Importer of record in the EU, your own Dutch company or a partner service

What an importer of record is in EU law

The term importer of record comes from trade practice, while EU customs law speaks of the declarant (Union Customs Code, Article 5(15)). A business that declares goods needs an EU customs number, the EORI number (Article 9).

Under Article 18, a direct representative declares in your name and on your behalf, while an indirect representative declares in its own name on your behalf. Companies from outside the EU usually choose indirect representation, because the declarant must be established in the EU.

A company from outside the EU registers for its EORI number in the EU country of its first customs operation. See the EORI number in the Netherlands.

Who can act as importer of record in the EU

The importer of record is the company named as declarant on the import declaration. For goods from outside the EU, several companies can take that role.

• Your own EU company. Your Dutch company declares the goods in its own name, with its own EORI number. A customs agent can lodge the declaration in its name, as direct representative.
• Your EU buyer. When you sell delivered at place (DAP), the buyer does the import clearance and pays the duty and the import VAT.
• An indirect customs representative. A company in the EU declares in its own name, on your behalf. It is debtor for the customs duty together with you (Article 77(3)). Importer of record services work this way.
• Your company abroad, in a few cases. For transit, temporary admission and occasional declarations, the declarant can be established outside the EU (Article 170).

EU importer of record requirements and responsibilities

• The customs debt. The importer pays or guarantees the import duty. With indirect representation, customs can recover the duty from the representative and from you (Article 77(3)).
• Import VAT. The importer needs a VAT number in the country of import, or a fiscal representative, a local firm that handles the VAT on its behalf. In the Netherlands, the Article 23 licence lets the importer report the import VAT in its VAT return and deduct it in the same return. See the Article 23 license in the Netherlands.
• Customs number and records. A business that declares needs an EORI number. The importer keeps the import documents, invoices and proofs of origin for customs and the tax office.
• Product rules. A consumer product may only be placed on the EU market if a business established in the EU, the economic operator, is responsible for it (General Product Safety Regulation, Article 16). The name and address of the importer go on the product or its packaging.
• Distance sales from 1 July 2028. For distance sales from outside the EU to EU consumers, the seller or the platform becomes the importer (Regulation (EU) 2026/2108, Article 5(14)). This importer is responsible for the customs debt, product compliance and record keeping. It must be established in the EU, or be represented by an EU company with the status of certified customs operator, Authorised Economic Operator (AEO). By 1 December 2027, the European Commission checks whether the central EU IT system for customs duty on distance sales will be ready for that date.
• Steel, aluminium, cement and fertilisers. Importers of more than 50 tonnes a year must use an authorised CBAM declarant established in the EU, and that status must be in place before the import. An importer from outside the EU works through an indirect customs representative with this status, who is then always the declarant. Your own Dutch company can apply for the status itself.

How importer of record services in Europe work

An importer of record service is a company in the EU that acts as indirect customs representative for you. It declares your goods in its own name and becomes debtor for the customs duty, together with you (Union Customs Code, Article 77(3)). Some providers also act as fiscal representative for the VAT.

In case C-714/20 of 12 May 2022, the Court of Justice of the EU ruled that EU customs law makes the indirect representative liable for the customs duty. Liability for the import VAT requires an explicit national rule.

You arrange the VAT yourself, with a VAT number or a fiscal representative in the country of import for the import VAT and your sales there. The right to deduct the import VAT belongs to the company that uses the goods for its taxed sales. That is the owner of the goods or the company that includes the import costs in its prices.

An importer of record service is a customs partner with its own contract with you. When you ask for one, our team introduces a partner for your goods and your country of import, and you see its price first.

Your own Dutch company as importer

Your own Dutch private limited company (BV) is established in the EU. It declares your goods in its own name with its own EORI number and has its own Dutch VAT number. With its own Article 23 licence, the company reports and deducts the import VAT in the same VAT return.

From its stock in the Netherlands, the company sells to buyers across the EU. It charges 0% VAT on sales to businesses in other EU countries and reports sales to Dutch consumers in its normal VAT return. Once its sales to consumers in other EU countries pass €10,000 a year, it files the EU VAT return for cross-border sales, the One Stop Shop (OSS).

The steps for the company and its registrations are on Dutch BV, VAT number, EORI number and Article 23 licence.

The company is also the EU importer under the product rules, and as importer it is liable for defective products. That liability applies under the EU product liability rules in force since 1985 and under the new rules for products placed on the market after 9 December 2026. The new rules add the authorised representative and the fulfilment service provider to the businesses that can be held liable.

A logistics provider or a warehouse as importer

A logistics provider in the Netherlands stores your goods and ships your orders. The importer is the company named as declarant in the customs declaration. That is usually the owner of the goods or its own EU company.

A customs broker that declares in the name of your Dutch company is a direct representative. Your company is then the declarant and the debtor for the duty. A broker that declares in its own name is an indirect representative and is debtor together with you (Dutch Customs handbook, 2026).

For medical devices the EU guidance says the same. A logistics company that only transports or stores devices is normally outside the roles of importer and distributor (MDCG 2021-27, 2023).

When your own Dutch company pays off

• Margin. Your Dutch company buys from your factory and sells to your buyers in Europe. It earns the margin on those sales in the EU and pays Dutch corporate tax of 19% on profit up to €200,000 and 25.8% above (2026).
• Stock. From a Dutch warehouse, you ship to buyers across the EU within days, and PostNL lists 2 to 3 working days to Germany (2025).
• Sales to business buyers. Your company invoices business buyers in other EU countries at 0% VAT on its own Dutch VAT number. European buyers deal with a European seller and a European contract.
• Bank. Your company can apply for a business bank account in the EU, so your buyers pay in euros to a European account. The bank decides after its own checks, and a complete file helps. See a business bank account for your Dutch company.
• One company, many roles. The same company can be the importer for customs, the economic operator for product safety, the applicant for the Article 23 licence and the authorised CBAM declarant.

For a single test order to one market, a partner service is often the quicker start, while your own company pays off once you import regularly.

What your own importer in the EU costs

We set up your Dutch company as one package with a starting price. Customs agents, warehouses and other partners charge their own prices, which you see in advance.

Your own EU importer for exporters from India and Turkey

The EU and India closed the negotiations on their trade agreement on 27 January 2026. On 11 September 2026 the European Commission sent the agreement to the Council for signature. After the signature, the European Parliament gives its consent, while India completes its own ratification. Under the agreement, the EU removes its tariffs on over 90% of tariff lines. The Commission names fisheries, chemicals, textiles, footwear and pharmaceuticals among the Indian sectors that benefit (European Commission, 2026). Once the agreement applies, your own importer in the EU claims the lower EU tariff on its imports from India, with the proof of origin from your factory. It then sells to European buyers from EU stock. See the EU and India trade agreement and a Dutch company from India.

Industrial goods from Turkey enter the EU duty-free under the customs union, in force since 1 January 1996, while separate rules apply to agriculture, coal and steel. Import VAT, the EORI number and the product rules still apply to every shipment. Each shipment from Turkey therefore needs an EU importer, a role your Dutch company can take. For steel and cement above 50 tonnes a year, the company can also apply to be the authorised CBAM declarant. See CBAM for exporters from Turkey.

Amazon shipments held at customs

Amazon treats the seller as the importer for stock sent to its fulfilment centres in the EU. According to its onboarding guide for EU and UK logistics (2024), the seller acts as importer of record or declarant and needs a VAT number in the EU country of import. For sellers established outside the EU, the guide names indirect representation for shipments to Germany and the United Kingdom.

For shipments to other EU countries, or when you want your own name on the declarations, your own EU company is the importer. Your current VAT numbers are in the name of your current company. When your Dutch company becomes the owner and importer of the stock, it registers for VAT in the countries where it keeps stock. Plan this before the first shipment.

Last reviewed on 13 November 2026 for customs representation, the importer roles and the product liability rules. The other sources were checked on 13 October 2026. Sources: Dutch Customs handbook, representation in customs declarations (changed 12 January 2026, in Dutch); Directive (EU) 2024/2853, Articles 2 and 8; Medical Device Coordination Group, MDCG 2021-27 rev. 1 on importers and distributors (December 2023); Union Customs Code, Regulation (EU) 952/2013, Articles 5, 9, 18, 77 and 170; Regulation (EU) 2026/2108 of 16 September 2026, Article 5(14) and recital 120 (most parts apply 12 months after entry into force, the distance sales rules from 1 July 2028); European Parliament, deal on the customs reform (March 2026); Council Regulation (EU) 2026/382, Article 3(2): the Commission check by 1 December 2027 (2026); Court of Justice of the EU, case C-714/20 (2022); European Commission, EORI number; General Product Safety Regulation (EU) 2023/988, Article 16; Finnish Customs, authorised CBAM declarant (2025); Business.gov.nl, CBAM: the 50 tonne threshold and the indirect customs representative (2026); European Commission, EU trade with Türkiye; European Commission, EU and India agreement (negotiations closed on 27 January 2026), proposal to the Council for signature (11 September 2026) and chapter-by-chapter summary (2026); Belastingdienst, corporate tax rates (2026); PostNL, international delivery times (2025); Amazon Global Logistics, EU and UK onboarding guide (2024).