How to Export to the EU: A Step-by-Step Guide for Non-EU Sellers

Who imports: the declarant, a representative and EORI

EU law has no importer of record; the key role is the declarant, who lodges the customs declaration in its own name or in whose name it is lodged. The declarant must normally be established in the EU (Union Customs Code, Article 170), with narrow exceptions such as transit, temporary admission and occasional declarations that customs accept as justified. A customs representative can act directly, in your name, or indirectly, in its own name on your behalf (Article 18). Under direct representation you stay the declarant, so a non-EU seller selling DDP normally uses an EU-established indirect representative, and both then owe the customs duty (see Triplicate's note on the importer of record).

The declarant needs an EORI number. Every economic operator established in the EU must register (Article 9), and a business holds only one valid EORI, used in every EU country. A non-EU business has no general obligation to get one just to sell to EU buyers: it registers only before it lodges a customs declaration, an entry or exit summary declaration or a temporary storage declaration itself, or acts as a carrier, and then once, in the EU country of its first customs operation. A VAT number is not an EORI, so check your buyer's number in the European Commission's EORI validation service (see Triplicate's note on EORI numbers). Who imports follows from the Incoterm and the type of sale:

• DAP, FCA, FOB or EXW: the EU buyer or its broker declares the goods with its own EORI and pays duty and import VAT.
• DDP: you take this on through an EU indirect representative appointed in writing; agree whose EORI goes in the importer and declarant fields. ICC advises sellers that cannot meet DDP obligations to use DAP or DPU.
• Consumer parcels up to EUR 150: VAT goes through your IOSS registration or the marketplace; give the IOSS number to the carrier or postal operator. Consumers normally need no EORI.

Customs value, TARIC code and origin

Duty is charged on the customs value, normally the transaction value: the price actually paid or payable, plus costs the buyer bears that the price leaves out, such as selling commissions, packing, assists and royalties paid as a condition of sale. The EU adds transport, insurance and related costs up to the point where the goods enter the EU, a CIF-type value (Union Customs Code, Article 71), and leaves out transport after the border. Show freight and insurance as separate amounts on the invoice, even on a CIF or DDP price, so that customs can count only the costs up to the border.

The duty rate depends on the tariff code and the country of origin. The first 6 digits of the code are the Harmonized System; the EU Combined Nomenclature uses 8 digits and TARIC 10, and the declaration uses the EU's full code, not your own country's export code. Check the duty and any preferential rate for the code in TARIC, and for certainty before you ship, ask for EU binding tariff information, which is valid for 3 years.

Non-preferential origin is usually the country of the last substantial transformation (in the EU, the last substantial, economically justified processing, Union Customs Code Article 60), so goods only repacked or relabelled in another country keep their origin. A lower rate under a trade agreement depends on preferential origin and its own proof, described below.

Import VAT, IOSS and the EUR 3 duty on consumer parcels

Import VAT is charged on top of duty at the rate of the country of import. A VAT-registered business buyer can usually deduct it; a consumer cannot. If you sell DDP and owe the import VAT yourself, your onward sale to the buyer is treated as taking place in that country, so you usually need a VAT registration there; take local VAT advice before quoting DDP.

For distance sales to consumers in consignments with an intrinsic value up to EUR 150 (the goods' price without transport and insurance, unless these are included in the price and not shown separately), the Import One-Stop Shop (IOSS) lets you charge EU VAT at checkout through one registration. Import is then VAT-exempt, so the customer pays no VAT at delivery; excise goods are excluded. A seller established outside the EU must appoint an EU-established intermediary, who is liable for the VAT, unless it is established in, and ships from, a country with a VAT mutual assistance agreement with the EU. If a marketplace facilitates the sale, it is the deemed supplier and collects the VAT. The IOSS number (IM plus 10 digits) is a VAT number, not an EORI; give it to the carrier. Above EUR 150, VAT is paid at import.

Council Regulation (EU) 2026/382 removed the EUR 150 duty relief. From 1 July 2026 to 1 July 2028, distance sales in consignments up to EUR 150 pay a customs duty of EUR 3 per item under any VAT method. An item is goods sharing a tariff classification: five T-shirts are one item, a T-shirt and a watch are two. The declarant pays, and from 1 November 2026 these declarations must carry product identifiers. Separately, on 21 September 2026 the Commission adopted a delegated act setting a handling fee of EUR 2 per item on distance sales of any value, due to start by 1 November 2026; confirm the start date.

Preferential duty: statements on origin, REX and EUR.1

A reduced or zero rate under an EU trade agreement or the EU's GSP works only if the goods meet that agreement's rules of origin and the importer has proof in the exact form the agreement sets; without valid proof, expect the standard rate. A non-preferential certificate of origin from a chamber of commerce only states where the goods were made and gives no duty reduction; it is needed only when the importing country, the contract or a letter of credit asks for one. The main EU forms of preferential proof are below (see Triplicate's note on certificates of origin):

• Statement on origin: written by the exporter on the invoice or another commercial document, in the exact wording the agreement sets, as under EU-Japan and EU-UK (EU-Canada calls it an origin declaration). Without REX registration or approved exporter status, it is limited to consignments of up to EUR 6,000; under the EU-UK agreement a UK exporter uses its EORI as the exporter reference.
• Origin declaration by an approved exporter, as under EU-Korea.
• EUR.1 movement certificate, endorsed by customs under many agreements; in the UK it is issued by chambers or the Institute of Chartered Shipbrokers. EUR.1s can be issued retrospectively after an error or omission.
• EU GSP: exporters in beneficiary countries register in REX and make out statements on origin; REX is not needed if the originating goods in the consignment are worth EUR 6,000 or less. Since 1 January 2021 their authorities may no longer issue Form A for the EU.

Product rules: cosmetics, product safety and wood packaging

Cosmetics fall under Regulation (EC) No 1223/2009. Only products with a Responsible Person (RP) established in the EU may be placed on the market, so a company outside the EU cannot be the RP: for imports it is the importer, unless the importer appoints another EU-established person by written mandate. The RP holds the Product Information File with a safety report, kept 10 years after the last batch is placed on the market, and notifies each product before sale in the CPNP portal; one free notification covers the EU. Labels show the RP's name and address, the country of origin, ingredients by their common glossary names, durability or period after opening, precautions, batch and function, in the language each Member State sets. Products placed on the market from 31 July 2026 need the expanded fragrance allergen labelling (see Triplicate's note on exporting cosmetics to the EU).

Since 13 December 2024 the General Product Safety Regulation (GPSR) requires an economic operator established in the EU for each product, named with postal and electronic address on the product, packaging, parcel or an accompanying document, plus the manufacturer's details and a type or batch number. Online listings must show the manufacturer, the EU responsible person, product identification, a picture and warnings. Toys, electrical equipment, machinery, PPE and other covered products also need CE marking, with a declaration of conformity and technical file kept 10 years. Goods subject to prohibitions or restrictions cannot use the simplified low-value (H7) declaration, and Germany requires LUCID registration before filled packaging, shipping boxes included, is first placed on its market.

Solid wood packaging from outside the EU, such as pallets, crates and dunnage, must be debarked, treated and marked to ISPM 15 (Regulation (EU) 2016/2031). Packaging made wholly of plywood, OSB or other processed wood, or of plastic or metal, needs no ISPM 15 treatment, but solid-wood skids or blocks on it do. Until 31 December 2026, wood packaging carrying goods such as slate, stone, ceramic tiles and aluminium sheet from Belarus, China and India is checked in at least 15% of consignments (see Triplicate's note on ISPM 15 wood packaging).

Documents, advance data, the new customs code and the UK

EU law sets no invoice format. The commercial invoice is a supporting document that must be in the declarant's possession and available to customs when the declaration is lodged, and handed over when EU law requires it or customs asks (Union Customs Code, Article 163). The broker takes the price, currency, delivery terms, origin and charges from it, so give the core fields with EORI numbers where the parties have them, and make the packing list from the same data; Triplicate's free generator makes both (see Triplicate's note on commercial invoice requirements).

Before arrival the carrier, or sometimes a forwarder or postal operator, files an entry summary declaration in Import Control System 2 (ICS2) for all transport modes, with some data due before loading for air cargo. Give it the EU consignee's EORI or, if it has none, its full address, and precise descriptions: ICS2 keeps a list of stop words that must not stand alone as a description, and vague data leads to information requests, do-not-load messages or penalties. The new Union Customs Code, Regulation (EU) 2026/2108, entered into force on 20 September 2026 and applies in stages from 2027 to 2034. It makes non-EU platforms and sellers responsible for customs formalities and duty, and its Customs Data Hub opens to e-commerce in 2028, when normal duty rates are due to replace the EUR 3, so watch for changes.

Great Britain has had its own rules since Brexit: a GB EORI, a UK-established agent acting indirectly for a non-UK importer, 20% import VAT on goods such as cosmetics and, for cosmetics, a UK Responsible Person and SCPN notification. Northern Ireland uses XI EORI numbers and follows EU cosmetics rules, with an RP in Northern Ireland or the EU and a CPNP notification (see Triplicate's note on exporting cosmetics to the UK).