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EU: Exporters re-defined; implications for non-EU entities

EU: Exporters re-defined; implications non-EU entities

The European Union (EU) changed the definition of exporter in its customs legislation in July 2018. As a result, non-EU established entities are no longer entitled to act as exporter of records in the EU.


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The revised exporter definition is to be fully enforced across the EU Member States with the planned deployment of the Automated Export System (AES). However, until the AES is fully operational, transitional measures may apply on a country-by-country basis.

Some EU Member States have taken a strict interpretation and are no longer accepting non-EU established companies as exporter of record. These include but are not limited to:

  • Belgium
  • Italy
  • Romania
  • Germany (being rolled out through the different customs offices)
  • Netherlands (from 1 December 2019)

Other EU Member States are currently still permitting non-EU established companies to act as exporter of record, with an indirect customs representative.

KPMG observation

Affected entities need to assess, manage, and consider how to mitigate the impact of new exporter definition on their European supply and value chains.

Read an October 2019 report prepared by the KPMG member firm in Switzerland

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