Your ERP generates hundreds of intra-EU goods movements every month. If your customs team still spends several days recompiling that data in a spreadsheet before manually uploading it to national declaration portals, you have not solved the problem — you have deferred it by a month. The 2022 Intrastat reform fundamentally reshaped EU statistical reporting obligations: the traditional combined goods declaration was split into two separate flows, and new mandatory fields were added. Four years on, a significant share of mid-market exporters have still not updated their ERP configuration accordingly.
This guide explains what changed, what your ERP must transmit each month, and how to configure the leading solutions to automate your declarations.
From the Old DEB to the New Intrastat Framework: Understanding the 2022 Reform
What Changed: Separation of Statistical and Fiscal Flows
Since 1 January 2022, the French DEB (Déclaration d’échanges de biens) no longer exists. It was replaced by two distinct obligations that answer to different submission calendars and different collecting authorities (douane.gouv.fr):
EMEBI (Enquête Mensuelle sur les Echanges de Biens intra-UE) is a purely statistical obligation, managed by the French customs authority (DGDDI). Unlike the former DEB, it only applies to companies selected by formal letter-notification from the DGDDI — it is not universal. Its purpose is to feed the foreign trade statistics of the Banque de France and Eurostat. For non-French EU companies, the equivalent obligation exists under national Intrastat rules administered by each member state’s statistical authority.
ERTVA (Etat Récapitulatif TVA) replaces the fiscal dimension of the former DEB. It lists VAT-exempt intra-community supplies and applies from the first euro, with no threshold, to all companies making B2B sales to buyers in other member states. It is submitted via the DEBWEB2022 portal (douane.gouv.fr) no later than the 10th working day following the reference month (douane.gouv.fr — EMEBI 2026 calendar). The equivalent in other EU countries is the EC Sales List (ESL) or Zusammenfassende Meldung (ZM), filed through each country’s tax authority.
Three additional mandatory fields since 2022: mode of transport (1 = maritime, 3 = road, 4 = air, 5 = postal/courier), country of origin of the goods (even if they transit through another EU country), and the buyer’s VAT registration number for dispatches. These fields did not exist or were optional under the old regime.
2026 Intrastat Thresholds by EU Country
France operates on a sampling model: only companies notified by the DGDDI are subject to EMEBI. The ERTVA, however, applies to all companies with no threshold. Other EU member states use monetary thresholds to define reporting obligations (eurofiscalis.com — EU Intrastat Thresholds 2026):
| Country | Arrivals (threshold) | Dispatches (threshold) | Filing deadline |
|---|---|---|---|
| France | DGDDI selection | DGDDI selection | 10th working day |
| Germany | EUR 3,000,000 | EUR 1,000,000 | 10th working day |
| Netherlands | CBS selection | CBS selection | 10th working day |
| Belgium | EUR 1,500,000 | EUR 1,000,000 | 20th of the month |
| Spain | EUR 400,000 | EUR 400,000 | 12th of the month |
| Italy | EUR 350,000 | From first euro (dispatches) | 25th of the month |
Germany significantly raised its thresholds in 2025, moving from EUR 800,000 to EUR 3,000,000 for arrivals. The Netherlands, like France, operates on a statistical-authority selection model via Statistics Netherlands (CBS).
What Your ERP Must Declare Each Month
Mandatory Data Fields: NC8 Code, Weight, Value, Origin
Every Intrastat declaration line must contain the following variables, per EU Regulation 638/2004 as amended (perspectives-conseils.com):
- 8-digit Combined Nomenclature code (CN8/NC8): the most sensitive field. This code classifies the goods according to the EU’s Combined Nomenclature. An incorrect or expired code invalidates the declaration and exposes the company to penalties. The nomenclature is updated every 1 January and obsolete codes must be refreshed in the ERP item master.
- Country of destination (dispatches) or country of origin (arrivals): the 2-letter ISO code of the EU partner country.
- Country of origin of the goods: added in 2022, this field records the non-preferential origin of the goods, which may be a third country outside the EU.
- Statistical value: the frontier value of the goods, in euros.
- Net weight in kilograms: plus supplementary units when the nomenclature requires them.
- Mode of transport: single-digit code based on the main mode used at the border.
- Transaction code: 11 (standard purchase/sale), 21 (return of goods), etc.
- Buyer’s VAT number (for dispatches, mandatory since 2022).
The EC Sales List (ESL/DES): Differences from Intrastat Goods Reporting
The EC Sales List (called DES in France) covers services rendered to VAT-registered buyers established in another member state (B2B, reverse-charge rule). It is distinct from Intrastat, which covers goods only. Two key differences:
No threshold: the ESL is mandatory from the first transaction, with no minimum. A company that invoices EUR 5,000 in consulting to a Belgian client must file an ESL for that month.
Different deadline: the ESL must be submitted no later than the 10th working day of the following month. In France it is filed via the impots.gouv.fr portal (DGFiP), not the douane.gouv.fr portal used for ERTVA and EMEBI. In other EU countries, the equivalent is filed through national tax authority portals.
Practical consequence for your ERP: service billing flows must be separated from goods flows in the configuration of intra-EU VAT transaction codes.
ERP Configuration for Automatic Intrastat Reporting
SAP S/4HANA: International Trade Module Replaces Legacy ECC Setup
In SAP ECC, Intrastat commodity codes were maintained in table T604 and declarations generated via MM-FT Foreign Trade transactions. In S/4HANA this architecture has changed: T604 is replaced by table /SAPSLL/CLSNR (descriptions in /SAPSLL/CLSNRT), and Intrastat processing is handled by the International Trade module, accessible in SPRO under Governance, Risk and Compliance → International Trade → Intrastat (SAP Community).
Configuration involves:
- Assigning CN8 codes to item master records (via the Basic Data → Customs Data segment) — any item without a CN8 code will be excluded from the generated declaration.
- Configuring transaction types (11, 21, etc.) in Customizing.
- Using dedicated Fiori apps to create, correct, and export Intrastat declarations (Fiori App “Intrastat Declaration”).
- Exporting in EDI or text file format compatible with national submission portals (e.g. DEBWEB2022 for France, IDEP.web for Belgium, eSTATISTIK.core for Germany).
ECC-to-S/4HANA migration projects must include a CN8 code verification phase: T604 data does not migrate automatically to /SAPSLL/CLSNR without a dedicated conversion step.
Dynamics 365 Finance & Operations: Built-In Localizations for EU Countries
Microsoft provides native EU Intrastat localizations in D365 Finance, including formats recognized by the respective national customs authorities. For France, two accepted file formats are available: SAISUNIC 330 and INTRACOM (learn.microsoft.com — French Intrastat).
Configuration steps:
Tax → Setup → Foreign trade → Foreign trade parameters: enable the Intrastat feature, define transport codes and transaction nature codes.Tax → Setup → Sales tax → Tax exempt numbers: register EU partner VAT numbers.- Assign CN8 codes in the released product master (Released product → Foreign trade tab).
To generate and submit the declaration: Tax → Declarations → Foreign trade → Intrastat → select the period → generate the file in the required format → upload manually to the national portal, or automate via a third-party EDI connector. Since direct portal connectivity is not natively included in D365, companies processing several hundred lines per month should evaluate a customs connector (ASD Group, Tradenet) to automate submission across multiple EU portals.
Odoo 17: Native Intrastat Module Since Version 16
Odoo has included a native Intrastat module since version 16, enabled at Accounting → Configuration → Settings → Customer Invoices → Intrastat (odoo.com/documentation/17.0). Configurable fields include default transaction codes, transport codes, and country of origin codes.
For French companies subject to EMEBI, a complementary EMEBI module (available on the Odoo App Store) adds the DGDDI-compliant declaration structure and separates dispatch and arrival flows. The generation path is: Accounting → Declarations → Intrastat → EMEBI.
The key watch point with Odoo: CN8 codes must be filled in on every product sold internationally. Without that data, the generated Intrastat declaration is incomplete — Odoo does not block invoicing when the code is missing.
Sage X3: FREECEXP and FREECINT Templates
Sage X3 includes a native intra-EU goods declaration function (DEB/EMEBI), accessible via the Purchases/Sales → Declarations menu. For France, Sage X3 uses two specific import/export templates (Sage X3 online help — FUNDEB):
- FREECEXP: template for dispatches (outbound flows to another EU country)
- FREECINT: template for arrivals (inbound flows from another EU country)
Configuration requires populating nomenclature codes (CN8) in item masters, and defining statistical regimes and transport modes in customs parameters. Third-party connectors (ASD Group, Tradenet, CustomsCalc) handle automatic submission to national declaration portals — DEBWEB2022 for France, IDEP.web for Belgium, eSTATISTIK.core for Germany — eliminating manual re-entry entirely.
Most Common Errors and How to Prevent Them
Incorrect or Outdated CN8 Codes on Items
This is the number one error. Combined Nomenclature codes are revised every 1 January: some codes are deleted, others are created or subdivided. An ERP whose item master has not been updated since 1 January generates declarations with expired codes.
French customs authorities report a high error rate on Combined Nomenclature codes among EMEBI filers (douane.gouv.fr), and the same pattern applies across EU member states. The fix requires an annual refresh of the item master in the ERP, ideally automated via a feed from the TARIC database maintained by the European Commission.
Corrective action: build a monthly ERP report listing all Intrastat movement lines where the CN8 code is blank or has fewer than 8 digits. Block invoicing on those items for EU export until the code is corrected.
Omitted Transactions: Returns, Partial Deliveries, Consignments
Intrastat does not only cover standard sales and purchases. Reportable flows also include: returns of goods (transaction code 21), partial deliveries on open orders, intra-group stock transfers between entities located in different EU countries, and goods on consignment that exceed the agreed return period.
These flows are often configured as “non-Intrastat” by default in the ERP, since they do not match a standard commercial transaction pattern. An audit of intercompany flows and returns is essential during any compliance project.
Correcting an Erroneous Declaration: Deadlines and Process
An incorrect or incomplete Intrastat declaration can be corrected through the relevant national portal. Corrections should not wait: the data feeds monthly foreign trade statistics and discrepancies detected by Eurostat can trigger formal follow-up from national customs authorities.
For the ERTVA (fiscal component in France), a late correction can result in a fine: EUR 750 per incomplete or incorrect declaration, rising to EUR 1,500 for repeat offences (perspectives-conseils.com). Adjustments related to intra-EU VAT exemption applied in error fall within the standard 3-year tax audit limitation period.
For the EMEBI statistical component, sanctions are lower — EUR 75 to EUR 150 per missing declaration, up to EUR 2,250 for repeat offences — but accumulating late corrections flags the company as an unreliable filer for subsequent reporting periods.
Pre-Submission Quality Checklist in Your ERP
Before uploading the monthly declaration to the national portal, run through these 8 checkpoints in your ERP:
- CN8 code completeness: zero Intrastat movement lines without an 8-digit CN8 code.
- CN8 code validity: verify that codes in use appear in the current version of the Combined Nomenclature (annual update on 1 January, via TARIC).
- Country of origin populated: no line missing the ISO country-of-origin code (mandatory since January 2022).
- Consistent transport mode: the transport code matches the mode actually used at the border, not the one anticipated at order entry.
- Buyer VAT number: for all dispatches, the buyer’s EU VAT number is validated (format and active status via the European Commission’s VIES service).
- Returns and credit notes included: credit notes on intra-EU sales or purchases are declared under transaction code 21 and not omitted.
- Intercompany transfers captured: stock movements between group entities located in different EU countries are included in the sending entity’s declaration.
- Accounting reconciliation: the total statistical value in the declaration reconciles with the intra-EU sales/purchase accounts in the general ledger for the same period.
A multi-entity group can centralise these controls in a consolidating entity that aggregates Intrastat data from all EU subsidiaries before submission, or opt for decentralised filing per entity — each approach has operational advantages depending on the flow volume and the group’s customs governance model.
Automating Intrastat declarations in your ERP is not a complex project — but it is a data project: the quality of CN8 codes, country-of-origin data, and VAT numbers in the item master drives 80% of compliance. The ERP configuration itself is well-documented and achievable in a few days for each solution.
To explore related regulatory obligations, read our guide on multi-country VAT automation in ERP (Avalara, SOVOS, Vertex), our article on France B2B e-invoicing: PDP, PPF and ERP compliance, and our guide to customs and international trade management in ERP.
