EU customs clearance step by step: EORI, declaration, release
Import clearance in the EU comes down to this: an importer with an EORI number (directly or through a customs representative) lodges an electronic customs declaration, customs accepts and possibly checks it, and once duty and VAT are paid or secured the goods are released for free circulation. The legal basis is the Union Customs Code (Regulation (EU) No 952/2013). Most delays come from things that should have been prepared earlier: classification, proof of origin and customs value.
By Hiram Trade Editorial Desk
- Published
6 min read
Step 1: EORI number
An EORI number is mandatory for all customs operations in the EU: import, export and transit. It consists of the two-letter code of the issuing member state and an identifier of up to 15 characters. A company established in the EU applies to the customs authority of its own member state; a non-EU company applies in the member state where it carries out its first customs operation.
In Poland the application is filed electronically on the PUESC platform. You first create an account with extended permissions, register the individual's data, and then submit the company registration form. According to the Polish government portal biznes.gov.pl, the procedure is free of charge and usually takes 1-3 working days. You can check a counterparty's number in the EU EORI validation tool.
Step 2: preparation before shipment
Before the goods leave the supplier, settle:
- Tariff classification. The CN/TARIC code determines the duty rate, VAT, required licences and trade defence measures. The rules are covered in HS and CN codes and tariff classification.
- Origin. A preferential rate requires proof of origin under the relevant agreement or preference scheme. For imports from the Philippines, see EU-Philippines trade and GSP+.
- Customs value. The starting point is the transaction value, the price actually paid or payable. Transport and insurance costs up to the place where the goods enter the EU customs territory are added, so on FOB or FCA purchases you have to add them yourself.
- Restrictions and licences. Some goods need phytosanitary or veterinary certificates, licences or registration in other systems, such as CBAM for steel or aluminium. From 1 January 2026, an importer (or its indirect customs representative) importing more than 50 tonnes a year of CBAM goods must hold authorised CBAM declarant status, and customs release such goods for free circulation only if the importer holds that status (importers of electricity and hydrogen always need it, whatever the quantity).
Step 3: arrival and temporary storage
Before arrival the carrier lodges an entry summary declaration (ENS) with safety and security data. On arrival the goods are presented to customs and go into temporary storage under customs supervision. Non-Union goods in temporary storage must be placed under a customs procedure or re-exported within 90 days. During that time the goods may only undergo handling to preserve them without changing their appearance or technical characteristics; customs may authorise the examination of the goods or the taking of samples.
Every day in port also costs money on the carrier and terminal side; container charges are covered in demurrage and detention charges.
Step 4: who lodges the declaration
Any person able to present the goods and documents can lodge a declaration, as a rule someone established in the EU. In practice most importers use a customs representative (customs broker). The Code provides for two types of representation:
| Type | How the representative acts | Who is the customs debtor |
|---|---|---|
| Direct | in the name of and on behalf of the importer | the importer |
| Indirect | in its own name but on behalf of the importer | the representative and the importer jointly |
Indirect representation costs more, because the representative takes on liability for the customs debt. It is used, for example, when the importer is not established in the EU. Set out the scope of authority, the type of representation and liability for data errors in the contract with the broker.
Declarations are lodged electronically. The Code also offers simplifications for authorised operators, including the simplified declaration, entry in the declarant's records and centralised clearance. A declaration can also be lodged before the goods arrive, which shortens time in port.
Step 5: documents
A typical import set:
- commercial invoice with description, quantity, price, currency and Incoterms rule,
- packing list,
- transport document: bill of lading, air waybill or CMR,
- proof of origin, if you claim a preferential rate,
- certificates and licences required for the goods,
- documents showing transport and insurance costs, if not on the invoice,
- power of attorney for the customs representative.
The invoice description must allow classification; "spare parts" or "samples" is not enough. More in international trade shipping documents.
Step 6: checks, duties and release
After the declaration is accepted, risk analysis decides whether the goods are released without control or face a document check or physical inspection. The amount due is based on the nature, customs value and quantity of the goods at the time the declaration is accepted. At this stage you pay customs duty, import VAT and any excise, or use a guarantee and deferred payment.
In Poland, Article 33a of the VAT Act allows importers who meet specific conditions to account for import VAT in their VAT return instead of paying it at customs. Check the conditions with an adviser or your broker before the first import; other member states have their own rules.
Release for free circulation means a non-Union good acquires Union status and can move freely within the EU. Commercial policy measures such as anti-dumping duties are applied at this point, along with the other formalities for importing goods.
If the goods will be processed and re-exported, or stored before sale, a special procedure may be used instead of release for free circulation; see special customs procedures in the EU.
Step 7: after clearance
Keep the declaration and supporting documents; the Code requires them to be kept for at least three years, and national rules may set longer periods. Check that the data on the declaration (commodity code, value, origin) match the documents, because amendments and post-release controls remain possible long after clearance.
What depends on your counterparty
Fast clearance depends on the quality of the supplier's documents. Hiram checks companies with an EU VAT number in VIES, and Polish companies also against the VAT white list and KRS; all companies are screened against EU, UN, UK and US sanctions lists. Hiram does not verify trade documents or handle customs clearance, so completeness of the invoice, proof of origin and certificates must be agreed in the contract. On the Hiram market, check each supplier's verification level on its profile.
Sources
- European Commission: Economic Operators Registration and Identification number (EORI) (opens in a new tab)
- European Commission: Customs declaration (opens in a new tab)
- European Commission: Importation (opens in a new tab)
- European Commission: CBAM definitive regime (opens in a new tab)
- Regulation (EU) No 952/2013 laying down the Union Customs Code, EUR-Lex (opens in a new tab)
- Polish VAT Act, Article 33a (text on lexlege.pl, in Polish) (opens in a new tab)
- biznes.gov.pl: Uzyskaj numer EORI (in Polish) (opens in a new tab)
- PUESC: EORI number for import and export (in Polish) (opens in a new tab)
This article is for information only and is not legal, tax or customs advice. Rules and rates change: check the current official sources or consult an adviser before you decide.