Fallback procedure

Two things have to happen before departure. The consignor informs the competent main customs office in writing about the outage, and does so before the first movement under the fallback procedure begins (section 36 (2) AlkStV). That notification is not required where the Federal Information Technology Centre has published the outage itself. The fallback document is drawn up in triplicate, and one copy travels with the goods.

Everything left pending in the system is caught up afterwards. Once EMCS is usable again the consignor submits the draft e-AD without delay, and the ARC that is issued is noted on the fallback document. The same goes for the follow-up messages: cancellation, change of destination or consignee and the report of receipt or export first run on paper and are then pulled through electronically (sections 37 to 39 AlkStV).

The fallback procedure is therefore not a second route alongside EMCS but a shifted sequence. The movement is only discharged once the electronic record is closed. Until then the goods remain in a live duty suspension arrangement, with every obligation that comes with it.

The most common mistake is the catching up itself. The goods travel on the fallback document, arrive, are stored, and in day to day terms the job looks done. Electronically it is still open and stays open until someone captures it. Such cases surface at the latest during an audit, as a duty suspended movement that was never discharged.

The second mistake is a mismatch between the paper and the later electronic record, for instance because a pallet was dropped at short notice. What the fallback document states has to reappear in the e-AD; quantity differences belong in the report of receipt, not in a correction email to the consignor.