Customs · UK + 27 EU member states
Importer of Record (IOR) services for the UK & EU

flexfrontier acts as your UK and EU Importer of Record — assuming customs liability, filing declarations and clearing your goods into the United Kingdom and all 27 EU member states, without you needing a local entity.

What is an Importer of Record?

An Importer of Record (IOR) is the legal entity named on a customs declaration as responsible for goods entering a country. The IOR must be established in the territory of import, and is accountable for the accuracy of the declaration, the payment of customs duty and import VAT, regulatory compliance of the goods, and record keeping for the statutory retention period. In both the UK and the EU, customs authorities will not release a commercial shipment without a valid, locally established Importer of Record — and carriers will not accept DDP freight without one being named.

If your business has no UK or EU entity, you cannot act as the importer yourself. flexfrontier closes that gap: we are named as Importer of Record on your declarations, we assume the customs liability, and we make sure your goods are classified, valued and declared correctly — so you keep control of your supply chain, your pricing and your customers without incorporating a foreign subsidiary.

DDP

The delivery term your buyers demand — and the customs role it hands back to you: someone locally established must be the importer

Art. 18 UCC

EU and UK customs law both require the importer/declarant to be established in the territory — a foreign entity cannot simply fill the box

UK + 27

One agreement covers the United Kingdom and every EU member state — one partner accountable at every border

UK Importer of Record services

UK imports are governed by the Taxation (Cross-border Trade) Act 2018 and administered by HMRC. Every import declaration is filed electronically through the Customs Declaration Service (CDS), and the importer must hold a GB EORI number and, for most commercial flows, a UK establishment. Since Brexit, an EU entity or EU EORI can no longer be used to import into the United Kingdom — a separate UK Importer of Record is required.

As your UK IOR, flexfrontier files your CDS declarations under our GB EORI, classifies your goods against the UK Global Tariff (UKGT), and applies Postponed VAT Accounting (PVA) so 20% import VAT is declared on a VAT return instead of being paid at the border — keeping it cash-flow neutral rather than a sunk cost. For regulated goods we also coordinate the UK-specific layer: UKCA marking evidence, IPAFFS pre-notification for food and products of animal origin under the Border Target Operating Model (BTOM), and MHRA or FSA registrations where they apply.

EU Importer of Record services

EU imports fall under the Union Customs Code (Regulation 952/2013), and a non-EU business cannot normally act as declarant itself. What happens next depends on what you already hold. If your company has its own EU EORI number and VAT registration, you can appoint an indirect customs representative under Article 18 UCC — an EU-established party who declares in their own name on your behalf and shares liability for the customs debt. But a large share of overseas businesses have neither an EU EORI nor a VAT number — and that is exactly when a full Importer of Record service is required: flexfrontier imports under its own established credentials, so your goods clear compliantly without you having to register anything first.

We support both routes under a single agreement covering all 27 member states: the full IOR service using our own EU registrations when you have none, or indirect representation when you hold your own EORI and VAT numbers. Either way, we manage ICS2 entry summary requirements ahead of arrival, file your import declarations at the main European gateways — Rotterdam, Hamburg, Antwerp, Le Havre and beyond — and structure import VAT so it is deferred or recoverable rather than lost. Once cleared, your goods are in free circulation and can move anywhere in the single market.

IOR vs Indirect Representation: "Importer of Record" describes the commercial outcome; "Indirect Customs Representation" is the legal mechanism (Art. 18 UCC) that makes it possible in the EU. They are two sides of the same arrangement.

When do you need an Importer of Record?

  • Selling DDP (Delivered Duty Paid). Your contracts or marketplace terms require you — not your customer — to handle import clearance, duty and VAT.
  • Amazon FBA and 3PL warehouses. Amazon will not act as Importer of Record for FBA inbound shipments, and most fulfilment centres take the same position — a third-party IOR is the standard solution for non-EU/UK sellers.
  • Your customer refuses the role. Many B2B buyers will not act as importer for goods they have not yet accepted — samples, replacements, consigned stock.
  • Equipment, demo units and spares. Moving tooling, IT hardware, event or test equipment into Europe without a local company to receive it.
  • Regulated products. Electronics, cosmetics, food, medical devices and toys need pre-import registrations — an IOR coordinates admissibility so goods are never stopped at the border.
Your Situation IOR Needed? Why
Selling DDP to UK or EU customers without a local entity ✓ Yes Your buyer expects delivered-duty-paid, and customs law says the importer must be locally established — the gap we fill.
Sending stock to Amazon FBA or a 3PL warehouse ✓ Yes Fulfilment centres will not act as importer for inbound freight — a valid IOR is a condition of the stock arriving at all.
Shipping IT hardware into data centres ✓ Yes Colocation providers refuse the importer role for equipment they host but do not own — we take it, DDP to the rack.
Demo units, loan sets and trade-show equipment ✓ Yes Hospitals, distributors and venues will not import goods they do not own — we clear them in and preserve the re-export position.
Regulated goods — food, devices, cosmetics, electronics ✓ Yes Admissibility is checked before shipment: registrations, labelling and conformity verified so goods clear rather than sit.
You hold your own UK/EU entity, EORI and VAT numbers ✗ Different route You can import yourself — or appoint us as indirect customs representative.
Excise goods — alcohol and tobacco ✗ Out of scope Excise movements sit outside our service.

Importer of Record for IT hardware, servers and data centres

The AI buildout has turned IT imports into one of the fastest-growing IOR use cases. GPU servers, networking equipment, storage arrays and spare parts are shipped constantly into UK and EU data centres — Frankfurt, Amsterdam, Dublin, London, Paris — and the party at the door is almost never willing to be the importer: colocation providers and data centre operators routinely refuse to act as Importer of Record for equipment they host but do not own.

We act as IOR for IT and data centre freight: DDP delivery to the rack, tariff classification for servers, GPUs and components, screening against encryption and dual-use control lists before shipment, and import VAT structured so it is recoverable rather than a project cost. High declared values are exactly what our pricing model is built for — and the same service covers warranty swaps, RMA returns and staged infrastructure rollouts across multiple EU sites.

Where the Importer of Record appears on the paperwork

The importer isn't a formality — it is the legal party on the import declaration filed through CDS in the UK or the national systems across the EU, liable for the customs debt, the accuracy of classification and valuation, and the admissibility of the goods. When we act as your IOR, our name and EORI sit in the importer box, and every clearance produces what your finance team needs:

  • Duty and import VAT settled — paid at the border and passed through at cost, itemised line by line on our invoice.
  • VAT kept recoverable — Postponed VAT Accounting in the UK and deferment mechanisms in the EU, structured before the first shipment.
  • Free circulation — once cleared, your goods move anywhere in the customs territory with no further customs controls.
IMPORT DECLARATION · CDS / national EU systems
Importer of Record flexfrontier Ltd 128 City Road, London EC1V 2NX · EORI on record
Consignor Your Company Inc., Austin TX, US
Goods Consumer electronics · 8517.62 · 640 units
Duty & VAT Settled at border · itemised at cost
Destination DDP — fulfilment centre, Kassel DE
✓ Cleared — Goods in free circulation

IOR vs consignee vs customs broker: who does what?

These roles are often confused, and the difference determines who customs authorities hold liable:

Role What they do Liable for the customs debt?
Importer of Record (IOR) Named on the declaration; responsible for its accuracy, duties, import VAT, compliance and records. Yes — fully.
Indirect representative (EU) EU-established party declaring in its own name on behalf of a non-EU trader (Art. 18 UCC). Yes — jointly and severally with the trader.
Customs broker (direct rep) Prepares and files the declaration as an agent, in the importer's name. No — liability stays with the importer.
Consignee The party physically receiving the goods (often a warehouse or your customer). No — unless also named as importer.

flexfrontier acts in the first two capacities — the ones that carry the liability and that non-established businesses cannot fulfil themselves.

How our IOR service works

  • 1 · Scope. A short call to understand your products, flows, Incoterms and destination countries. We confirm exactly which registrations and checks apply.
  • 2 · Onboard. You return our document pack — company details, product data, invoice format. Most clients are onboarded within 24 hours.
  • 3 · Clear. We are named as importer on your shipments. Declarations, duty and VAT settlement, and admissibility checks are handled per shipment.
  • 4 · Support. Monthly reporting, duty optimisation reviews, and audit-ready records for the statutory retention period.
Step 01
Appoint & vet

Mandate signed and products compliance-checked — classification, admissibility and documentation reviewed before anything ships. Onboarding from 24 hours.

STEP 02
We import

The declaration is filed with flexfrontier in the importer box under our EORI — duty and import VAT settled at the border on your behalf.

Step 03
Cleared & delivered

Goods enter free circulation and move DDP to the final door — customer site, fulfilment centre or data-centre rack.

Step 04
Costs itemised, VAT recovered

Every charge passed through at cost on an itemised invoice, with the VAT structure set up so import VAT is deferred or recovered — not lost.

What you'll need to provide

  • Company registration documents and a signed representation mandate.
  • Product information: descriptions, materials, intended use, and any test reports or certificates we should hold.
  • Commercial documentation per shipment: invoice, packing list and transport details.
  • For regulated goods: labelling artwork and conformity documentation, which we review before the first shipment.

IOR pricing

IOR services are priced as a minimum fee per shipment or a percentage of the declared value — whichever is greater — with duty and import VAT passed through at cost and itemised on every invoice. There are no setup fees for standard onboarding. Tell us your volumes and lanes and we will send a same-day quotation.

Why businesses choose flexfrontier as their IOR

  • One agreement, 28 countries. UK plus all 27 EU member states under a single contract and a single point of contact.
  • Liability genuinely assumed. We are named on the declaration and carry the customs debt — not an agent-only arrangement that leaves risk with you.
  • 12+ years of customs and compliance expertise. Deep, practical knowledge of UK and EU market entry — the classification calls, valuation questions and country-specific quirks that keep shipments moving.
  • Onboarding from 24 hours. Built for urgent first shipments as well as ongoing programmes.
Country coverage
Importer of Record by country

Every EU member state applies the Union Customs Code, but VAT treatment, declaration systems and port practice differ country by country. flexfrontier acts as Importer of Record across the UK and all 27 EU member states — pick a market to see how we clear into it.

UK Importer of Record
HMRC · CDS · GB EORI · Import VAT 20%

Post-Brexit, the United Kingdom requires its own importer — EU entities and EU EORIs no longer qualify. We file through the Customs Declaration Service under our GB EORI, classify against the UK Global Tariff and apply Postponed VAT Accounting so import VAT never hits your cash flow.

We also handle the UK-specific compliance layer: UKCA marking, BTOM/IPAFFS pre-notification for food and animal-origin products, and FSA or MHRA registrations where required.

Importer of Record in Germany
Zoll · ATLAS · Import VAT (EUSt) 19% · Hamburg / Bremerhave

Germany is the EU's largest economy and one of its strictest customs environments. German forwarders are famously reluctant to offer indirect representation to non-EU companies because of the joint liability it carries — which is why so many DDP shipments into Germany stall at clearance.

flexfrontier takes that role on. We act as your German Importer of Record with declarations filed through the ATLAS system, covering flows into Hamburg, Bremerhaven, Frankfurt and German Amazon FBA and 3PL warehouses.

Importer of Record in France
DGDDI · TVA 20% mandatory reverse charge · Le Havre / Marseille / CDG

France requires a French VAT number before customs clearance, and since 2022 import VAT is mandatorily reverse-charged onto the French VAT return — favourable for cash flow, but only if the registrations are in place first.

We act as your French Importer of Record, coordinate the French VAT registration the regime requires, and clear goods through Le Havre, Marseille-Fos and Paris CDG for onward distribution across the EU.

Importer of Record in the Netherlands
Douane · Article 23 VAT deferment · Rotterdam / Schiphol

The Netherlands is Europe's most popular import gateway for a reason: the Article 23 licence lets import VAT be deferred to the VAT return instead of being paid at the border, and Rotterdam is the EU's largest port.

As your Dutch Importer of Record we combine indirect representation with Article 23 import VAT deferment — the most cash-flow-efficient entry route into the EU for many non-established businesses.

Importer of Record in Italy
Agenzia Dogane · IVA 22% · Genoa / La Spezia / Milan

Italy combines a major manufacturing customer base with document-heavy customs practice, and Italian authorities expect precise conformity of invoices, classification and origin evidence.

We act as your Italian Importer of Record for flows through Genoa, La Spezia and Milan Malpensa — including fashion, furniture, machinery and e-commerce stock destined for Italian marketplaces and fulfilment networks.

Importer of Record in Spain
AEAT · IVA 21% deferrable · Valencia / Barcelona / Algeciras

Spain hosts three of the Mediterranean's largest container ports and a fast-growing e-commerce market. Importers filing monthly VAT returns can defer import IVA rather than paying at the border.

flexfrontier acts as your Spanish Importer of Record through Valencia, Barcelona, Algeciras and Madrid, structuring VAT so it is deferred or recovered rather than becoming a landed cost.

Importer of Record in Belgium
FOD Financiën · ET 14000 deferment · Antwerp-Bruges

Antwerp-Bruges is Europe's second-largest port and a natural entry point for chemicals, consumer goods and project cargo. Belgium's ET 14000 licence shifts import VAT to the periodic VAT return — no cash at the border.

We act as your Belgian Importer of Record, combining indirect representation with ET 14000 deferment and onward movement across the Benelux and the wider single market.

Importer of Record in Ireland
Revenue · Postponed accounting · VAT 23% · Dublin

Ireland is the EU's only English-speaking common-law market and a favourite first EU step for US and UK businesses. Postponed accounting lets import VAT be handled on the VAT return rather than paid on arrival.

As your Irish Importer of Record we clear goods through Dublin Port and Dublin Airport — including UK-landbridge flows — with the registrations needed to keep import VAT cash-flow neutral.

Importer of Record in Poland
KAS · VAT 23% · Gdańsk / Gdynia

Poland has become Central Europe's logistics engine — a fast-growing e-commerce fulfilment base with major Baltic container ports at Gdańsk and Gdynia and dense road links into Germany and the wider EU.

We act as your Polish Importer of Record for sea freight into the Baltic ports and for stock destined for Polish fulfilment centres serving the whole single market.

FAQ
Importer of Record — FAQs
  • What does an Importer of Record (IOR) do?

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    The Importer of Record is the legal entity named on the customs declaration for goods entering a country. It is responsible for the accuracy of the declaration, tariff classification and valuation, payment of customs duty and import VAT, regulatory compliance of the goods, and keeping customs records for the statutory retention period.

  • Who can act as Importer of Record in the UK?

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    For most commercial imports, only a business established in the UK holding a GB EORI number can act as Importer of Record. Non-UK companies without a British entity appoint a UK-established IOR provider like flexfrontier to fulfil the role on their behalf.

  • Who can act as Importer of Record in the EU?

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    The importer must be established in the EU customs territory. A non-EU business with its own EU EORI and VAT registration can appoint an indirect customs representative under Article 18 UCC; a business with neither — the more common case — uses a full IOR service, where flexfrontier imports under its own established credentials across all 27 member states.

  • What is the difference between the Importer of Record and the consignee?

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    No. Acting as Importer of Record does not transfer ownership — we take on the customs and fiscal responsibilities of importation, while title to the goods remains with you or passes to your customer under your normal commercial terms.

  • Does the Importer of Record own the goods?

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    The consignee is the party physically receiving the goods — often a warehouse, fulfilment centre or your customer. The Importer of Record is the party legally responsible for the customs declaration, duties and compliance. They can be the same entity, but for non-established sellers they usually are not.

  • Can I import into the UK or EU without a local company?

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    Yes. That is exactly what an IOR service is for: flexfrontier acts as the locally established importer so you can ship into the UK and EU without incorporating a subsidiary, hiring staff or opening local offices.

  • Can I import into the UK or EU without a local company?

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    Yes. That is exactly what an IOR service is for: flexfrontier acts as the locally established importer so you can ship into the UK and EU without incorporating a subsidiary, hiring staff or opening local offices.

  • Can one IOR cover all EU countries?

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    Yes. Once goods are cleared into free circulation in any member state they can move throughout the single market, and flexfrontier's agreement covers imports into all 27 EU countries — Germany, France, the Netherlands, Italy, Spain, Belgium, Ireland and the rest — plus the UK under a separate GB arrangement.

  • Can you act as IOR for Amazon FBA shipments?

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    Yes. Amazon will not act as Importer of Record for inbound FBA freight, so non-EU and non-UK sellers need a third-party IOR. We clear FBA and 3PL inbound stock into the UK, Germany, France, Italy, Spain and the rest of the EU, with the VAT and EPR registrations marketplaces ask for.

  • How is import VAT handled — do I lose it as a cost?

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    Usually not. In the UK we use Postponed VAT Accounting; in the EU we use deferment mechanisms such as the Netherlands' Article 23 licence, Belgium's ET 14000, France's mandatory reverse charge and Ireland's postponed accounting. Structured correctly, import VAT is declared and recovered on a VAT return rather than paid and lost at the border.

  • What documents does an Importer of Record need?

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    A signed representation mandate, your company registration documents, product information (descriptions, materials, intended use), and per-shipment commercial documents — invoice, packing list and transport details. For regulated goods we also review labelling and conformity documentation before the first shipment.

  • How much does an IOR service cost?

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    Pricing is a minimum fee per shipment or a percentage of the declared value — whichever is greater — with duty and import VAT passed through at cost and itemised. There are no setup fees for standard onboarding, and quotations are issued the same day.

  • How quickly can an Importer of Record be set up?

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    Most clients are onboarded within 24 hours of returning our document pack. Registrations that depend on authorities — VAT numbers, certain product registrations — take longer, but we sequence the work so nothing blocks your first shipment unnecessarily.

  • Which products can't you import?

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    We do not act as IOR for excise goods (alcohol, tobacco), weapons and dual-use items requiring licences we do not hold, or products we assess as non-compliant and unrectifiable. For most consumer and industrial goods — including regulated categories like electronics, cosmetics and food — we can act once the right registrations are in place, and we arrange those too.

  • What does DDP mean and why does it require an Importer of Record?

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    Delivered Duty Paid is the Incoterm under which the seller bears every import cost and formality to the buyer's door. It is what UK and EU buyers increasingly demand — but customs law requires the importer to be locally established, so a foreign seller cannot perform its own DDP promise. An IOR closes that gap: we are the established importer, and your customer receives goods with nothing to do at the border.

  • What does 'free circulation' mean?

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    It is the customs status goods gain once import formalities are completed and duty and VAT are settled: they are treated like domestically produced goods and can move anywhere in that customs territory — all 27 EU member states from a single EU clearance — with no further customs controls.

  • What is the difference between an IOR and a customs broker?

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    A broker files declarations in your name as a direct representative — the legal responsibility stays with you, which is exactly why brokers require you to be an established importer first. The IOR is the importer: we are named on the declaration, we carry the customs debt and compliance responsibility, and no local entity of yours is needed. Brokers process paperwork; an IOR takes the legal position.

  • Do you check product compliance before importing?

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    Yes — it is a condition of the service, because the importer is liable for admissibility. Before goods ship we verify classification, labelling and marking requirements, and the registrations the product category needs (GPSR Responsible Person, CE economic operator, FBO and so on — services we provide in-house). Goods that would be stopped at the border are fixed before they fly, not after.

  • Can you handle urgent or already-stuck shipments?

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    Yes. Onboarding runs from 24 hours, and consignments already held at a port or airport for want of a valid importer are a routine starting point — we assess what blocked the entry, take on the importer role, and work with the carrier and customs to release the goods.

  • Do you also handle the export side when stock needs to leave?

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    Yes — our Exporter of Record service is the mirror of the IOR: FBA removals, returns, relocations and end-of-project equipment shipped back out with the declaration filed under our name and proof of export retained. Paired together, moving inventory between the UK, EU and the rest of the world becomes one managed flow.