Since ATLAS release 8.4/AES release 2.1 has gone live, you, as an economic operator, must use an EORI number. From this point on it is no longer possible to use, or to be identified, within the ATLAS system without the EORI.
For the time being, an economic operator who has not yet been assigned an EORI number may continue to lodge customs, export, and/or transit declarations as long as he or she can prove to have submitted an application for an EORI number either with the General Directorate of Customs’ Master Data Management office in Dresden (i.e. GZD – DO Dresden – Stammdatenmanagement) or with the competent authority in another Member State. Where it is the case that you already have requested an EORI number from GZD – DO Dresden – Stammdatenmanagement, it is necessary that you provide a copy of your online operator request, or of form 0870, together with proof that you have indeed sent off the relevant application to that office, which may be in the form of a fax transmission report. Should you have requested an EORI number in a different Member State, you must also furnish suitable proof of having lodged the relevant application. It is then for the customs office to decide whether the supporting documents you provided justify your request for a derogation. Such exception does not extend to ATLAS participants for whom it is mandatory to have an EORI number.