UPDATE: BAFA fact sheet on Art. 5 of the new Dual-Use Regulation

In the future, the ‘carrier’ must be specified in every export declaration with their EORI number (or alternatively TCUI number for carriers based in the third country). In Germany, this change will be introduced with the AES release 3.0, which is to be implemented as part of a soft migration by April 2023 at the latest. This is likely to pose a massive challenge for many exporters. In my opinion, the only practical solution is to separate the export declaration and the ASumA (the summary of exit display) and to submit the ASumA separately. The carrier is obliged to submit the ASumA before the goods actually leave. Since all ASumA data was already available when the ABD was created, the ASumA information could be transmitted together with the ABD by the exporter, which, to my knowledge, is almost always the case in Germany and makes a separate ASumA largely obsolete. The now necessary separation of ABD and ASumA is likely to lead to an unbearable burden on freight forwarders and logistics companies and to delays in exports.