Importer of Record (IOR) for the EU, UK and Switzerland
Bring goods into your buyer’s market without setting up a company there. We become the declared importer of record, fully compliant, with your import VAT kept recoverable.
Two decades in customs & VAT · Big Four background · Established in the EU, UK and Switzerland
What is an importer of record?
An importer of record (IOR) is the entity legally responsible for goods at the moment of import. It is the party named on the customs declaration. It makes sure the goods are compliant, pays the duties and import taxes, and keeps the required records. In the EU and the UK that party must be established locally. That is exactly the problem for an overseas business.
In practice the importer of record owns a chain of obligations: classifying the goods under the right customs code, declaring an accurate customs value and origin, settling customs duty and import VAT, meeting any product and licensing rules, and holding the documentation for audit. Get any of it wrong and the liability lands on the importer of record, which is why the role cannot be treated as a formality.
A point worth clearing up; the importer of record should not be conflated with the freight forwarder, the customs broker, the consignee on the transport documents, or the owner of the goods. Each of those is a separate role, and none of them makes a party the importer of record. The importer of record is the party that is legally the declarant, accountable to customs for the entry.
When you need a third-party importer of record
Delivered Duty Paid means you, the seller, are responsible for clearance, duty and import VAT, so you have become the importer of record, often without planning for it. Incoterms typically decide who imports.
Moving goods into local storage is an import, and someone with a local establishment must be the importer of record before the goods can be stored and sold on.
The principal receives the goods in its own name but, as a non-resident, needs a locally established importer of record to act as declarant and clear them.
A coordinated multi-country deployment needs one partner that can be the importer of record in each destination. Timelines do not slip while you line up a different broker in every market.
Machinery, IT and data-centre hardware, demo stock and returns all need an accountable importer at the border.
Selling DDP? Then you are the importer of record
Delivered Duty Paid, or DDP, looks like a customer-friendly term: you quote a landed price and handle everything to the door. But it also makes you, the seller, the party responsible for clearing the goods, paying duty and import VAT, and meeting local rules. In other words, it makes you the importer of record in a market where you have no entity. That is where shipments stall. We take on the importer-of-record role behind your DDP terms. You keep offering the convenience your customers expect and deliver smoothly, with the clearance handled by us rather than landing on you.
Your three options as a non-established importer
Appoint the customs broker
Most brokers say no. The few who agree to the joint-and-several liability for the customs debt often price it heavily. See indirect customs representation.
Set up a local company
Full control, but high cost and a stack of corporate obligations you may not need.
Appoint a third-party importer of record
We are already established in the market, take on the customs responsibility, and keep your VAT recoverable. No subsidiary, no broker stand-off.
How we act as your importer of record
Before anything is filed, we run a short customs risk assessment, checking the customs classification, the declared customs value and the origin of your goods. We do this for two reasons: to protect our position as the party on the declaration, and to keep you clean as the seller. Onboarding is digital, with an e-signed agreement, so stalled shipments can move again quickly. From there we clear every later shipment and keep you compliant.
Goods already stuck in customs?
Sometimes a shipment is held because there is no compliant importer of record. The cause might be no local entity, no one willing to take the declaration, a classification or value query, or a DDP term nobody planned for. In those cases we can often step in as the established importer and get it released. We run a fast risk assessment, confirm the classification, value and origin, then take on the importer-of-record role and work with your existing freight forwarder or broker to clear the goods. Send us the air waybill or entry details, and we will tell you quickly whether we can act.
Keeping your import VAT recoverable
Here is the trap that catches careless setups. EU law only lets a business deduct import VAT under two conditions. It must have the right to dispose of the goods as owner. And the import cost must feed into its own onward taxable supplies. So if a third party is named as importer of record but does not own the goods, the import VAT can become irrecoverable, a pure cost rather than a wash.
We structure the arrangement so that does not happen. The party entitled to deduct keeps that right. We use any available deferment and reverse-charge mechanisms in each market, so import VAT is not paid at the border and chased later. The result is a clean VAT position, not a nasty surprise on the next return.
In practice, the cleanest way to keep import VAT recoverable is to register the owner of the goods, the principal, for VAT in the country of import. That makes the principal the party entitled to deduct or reclaim it. We arrange that registration and the fiscal representation that some countries require. We act as that representative in some countries, elsewhere we partner with an established representative and run the compliance.
Related: our VAT registration and fiscal representation services for non-EU businesses.
Importer of record in the EU, UK and Switzerland
European Union
The Union Customs Code requires the declarant to be established in the EU; a non-EU importer must act through an EU-established party and be identified by an EORI number. Import VAT treatment, and whether you can defer it or apply a reverse charge, varies by member state, so the choice of entry country matters. As an EU-established importer of record we remove the need for a reluctant broker or a new subsidiary.
United Kingdom
The United Kingdom is a separate customs territory. It has its own tariff, the CDS declaration platform and a GB EORI requirement. An EU EORI is not accepted. The importer of record must be established in the UK, so a non-UK business generally cannot take the role itself. That is where we come in. We set up the UK VAT registration and Postponed VAT Accounting, so import VAT can be declared and reclaimed on the same return, instead of paid at the border.
Switzerland
Switzerland sits outside the EU and EEA. A foreign business that triggers Swiss VAT must register. This happens once worldwide turnover from taxable supplies passes CHF 100,000. The business must also appoint a Swiss-domiciled fiscal representative. Import VAT can be deferred through the transfer procedure to protect cash flow under certain conditions.
Importer of record FAQs
Who can act as importer of record, market by market.
See how indirect representation, importer of record and VAT recovery fit together.
Ready to import without the local-entity headache?
Tell us the goods, the lane and the Incoterm. We will show you the cleanest way in. As your importer of record, we make sure your ambition is not held back by borders.