Share with your friends

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.


Related content

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

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal