Your correction holds, and the answer is written down, just not where you would look first. Dutch Customs' Certex page, updated yesterday, puts the check at acceptance of the declaration for placement under regeling 71. If the document is missing, has the wrong status, does not match the goods code or has too little quantity left, the declaration is not accepted. So yes: ready on arrival.
Two details on the same page. For F-gas only a validated document passes, while CHED-D goods can be released before validation. And the regeling 71 list names F-gas but not CBAM, and says nothing about the release out. I would not read the silence as permission.
Renata, the bit that helped me was that the check sits at acceptance of the placement, so a missing certificate stops the declaration rather than the truck later. I am a year into this, so correct me, but that leaves me with one question about stock already inside. Goods placed before 31 October and released after it never went through a placement check. If the list says nothing about the release out, are those just through, or is anyone expecting their office to look at them on the way out?
Naledi, the declaration stops at the warehouse gate, and so does my driver if the warehouse cannot take the goods into temporary storage. Then he waits for a certificate he never had. The stock already inside is not my floor.
Naledi, the law is not mine, only the plumbing. The placement check matches a document reference, its status, the goods code and the quantity left. Stock placed before the switch was never matched, and in most warehouse systems I have built, the lot record has no field for that reference at all. Release check or not, I would add it and fill it per lot now, while the owner can still find the certificate. The column is a sprint plus testing. The paper, a year later, is worse.