One Number Follows the Goods to the Last Border

The Number That Starts Everything

An EORI number is the identity an operator uses for every customs transaction in the European Union. It is issued by a member state, it is checked at every declaration, and without it nothing can be lodged. A company established in the EU applies to the customs authority of the country where it is established or where it first does business. A company outside the EU can hold one, but only through a representative and only in the member state where it first lodges a declaration.

The detail that catches buyers is that the EORI is a customs identity, not a tax identity. It does not make you liable to VAT, and it does not by itself entitle you to recover import VAT. Those are separate registrations, in a specific member state, and the second one is the one that determines whether the VAT on your import is a cost or a cash-flow item.

Check the number before the booking, not after. A wrong digit on a declaration does not produce an error message; it produces a customs broker on the phone at the destination, a revised declaration, and a container that waits. The EORI validation service on the Commission's site takes seconds and is free.

Who Can Be the Importer of Record

The importer of record is the party on whose behalf the goods are declared. In most member states it must be established in the EU, or represented by someone who is. Indirect representation — where the representative is jointly liable for the duty — is a distinct legal arrangement from direct representation, and the two are not interchangeable when something goes wrong.

A Chinese seller shipping DDP to the EU therefore needs either an EU establishment or a fiscal and customs representative. Where the buyer is a VAT-registered EU company, the clean arrangement is usually the reverse: the buyer imports on its own EORI, and the seller's price is DAP or DDP with the duty and VAT recharged. That keeps the import VAT recoverable by the party that can recover it and keeps the duty liability with the party that owns the goods.

Since the General Product Safety Regulation took effect, there is a second, separate requirement that has nothing to do with customs. Consumer products placed on the EU market need a responsible economic operator established in the union, named with a contact address on the product or its packaging. A factory in Guangdong cannot be that operator. The importer usually is, and the label has to say so before the goods are offered for sale.

Import VAT, and Getting It Back

Import VAT is charged when the goods are released for free circulation, and it is charged on a base that includes the customs value, the duty, and the freight and insurance to the EU border. On a container of consumer goods that base is meaningfully larger than the invoice value, and the VAT is calculated on that larger number.

The charge is normally recoverable, in full, by a VAT-registered importer in the member state of import, through the periodic return. What it costs is cash and time: the VAT is paid at the border, the recovery comes one to three months later depending on the filing cycle. On a large container that gap is a real working-capital item, and it is the single most common reason a first-time importer is surprised by the cost of importing into Europe.

Several member states allow postponed accounting, where the import VAT is declared in the return instead of paid at the border, removing the gap entirely. Whether it is available, and on what conditions, depends on the country and on the importer's registration. It is worth asking the question before the first shipment rather than after it.

Two practical points. VAT paid at import is not recoverable if the importer is not registered in that member state, so a UK or US company importing directly into Rotterdam will find the VAT is a cost, not a credit. And a refund claim from abroad is a slow administrative process with its own deadlines, not a substitute for registration.

IOSS and the Parcel Trade

The Import One-Stop Shop is the mechanism for business-to-consumer sales of goods with an intrinsic value of up to 150 euros. The seller, or an intermediary acting for it, registers in one member state, charges VAT at the rate of the customer's country at the point of sale, and reports the whole thing in one return. The parcel then arrives with the VAT already accounted for and no collection at the door.

Above 150 euros, IOSS does not apply: the parcel is imported normally, duty is charged, VAT is charged at import, and the carrier usually collects both from the consumer plus a handling fee. That fee is often larger than the VAT, and it is the reason cross-border parcel economics change abruptly at the threshold.

For a fair buyer, the question is whether the goods are going to a business or to a consumer. A pallet to a retailer's warehouse is a normal import. Individual parcels to consumers, drop-shipped from a Chinese warehouse, are a different business with a different tax mechanism, and mixing the two on one commercial invoice creates an entry that is neither.

IOSS registration is not open to every seller: a non-EU business normally needs an EU-established intermediary. That intermediary carries obligations, and it is worth establishing who is liable for the VAT if the return is filed late.

Advance Data Before the Goods Move

ICS2 is the EU's advance cargo information system. It requires an entry summary declaration, filed electronically, before the goods are loaded — for maritime cargo, before loading at the foreign port. The carrier files it, but the data comes from the shipper, and the shipper's data is where it usually fails.

What the filing needs is the same six-digit HS code, a precise goods description, the consignee with a valid EORI, and the party responsible for the goods. A description of "general cargo" or "parts" is rejected. A house bill with no EORI for the consignee produces a filing that cannot be completed, and a container that cannot be loaded.

The system arrived by transport mode, on separate timetables, and the maritime phase is the last and the largest. Carriers have built their own cut-offs in front of the legal deadline, typically several days before sailing, because they need time to transmit and to absorb rejections. Those carrier cut-offs, not the regulation, are what a shipper actually experiences.

The consequence for a buyer is straightforward: the supplier has to send complete shipment data earlier than they did five years ago, and a factory that treats the bill of lading instruction as something to do the day before sailing will miss boats. Put the data requirement in the purchase order.

Duty, Origin and the Anti-Dumping Question

Duty in the EU is set by the TARIC classification, ten digits, and calculated on the customs value. Chinese-origin goods pay the erga omnes rate unless a trade defence measure applies. There is no general preference for Chinese goods into the EU; the preference question is the other direction.

Anti-dumping and countervailing measures are the part buyers miss. The EU maintains measures on a long list of products from China — certain steel products, ceramics, solar glass, bicycles, and many others — and where a measure applies the duty can be multiples of the standard rate. Some measures allow a company-specific rate for cooperating exporters, which means the same product from two factories can enter at very different cost. The only way to know is to check the measure for the exact product and the exact exporter.

Rules of origin matter if you intend to re-export or to claim preference elsewhere. Chinese-origin goods do not acquire EU origin by being repacked in Rotterdam. Substantial transformation is a legal test, not a warehouse operation, and the paperwork supporting a change of origin has to survive an audit years later.

One more regime sits on top of duty for a defined list of goods. The carbon border adjustment mechanism applies to imports of steel, aluminium, cement, fertiliser, electricity and hydrogen, and it moved from reporting to a financial obligation with certificates. The scope and the thresholds have been adjusted more than once, including a de minimis for small importers. If your product is on that list, confirm the current position before you price it.

Product Rules That Stop a Container

Customs will release goods that cannot legally be sold. The distinction matters because a container can be cleared, delivered, and then be unsellable, which is a worse outcome than a hold at the port.

The CE mark is a declaration by the manufacturer that the product meets the applicable directives, backed by a technical file and, for many categories, a conformity assessment involving a notified body. Applying the mark without the file is unlawful and is checked in the market, not at the border. Which directives apply depends on the product: low voltage, electromagnetic compatibility, machinery, toys, medical devices, radio equipment, and so on.

REACH restricts substances and requires registration for substances manufactured or imported above a threshold; the candidate list of substances of very high concern carries communication duties even at low concentrations. RoHS restricts hazardous substances in electrical equipment. Packaging has its own rules on heavy metals and, increasingly, on recyclability and recycled content.

For food contact articles, the framework regulation plus the material-specific measures decide what the plastic, coating or paper may contain and what migration testing is expected. A supplier who can produce a test report for the exact material and the exact application is worth more than one who can produce a certificate with no product name on it.

One Clearance, Twenty-Seven Markets

Once goods are released for free circulation in one member state, they move freely across the union. That is the practical advantage of the single market and the reason many importers clear in Rotterdam, Antwerp or Hamburg and truck onward.

It is not a licence to choose the easiest border. The member state of import is where the VAT is due and where the entry is lodged, and the choice has consequences: registration obligations, the availability of postponed accounting, the cost of the onward leg, and the audit risk profile of that administration. Clearance shopping is legitimate when it reflects a real commercial route and questionable when it is only a way to avoid a registration.

Where goods are cleared in one country and sold in another, distance selling rules can create a second VAT registration in the destination country once a turnover threshold is passed. That threshold is set per country, and the sale of goods already in free circulation is a domestic supply, not an import — a different mechanism from the one described above.

For a buyer working from Guangzhou, the useful planning question is where the goods will actually be sold and stored. Clear near the warehouse, not near the cheapest broker. Our Netherlands and Germany pages cover the two most common first entry points.

FAQ