The EFC field notes

Real regulation, in the shape it actually reaches a brand.

Notes from the operation on how goods cross the EU border, clear into free circulation or sit under bond, settle their VAT, meet GPSR, and come back for repair. Worked examples, plain mechanics, and the citation where the rule really lives.

Latest

Customs and the border 5 min read Demo equipment that is not for sale Does demonstration equipment count as an import the same way a sale does? Temporary admission, the 24-month limit, and what happens if a demo unit is sold.
Logistics and fulfilment 5 min read Holding spare parts and demo units in Europe A checklist for hardware and medtech teams: what needs to sit in Europe, what can stay home, and how parts and demo kits are imported. Returns and reverse logistics 6 min read Keeping a warranty promise in Europe What can go wrong when a brand promises EU customers repair or replacement: the two-year guarantee, and why the fix can cross the border twice.

All field notes

September 2026

  1. Customs and the border 5 min read Demo equipment that is not for sale Does demonstration equipment count as an import the same way a sale does? Temporary admission, the 24-month limit, and what happens if a demo unit is sold.
  2. Logistics and fulfilment 5 min read Holding spare parts and demo units in Europe A checklist for hardware and medtech teams: what needs to sit in Europe, what can stay home, and how parts and demo kits are imported.
  3. Returns and reverse logistics 6 min read Keeping a warranty promise in Europe What can go wrong when a brand promises EU customers repair or replacement: the two-year guarantee, and why the fix can cross the border twice.
  4. Customs and the border 8 min read After EUR 3: the 2028 customs duty change What the texts say about low-value imports after 1 July 2028: normal duty rates, the Customs Data Hub, the new customs code and the handling fee.
  5. Business development 7 min read How Spanish retail and distribution buy How Spain's grocery, department-store and pharmacy channels buy, what the agency law says, and which trade fairs fall in 2027 and 2028.
  6. Market access and IOR 7 min read Importer or distributor: who holds EU stock? Who is the importer when a European distributor buys from a manufacturer outside the EU, who owes duty and import VAT, and who carries the GPSR duties.
  7. GPSR and product compliance 7 min read Product recalls in the EU: Safety Gate and GPSR What the Safety Gate 2025 figures show, what GPSR Articles 35 to 37 require in a consumer recall, and why batch-level stock data keeps a recall narrow.
  8. Customs and the border 7 min read DAP or DDP for shipments into the EU Under DDP the seller clears the import and pays duty and import VAT. What that requires of a seller from outside the EU, and when DAP fits better.
  9. Customs and the border 7 min read EU trade agreements in Latin America: proving origin Which EU agreements with Chile, Mexico, Colombia, Peru, Ecuador and Central America apply in 2026, and the proof of origin each one accepts.
  10. Business development 10 min read How European retail chains buy Retail chains buy on a calendar, not on request. How range reviews, annual negotiations and buying groups work in Europe, and when to approach.
  11. Market access and IOR 7 min read Selling in Europe without an EU company Can a company from outside the EU sell in Europe without an EU entity? What a party inside the EU makes possible, and what the law still requires.
  12. Business development 10 min read What European distributors ask before signing What a European distributor checks before taking on a brand from outside the EU: stock, lead time, labels, the GPSR operator, barcodes, returns and margin.
  13. Business development 9 min read Private label in Europe: winning retailer deals Store brands hold 38.8 percent of grocery sales in 17 European markets. How own-brand tenders, audits and the PLMA show work for manufacturers.
  14. Business development 9 min read European trade fairs for manufacturers The European trade fairs that matter for food, beauty, medtech, industrial and consumer goods makers, with dates, and how to book buyer meetings.
  15. Country guides 6 min read Selling into Italy from stock in Portugal What a seller shipping from Portuguese stock to Italian customers settles first: packaging labels, CONAI and its contribution, Italian language, RAEE.
  16. Customs and the border 7 min read The Product Identifier customs will ask for From 1 November 2026, imported goods sold at a distance need a Product Identifier for EU customs. What the guidance asks for, and what it does not.
  17. VAT and OSS 6 min read One EU stock pool for B2B and B2C buyers Can the same EU stock serve distributors and consumers? Yes: one physical pool, two VAT treatments, and OSS covers only the consumer side.
  18. Sectors 7 min read Consignment stock and loan sets for EU hospitals How consignment stock and surgical loan sets work for EU hospitals, what the MDR asks on implant cards and UDI, and what the warehouse does in between.
  19. Business development 8 min read Commercial agent, or a managed route? What Directive 86/653/EEC gives a commercial agent when the contract ends, how it differs from a distributor, and the routes manufacturers use instead.
  20. Business development 6 min read How a European distributor search runs How to find a distributor in Europe: map who sells the category, rate each candidate on evidence, name the buyer, and write an approach that gets read.
  21. Country guides 6 min read Selling into Spain from stock in Portugal What a seller shipping from Portuguese stock to Spanish customers settles first: packaging EPR, Spanish labels, RAEE and batteries.
  22. Customs and the border 7 min read Anti-dumping duties and the origin of goods How EU anti-dumping and countervailing duties attach to origin and to named producers, how long they last, what counts as circumvention, and where to check.
  23. Country guides 8 min read Selling into France from stock in Portugal What a seller shipping from Portuguese stock to French customers settles first: EPR and the IDU, Triman and Info-tri, marketplace checks and French language.
  24. Customs and the border 9 min read EUR 3 customs duty: per item, not per parcel The EUR 3 customs duty applies per item, not per parcel. What Regulation (EU) 2026/382 says, which shipments it covers, and what IOSS does not change.
  25. Customs and the border 6 min read CBAM for importers of steel and aluminium CBAM has applied in its definitive form since 1 January 2026. The 50-tonne threshold, authorised declarant status, and the first certificates in 2027.

August 2026

  1. Customs and the border 6 min read EUDR: deforestation rules for importers Which products the EU Deforestation Regulation covers, who files the due diligence statement, and the application dates as amended in December 2025.
  2. Customs and the border 7 min read Importing food into the EU: border controls Which food imports stop at an EU border control post, what the CHED and TRACES do, and how other food is checked under Regulation (EU) 2017/625.
  3. Logistics and fulfilment 8 min read Shipping lithium batteries from an EU warehouse How ADR classes lithium batteries, what packing, marking and training a warehouse needs, and the EU Batteries Regulation dates that apply to sellers.
  4. Country guides 5 min read Canary Islands, Ceuta, Melilla: outside EU VAT The Canaries, Ceuta and Melilla sit outside the EU VAT area. Why a shipment there from Portugal is an export, and what changes only if a buyer is there.
  5. Business development 10 min read One European market first, or all at once? The EU is one market with 27 buying cultures. How to pick a lead market, and what changes by country: language, retail concentration, payment terms.
  6. Business development 8 min read Selling to EU hospitals through public tenders How EU public tenders work for manufacturers from outside the EU: Directive 2014/24/EU, the 2026-2027 thresholds, GPA access, and the medical device rules.
  7. VAT and OSS 9 min read Zero-rated B2B sales from stock in Portugal When a sale from Portuguese stock to a business in another EU country is exempt: the 2020 conditions, what goes wrong, and where OSS applies.
  8. Logistics and fulfilment 6 min read Serving Spain and Portugal from one stock One EU stock can serve Spanish and Portuguese buyers together. The VAT rules for B2B and consumer sales, Spanish labels, parcels and returns.
  9. Country guides 8 min read Selling into Germany from stock in Portugal What a seller shipping from Portuguese stock to German customers settles first: LUCID and the 2026 packaging rules, stiftung ear, batteries and language.
  10. Sectors 7 min read Selling food supplements in the EU Directive 2002/46/EC, national notification in Portugal and Germany, novel food status, labelling and language: what a supplement brand settles first.
  11. VAT and OSS 8 min read Marketplace deemed supplier rules in the EU When a marketplace becomes the deemed supplier for EU VAT under Article 14a, what that covers for sellers from outside the EU, and what it leaves out.
  12. Customs and the border 6 min read The EU-Mercosur agreement: what changes for importers The EU-Mercosur interim trade agreement has applied provisionally since 1 May 2026. What it cuts, how origin is proved, and what stays line by line.
  13. Sectors 8 min read Holding cosmetics stock for the EU market What the EU Cosmetics Regulation asks of those who store and supply cosmetics, and why its Responsible Person is a different role from the GPSR one.
  14. Logistics and fulfilment 7 min read Pan-European FBA or your own EU stock Pan-European FBA spreads stock across Amazon's EU centres and needs a VAT number in each storage country, compared with one stock base and OSS.
  15. VAT and OSS 9 min read Who needs a fiscal representative in Portugal When a business from outside the EU must appoint a VAT fiscal representative in Portugal, what it is liable for, and what it does not cover.
  16. Sectors 8 min read Storing and shipping medical devices in the EU What MDR and IVDR Articles 13 and 14 ask of importers and distributors on storage, transport and checks, and where a third-party warehouse fits.

July 2026

  1. Logistics and fulfilment 7 min read Last-mile delivery across the EU What EU consumer law says about delivery: the 30-day default, when risk passes to the buyer, when the withdrawal clock starts, and what to set with carriers.
  2. VAT and OSS 9 min read Import VAT in the return, not at the border Which EU countries let importers declare import VAT in the VAT return instead of paying it at the border, on what conditions, and why it helps cash flow.
  3. Country guides 7 min read Brazilian brands selling in Europe: what to settle first EU-Brazil trade, the DU-E export filing, cosmetics under CPNP, food via TRACES, supplement notification, and European versus Brazilian Portuguese.
  4. Logistics and fulfilment 7 min read Lot, batch and expiry control in an EU warehouse FEFO or FIFO, batch records and traceability: which EU rules call for lot control for food, cosmetics, consumer products and medical devices, and why.
  5. Customs and the border 8 min read HS codes and Binding Tariff Information How the 8-digit Combined Nomenclature builds on the HS, why the code sets duty and other rules, and how a BTI decision gives three years of certainty.
  6. Customs and the border 11 min read T1 transit explained for importers What T1 external transit is, when a container moves under it from an EU port to Portugal, and how the guarantee, NCTS, time limit and liability work.
  7. Logistics and fulfilment 6 min read Shipping from South America to European ports Which carrier services link South America with European ports, what reefer cargo needs, and why the port of arrival shapes release.
  8. Logistics and fulfilment 7 min read Parcel, pallet or groupage: moving stock from Portugal How to choose between parcel, pallet network, groupage and full truck when stock held in Portugal serves consumers, retailers and distributors in Europe.
  9. Customs and the border 8 min read Customs value: what goes in and what stays out How EU customs value is built from the price paid under UCC Articles 70 to 74: freight to the border, royalties, assists, what is excluded, and the VAT link.
  10. Customs and the border 7 min read What an EORI number is, and what it is not Who needs an EORI number, where a business from outside the EU gets one, and why it is a customs identifier, not a VAT number or a licence.
  11. Bonded warehousing 9 min read Bonded or release on arrival, in numbers Cash-flow numbers for a customs warehouse against release on arrival, for slow high-value goods and fast movers, and what bonded costs in discipline.
  12. Customs and the border 8 min read Finishing and assembly in the EU: origin rules When EU finishing or light assembly changes where goods come from under UCC Article 60, which operations never do, and how a BOI ruling settles it.
  13. Bonded warehousing 4 min read Bonded warehouse: deferral, not exemption Why a customs warehouse defers duty and import VAT to each release rather than cancelling them, and when holding stock under bond in Portugal fits.
  14. Market access and IOR 4 min read Importer of record without an EU entity What an importer of record is, why a company with no EU entity struggles to find one, why customs brokers refuse the role, and who can carry it.
  15. GPSR and product compliance 4 min read GPSR and the Responsible Person, explained Who can act as the EU Responsible Person for consumer products under GPSR, what the role holds under Regulation (EU) 2019/1020, and where it stops.
  16. Returns and reverse logistics 5 min read Customs relief for returns and repairs Why a return sent back for repair is taxed as a new import, how returned goods relief and outward processing prevent it, and when returns stay in the EU.
  17. VAT and OSS 4 min read OSS, IOSS, and what they do not cover What the One Stop Shop covers for sellers from outside the EU, how IOSS differs, and what neither covers: B2B sales and moving your own stock.
  18. Market access and IOR 4 min read Selling to 27 EU markets from one import Why clearing customs on every parcel scales badly, and how one import into EU stock serves orders in all 27 member states.

By question

Straight to the answer
  1. Does demo equipment count as an import the same way as a sale? No. Demo equipment that is not for sale
  2. Do I need to hold spare parts in Europe, or can I keep shipping them one at a time? It depends on the failure pattern. Holding spare parts and demo units in Europe
  3. What is the EU legal guarantee period for consumer goods? A minimum of two years from delivery, under Article 10 of Directive (EU) 2019/771. Keeping a warranty promise in Europe
  4. What happens to low-value imports into the EU after 1 July 2028? The temporary EUR 3 customs duty ends, and the old duty relief for consignments of up to… After EUR 3: the 2028 customs duty change
  5. How concentrated is Spanish grocery retail? Concentrated at the top. How Spanish retail and distribution buy
  6. Should my European distributor be the importer of record? Neither route is correct in the abstract. Importer or distributor: who holds EU stock?
  7. How many Safety Gate alerts were there in 2025? The Commission's Safety Gate report for 2025 recorded 4,671 alerts… Product recalls in the EU: Safety Gate and GPSR
  8. Should I sell DAP or DDP to customers in the EU? Under DAP, the seller delivers to the agreed place and the buyer clears and pays for the… DAP or DDP for shipments into the EU

Every question, by topic