EORI, Economic Operators and Customs Representation
EU customs law uses precise roles. Commercial labels such as importer of record, broker, courier or platform do not always match the legal role in the customs declaration.
Source check date: 2026-06-11.
Legal Basis
Regulation (EU) No 952/2013, CELEX 32013R0952, is the core source. Official link: UCC.
Relevant articles:
- Article 5: definitions.
- Article 9: EORI registration.
- Article 15: obligation to provide accurate information.
- Article 18: customs representation.
- Article 170: declarant.
- Articles 77, 79 and 84: debtor and liability.
Official operational sources:
EORI
An Economic Operators Registration and Identification number is required for customs operations in the EU customs territory, including import, export and transit. Non-EU operators may need an EORI when they perform EU customs activities.
EORI validation is an operational check. It does not prove that an operator has the right authorisation, licence, representation mandate, or VAT status.
Importer, Declarant and Holder of the Procedure
The importer is often a commercial or national tax concept. The customs declaration should identify the legally relevant person: declarant, represented person, representative, holder of the procedure, consignee, carrier, or debtor.
The declarant lodges a customs declaration in their own name or in the name of another person. The holder of a procedure is responsible for compliance with the procedure and its discharge.
Direct and Indirect Representation
Under UCC Article 18, customs representation can be direct or indirect.
Direct representation means the representative acts in the name and on behalf of another person. Indirect representation means the representative acts in their own name but on behalf of another person.
Indirect representation can create joint liability for customs debt. The allocation should be documented in contracts, powers of attorney, declaration fields, and broker instructions.
Carrier, Postal Operator, Express Courier and Platform Roles
Carriers, postal operators, express couriers and platforms may have different responsibilities in ENS filing, ICS2 data, low-value import declarations, IOSS or special-arrangement flows, presentation of goods, and VAT deemed-supplier rules.
Key Compliance Points
- Validate EORI before filing.
- Confirm whether the representative is direct or indirect.
- Keep written representation authority.
- Do not confuse VAT importer, customs declarant and commercial buyer.
- Confirm who bears customs debt, import VAT, excise, penalty and post-clearance recovery risk.
- For non-EU sellers, check establishment, EORI, indirect representation, IOSS intermediary, fiscal representative, and national VAT rules.
Member State Examples
- France: registered customs representative
- Germany: customs representation
- Germany: EORI number
Dynamic or Member State-Specific Notes
Representation registration, customs broker practice, national portal access, and VAT representative requirements vary by Member State.