Most exporters assume the importer is whoever receives the goods. The importer is whoever declares them. That party lodges the customs declaration in its own name, owes what the declaration generates, and is the one the authorities write to when something about the product, the value or the origin turns out to be wrong. The role is not a courtesy and it is not transferable after the fact: it follows the declaration, and the declaration follows the commercial terms you agreed when you quoted.
Selling to a European importer, or being the importer yourself?
Both arrangements move the same container to the same warehouse, and they are different businesses. In the first, you sell goods at a border: your customer declares them, pays what is due, and takes on the European obligations attached to putting the product on the market. In the second, you sell goods already inside the Union: you declared them, you paid, and every European obligation attached to the product is yours until a European distributor takes its own share. The price looks comparable on a spreadsheet. The exposure does not.
- Who lodges the declaration. The importer, in its own name, through a customs representative or directly. A forwarder acting for you is not the importer: it is an agent, and the declaration still says who the principal is.
- Who owes the customs debt. Duty, and any measure that attaches to the goods, follow the declarant. If a later audit finds the classification or the origin was wrong, the bill goes to the party named on the declaration, not to the one who prepared the invoice.
- Who pays the import VAT, and who can deduct it. Import VAT is charged to the importer. Deducting it requires a VAT registration in the Member State concerned, which a company with no presence there does not have by default.
- Whose name is on the product and in the file. The party established in the Union that places the product on the market appears on the labelling, holds the technical file and answers the market surveillance authority. If that party is a shell with no capacity to answer, the whole range is at risk.
- Who the injured customer sues. European product liability reaches the manufacturer and, when the manufacturer is outside the Union, the importer who brought the product in. Choosing to be the importer is choosing to be the defendant reachable in a European court.
Who needs an economic operator number, and which state issues it?
Any party that lodges a customs declaration in the Union needs an economic operator registration and identification number — the EORI number. It identifies you across every customs office of the Union, it is unique, and nobody else's can be used in your place. A company established in the Union obtains it from the Member State where it is established. A company established outside the Union obtains it from the Member State where it first needs it, which in practice means the state where it will lodge its first declaration or apply for its first authorisation. Each Member State runs its own application procedure, asks for its own supporting documents and takes its own time over it — so the question is never only whether you need the number, but which administration you will be dealing with for years afterwards.
What the importer status makes you carry
- Product compliance, in full. Verifying that the manufacturer did the conformity assessment, that the declaration of conformity exists and that the technical file can be produced on request. Keeping your own name and address on the product or its packaging. Not placing a product you have reason to believe non-compliant on the market.
- The customs debt, including the part discovered later. Classification, origin and customs value are declared by you and audited afterwards. A correction reaches back over the period the authority is entitled to review, with interest — which is why an error repeated on every shipment is far more expensive than the same error made once.
- Import VAT, and the registration that lets you recover it. Import VAT is not a tax on your margin: it is recoverable, but only by a party registered for VAT in the right Member State and holding the import document in its own name. Without that registration it stops being recoverable and starts being a cost.
- Product liability, and the obligations that come with selling. Beyond safety, the importer inherits the duties attached to being the one who supplies the European market: monitoring complaints, cooperating on corrective action, registering for extended producer responsibility where the product falls within it, and holding insurance that actually covers this territory.
Why delivered duty paid makes you the importer without anyone writing it down
A European buyer asks for a landed price, all taxes and duties included, delivered to its door. It is an entirely reasonable request and it sounds like a transport arrangement. It is not. Quoting on those terms means you undertake to clear the goods for import, which means you are the declarant, which means you have just taken the importer's status — the customs debt, the import VAT, the compliance file and the liability — in a sentence nobody negotiated. The consequences follow immediately. In several Member States a company not established in the Union cannot lodge an import declaration in its own name without a representative who accepts joint liability, and finding one takes longer than the voyage. And the import VAT you pay at the border is only recoverable if you are VAT registered there, so a seller who has not registered has quietly turned a recoverable tax into a loss on every order.
What to settle before the order is confirmed
- Decide who is the importer, and write the name. Not « the customer handles customs » but the legal name, the address and the operator number of the party that will lodge the declaration. If that party is you, say so knowingly; if it is the buyer, have the buyer confirm it in the order.
- Choose the commercial term to match that decision. Terms that stop at delivery without import clearance leave the status with the buyer; terms that include duties paid move it to you. Pick the term because of who should be the importer, not because of who should pay the freight.
- If it is you, register before you ship. The operator number, the VAT registration in the Member State of entry, a customs representative who has accepted the file in writing, and the compliance documents in the name that will appear on the product. All of it before the booking, none of it while the container waits.
- Say in the contract who bears a later correction. Classification, origin and value are audited after the goods are sold. The party that will receive that notice should know it, and the party that supplied the data on which the declaration was based should have undertaken that the data was right.
Before quoting a landed price to a European customer, ask yourself one question: if a customs officer opens this file in years to come, whose name is on the declaration? If the answer is yours, the quotation is not a price — it is a decision to become a European importer, and it needs a registration, a representative, a VAT number and an insurance policy behind it. If the answer is the buyer's, get the buyer's operator number in writing before the goods leave, because a consignment that arrives with nobody willing to declare it does not wait patiently — it accrues storage and becomes everyone's problem at once.
Where to read it yourself
Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.