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From 1 Nov 2026: a €2 Union handling fee per item type on consumer parcels from outside the EU, at any value. What it means →

Importer of record in the EU: we declare your goods

Customs releases your goods only when an importer established in the EU signs the declaration. Noda declares them in its own name, for you, as indirect customs representative, and acts as your VAT representative in Estonia. We specialise in goods entering the EU through the Baltics and work with any other EU entry point: customs law is the same in every member state. You don't need an EU company.

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A set-up fee and a price per shipment, in your proposal

Short answer

"Importer of record" is trade language. In EU customs law the importer is the declarant: the company that lodges the customs declaration, and it must be established in the EU. Noda takes that role as your indirect customs representative: it declares your goods in its own name, for you, and owes the customs debt together with you.

Delivered by: Noda, Tallinn · Last reviewed: October 2026

Article 170
The company that lodges the declaration must be established in the EU
Article 77(3)
As indirect representative, Noda owes the customs debt together with you
21 Sep 2027
The new Union Customs Code applies; article numbers change

Do you need this?

Yes, if

  • You ship in bulk to stock in the EU or to business buyers.
  • Your EU buyer asks who the importer is.
  • Your shipment waits at customs with no declarant in the EU.

No, if

  • You only send parcels to consumers, and the carrier or platform declares them.
  • Your EU buyer clears the goods itself (delivered at place, DAP).
  • Your own EU company imports in its own name.

Shipments stuck at customs

The most common reason: nobody in the EU can sign the declaration.

Marketplace stock

Amazon treats the seller as the importer of record for stock sent to its EU fulfillment centres, and asks for a VAT number in the country of import. A seller from outside the EU needs an EU customs representative to declare the goods. That is the role we take.

Bulk shipments and B2B orders

Without an EU declarant, the goods wait in temporary storage, and storage fees grow every day. We declare the shipment once we have the invoice, the packing list and the product codes.

Who does what

Ownership of the goods stays with you. The customs work is ours.

You

Your goods

  • Commercial invoice, packing list, values and origin
  • Proof of origin, if you claim a lower duty
  • Customs duty and import VAT, paid from your prepayment or against our invoice, before release, at cost

Noda

The declaration

  • Confirms the product codes with you before the first shipment
  • Lodges the declaration in its own name, for you
  • Registers you for VAT in Estonia and files your returns
  • Arranges your EORI number
  • Answers customs and keeps the import records

Partner

Transport and storage

  • Your forwarder, or one we suggest, brings the goods to Estonia
  • A partner warehouse receives them, if they go into stock

Direct or indirect representation

Union Customs Code, Article 18. For a company from outside the EU, indirect representation is the usual route.

Direct representativeIndirect representative
DeclaresIn your name, on your behalfIn its own name, on your behalf
DeclarantYouThe representative
Customs debtYouThe representative and you, jointly (Article 77(3))
Works forCompanies established in the EUCompanies outside the EU, too
NodaYes, for EU companiesYes: this is how we act as your importer of record

Your VAT representative in Estonia

When your goods enter the EU through Estonia, or stay in stock here, you need an Estonian VAT number.

When it's required

Estonia requires a VAT representative for companies from outside the EU, except Norway and the United Kingdom (Estonian Tax and Customs Board).

What we do

  • Register your company for VAT in Estonia
  • File your Estonian VAT returns every month
  • Register you for OSS and file your quarterly OSS returns for sales to consumers in other EU countries
  • Handle the import VAT: 24% in Estonia, deductible in your VAT return under the normal rules
  • Act as your IOSS intermediary if you ship parcels worth up to €150 to EU consumers, and file your monthly IOSS returns

Liability

A VAT representative is liable with you for the VAT. That is why we check your figures before each return.

Your EU customs number (EORI)

Every importer needs an EORI number. A company from outside the EU registers in the EU country of its first customs operation. When that is Estonia, we file the application. The number is free.

How it works

  1. 1

    Tell us

    What you ship, how often and where it enters the EU.

  2. 2

    Your proposal

    The set-up and the price per shipment, in writing.

  3. 3 · 2–3 weeks

    Set-up

    Customs mandate, EORI number and VAT registration in Estonia.

  4. 4

    First shipment

    The goods arrive in Estonia. Noda declares them.

  5. Every month

    Every month

    A declaration per shipment, your Estonian VAT return, records kept.

What it costs

From €200 to set up and from €50 per shipment, excl. VAT. VAT representative from €99 a month. Your proposal states the exact amounts before you decide. No minimum term: you can leave with 30 days' notice.

The price depends on

  • Shipments a month
  • Product codes per shipment
  • Whether the goods go into stock in Estonia

Paid at cost

  • Customs duty
  • Import VAT
  • Any fees charged by customs

How you pay them: a prepayment before your first shipment, then our invoice for each shipment, paid before release. We don't finance duty.

No fee for customs questions about a shipment we declared.

What we don't do

  • We don't guess product codes. We confirm the tariff code with you before the first declaration.
  • We don't take ownership of your goods or resell them. They stay yours.
  • We don't act as declarant for steel, aluminium, cement or fertilisers under CBAM.
  • We don't handle trade to or from Russia or Belarus. Goods in transit through them only where EU sanctions permit. Sanctions policy

Common questions

What is an importer of record in the EU?

In EU customs law it is the declarant: the company that lodges the import declaration in its own name, or in whose name it is lodged. It must be established in the EU and have an EORI number.

Can a company from outside the EU be the importer of record?

In most cases, no. It works through an EU company: its own, its EU buyer, or an indirect customs representative such as Noda.

Why are my shipments stuck at customs?

Usually because no declarant in the EU is named, or the product codes and values are missing. We can take over a waiting shipment once we have the documents.

Can you clear goods entering through another EU country?

Yes. We specialise in the Baltics, but EU customs law is common to all member states, and we work with any EU entry point. Your proposal confirms the route and who declares where.

Who pays the duty and the import VAT?

The declarant pays customs. As your indirect representative, we pay customs and you pay us the same amount, before release. By law, the customs debt is shared between us.

Can you be my IOSS intermediary?

Yes. If you ship parcels worth up to €150 straight to EU consumers, we register you for IOSS and file your IOSS return every month. Your customer pays the VAT at checkout, and the parcel clears customs without a VAT bill at the door. The price is in your proposal.

Do I need an EORI number?

Yes. Every importer needs one. It is free, and we file the application when your first customs operation is in Estonia.

What changes in 2027 and 2028?

The new Union Customs Code applies from 21 September 2027. For parcels sold from outside the EU to EU consumers, the seller or the platform becomes the importer; one not established in the EU acts through an indirect customs representative with AEO status. The EU Customs Data Hub becomes mandatory for e-commerce from 1 July 2028. We update this page as the European Commission publishes the details. See EU parcel rules 2026.

Sources: Union Customs Code, Regulation (EU) 952/2013, Articles 5, 9, 18, 77 and 170; Regulation (EU) 2026/2108; Estonian Tax and Customs Board, VAT representatives of non-residents; Amazon, EU and UK logistics onboarding guide (2024). Last reviewed: October 2026.

Related: Stock in Estonia · EU parcel rules 2026 · EU Responsible Person

What we need from you to start

  • Commercial invoice and packing list for the first shipment
  • Product codes, if you have them, and the origin of the goods
  • Proof of origin, if you claim a lower duty
  • Signed power of attorney for customs (our template)
  • Your company details, for the EORI and VAT registration

Get a quote

Tell us what you ship, how often and where it enters the EU. You get a proposal for your imports.

We reply within 1 business day, Tallinn time.

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