Under the article 233 of Reg. (EC) n. 2913/1992 (Community Customs Code , "CCC"), the customs debt shall be extinguished, among other things, when, with regard to the goods declared for a customs procedure entailing the obligation to pay duties, goods, after their irregular introduction in the EU customs territory, before their release, are either seized and simultaneously or subsequently confiscated.
The Court of Justice specifies that the extintion of the customs debt takes place only if the the seizure of goods unlawfully introduced into the customs territory of the Community has been executed before the goods have gone beyond the first customs office situated inside that territory. Accordingly, the seizure and confiscation of the goods after that time no longer results in an extinction of the customs debt.