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, the UK and Switzerland 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 is not the freight forwarder and not the customs broker, it is never the consignee on the transport documents, and it never owns the goods. It is the party that is legally the declarant, accountable to customs for the entry, and in the EU, UK and Switzerland that party must be locally established.
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 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 non-EU 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 rather than landing on you.
Your three options as a non-established importer
Appoint an indirect representative
A representative declares on your behalf — a role most brokers and carriers decline, because they take on joint-and-several liability for the customs debt. See indirect customs representation.
Create an EU, UK or Swiss company
Effective but slow and expensive, and brings corporate and tax obligations you may not need.
Appoint a third-party importer of record
Such as Occendra: we are already established locally, carry the customs responsibility, and protect your VAT position.
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. Because Occendra is established in the EU, you do not need a separate indirect representative or a local company. 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 and confirm the classification, value and origin. We 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 ourselves in Switzerland and the UK. Elsewhere we partner with an established representative and run the compliance. Where these routes are not available, we set up the business’s own local registration instead.
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 Occendra Ltd comes in. We also 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. In most cases the business must also appoint a Swiss-domiciled fiscal representative. Import VAT can be deferred through the transfer procedure to protect cash flow.
Importer of record FAQs
An Authorised Economic Operator you can rely on
Occendra holds AEO (Authorised Economic Operator) status, the customs authorities’ trusted-trader standard. It means our compliance, controls and record-keeping have been audited and approved. That can translate into smoother clearances and lower-risk treatment for the shipments we handle as your importer or exporter of record.
Reviewed by Occendra's indirect-tax team
Mikael · Managing Director · LL.M., specialisation in tax
We believe ambition, not barriers, should decide how far a business can go. So we put close to twenty years of customs and VAT expertise to work for you. It was built in Big Four firms and in-house tax teams. We are the established party that takes on the barriers others will not. We do not only advise. We file the declarations and carry the responsibility ourselves.
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 up at the border.