this simplification.
How Nexport Logistics handles it
A T2L is lodged by a customs declarant, and we have our own. We check whether your move needs a T2L/T2LF, prepare it and file it in PoUS for the MRN. Where the carrier is an authorised issuer, we rely on the manifest C-status instead of a separate document. Either way your Union goods are proven as Union goods, tracked with your Customs and B/L in Nexportal.
Moving Union goods by sea, or to or from a special fiscal territory? Email info@nexportlogistics.nl.
Official sources: Douane — Proof of Union Status (PoUS) · European Commission — Proof of Union Status system · Douane handbook — afgifte T2L/T2LF. Related: Customs · Customs It Systems · Shipping Documents