Importer of record in the EU: a service provider or your own company
Your shipments wait at customs until an importer established in the EU is named. Service providers offer to take that role for a monthly fee. This page explains what the importer of record is in EU law, who can be it, and when your own Dutch company takes the role.
Ask about your situationEU customs law calls the importer of record the declarant: the person who lodges the customs declaration in its own name, or in whose name it is lodged (Union Customs Code, Article 5). The declarant must be established in the EU (Article 170), apart from a few cases such as transit.
A company from outside the EU has two options. It can work with an indirect customs representative: a company in the EU that declares in its own name for you and is liable with you for the customs duty. This is what importer of record services offer. Or it can set up its own EU company, which declares in its own name with its own customs number (EORI).
Your own Dutch company is then the importer, with its own VAT number, its own Article 23 licence for import VAT and its name on your products as the EU importer. It fits when you import regularly, keep stock in the EU or sell to several EU countries.
What an importer of record is in EU law
The term importer of record comes from trade practice. EU customs law uses the declarant: the person who lodges the declaration in its own name, or the person in whose name it is lodged (Union Customs Code, Article 5(15)). Every declarant has an EU customs number, the EORI number.
A representative can act in two ways (Article 18). A direct representative declares in your name and on your behalf. An indirect representative declares in its own name, on your behalf. For a company from outside the EU, only indirect representation is possible, 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.
What an importer of record service does
An importer of record service is a company in the EU that acts as indirect customs representative for you, sometimes together with fiscal representation for the VAT. It declares your goods in its own name and becomes debtor for the customs duty, together with you (Union Customs Code, Article 77(3)).
For import VAT, 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 needs an explicit national rule (case C-714/20, 12 May 2022).
The VAT side is yours: a VAT number in the country of import, or a fiscal representative, for the import VAT and your sales there. The right to deduct import VAT is for the company that uses the goods for its taxed sales: as owner, or with the import costs in its prices.
Your own company as importer
Your own Dutch company, a BV, is established in the EU. It declares your goods in its own name, with its own EORI number, or through a customs agent that acts as direct representative in its name. It has its own Dutch VAT number and applies for its own Article 23 licence; with the licence, the import VAT is reported and deducted in the same VAT return.
From its stock in the Netherlands, the company sells to buyers across the EU: 0% VAT on sales to businesses in other EU countries, and the One-Stop Shop (OSS) for sales to consumers.
The company is also the EU importer for product rules. Under the General Product Safety Regulation (GPSR), a consumer product may be placed on the EU market only when an economic operator established in the EU is responsible for it (Article 16). The name and address of the importer go on the product or its packaging. The importer is also liable for defective products: under the EU product liability rules since 1985, and under the new rules for products placed on the market after 9 December 2026, which add the authorised representative and the fulfilment service provider.
Service or own company: the comparison
| Importer of record service | Your own Dutch company | |
|---|---|---|
| Declarant for customs | The provider, as indirect representative | Your company, or a customs agent in its name |
| Liability for the customs duty | The provider and you together | Your company |
| Import VAT | Your own VAT number, or a fiscal representative with the Article 23 licence | Your own Dutch VAT number and Article 23 licence |
| EU importer named on the product | The provider, when it takes that role | Your company |
| Stock and sales in the EU | Arranged per shipment | From your own stock, in your own name |
| Suits | A first shipment, a test of one market | Regular imports, stock in the EU, sales in several countries |
Amazon shipments held at customs
Amazon treats the seller as the importer for stock sent to its fulfilment centres in the EU. Its onboarding guide for EU and UK logistics (2024) says that the seller acts as importer of record or declarant, and that a VAT number is needed 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.
Sources: Union Customs Code, Regulation (EU) 952/2013, Articles 5, 18, 77 and 170, replaced by Regulation (EU) 2026/2108 from 21 September 2027; Court of Justice of the EU, case C-714/20 of 12 May 2022; European Commission, EORI number; Dutch Customs, handbook on customs representation; General Product Safety Regulation (EU) 2023/988, Article 16; Amazon Global Logistics, EU and UK onboarding guide (2024). Checked on 25 September 2026.
Who does what
Holdwise sets up and manages the Dutch company that is your importer. Customs agents, the warehouse and product specialists do the physical and technical work. You keep one contact.
Your company
- Your products, your suppliers and your prices
- Product documents: technical file, labels, safety information
- Your marketplace accounts and your sales plan
The Dutch base
- Sets up the Dutch BV by power of attorney, with the notary
- EORI customs number, VAT number and the Article 23 application
- VAT registrations where the company keeps stock, and the One-Stop Shop
- Bookkeeping and VAT returns, month by month
Customs, storage, product rules
- Customs agent for the declarations
- Warehouse and fulfilment in the Netherlands
- Product compliance: GPSR, CE marking, labels
Step by step
From goods waiting at customs to imports in the name of your own company.
- Your imports. You share your products, your volumes, the countries of import and your sales channels. Holdwise answers in writing which importer set-up fits.
- The company. The notary sets up the Dutch BV by power of attorney, usually within one week once all documents are complete.
- The numbers. EORI customs number, VAT number and the Article 23 application, plus VAT registrations where the stock will be.
- The product side. The name and address of the Dutch company go on the products or the packaging as the EU importer.
- The first shipment. The customs agent declares the goods for your Dutch company.
- Every month. Bookkeeping and VAT returns, and the One-Stop Shop return every quarter for sales to consumers.
Related guides
More on customs, import VAT and product rules for importers.
Common questions
Ask about your own situation
Tell us what you make or sell, where your company is and which countries you want to sell in. You get a written answer. Where a Dutch company fits, we write down what it would look like and what it costs.
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