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.
The EORI number (Economic Operators Registration and Identification number) is the identifier customs authorities use for a business in every customs operation in the EU. The European Commission states that it “is mandatory for the clearance of all types of customs operations in the customs territory of the EU, such as import, export and transit.” A business established outside the EU gets its number in the member state where it first carries out one of those operations. That one number then serves across the whole EU.
It is an identifier and nothing more. It is not a VAT number, it does not register the business for VAT, and it grants no permission to trade.
Who needs an EORI number?
The Commission lists three groups. Every economic operator established in the EU customs territory needs one. So does an operator established outside it that lodges customs declarations, entry or exit summary declarations, or temporary storage declarations, or that acts as a carrier. Persons other than economic operators need one only where national law or another EU act requires it.
The legal basis is Article 9 of the Union Customs Code, Regulation (EU) No 952/2013. An operator established in the EU registers with the customs authorities of the place where it is established. Article 5 of Delegated Regulation (EU) 2015/2446 then sets out when an operator established outside the EU must register. It must do so before it lodges a customs, summary or temporary storage declaration, or acts as a carrier, subject to narrow exceptions.
How do non-EU businesses get one?
The rule is the first customs operation. Article 9(2) of the Union Customs Code says an operator not established in the EU registers “with the customs authorities responsible for the place where they first lodge a declaration or apply for a decision.” The Commission puts it more plainly: it is “the EU country in which they intend to carry out their first customs operation.”
The number itself has a fixed shape. It starts with the two-letter code of the issuing country, followed by an identifier of up to 15 alphanumeric characters.
In Portugal, the Autoridade Tributária e Aduaneira builds the EORI from the tax number: the EORI is PT followed by the NIF. So a Portuguese tax number comes first, and the EORI follows from it. What that first registration involves for a business from outside the EU is set out in who needs a fiscal representative in Portugal. For operators established in Portugal, the number is assigned automatically the first time they interact with the customs systems, directly or through a representative. An operator established outside the EU that first operates in Portugal must request the number there. The request goes through the Portal das Finanças, with an email address to receive the credentials for the EORI form.
After that, the number travels. “At any point in time, a person can be assigned only one valid EORI number,” the Commission states. It has no expiry date. It can be invalidated on request, or when the business stops operating, and the registered data is then kept for 10 years after invalidation.
Suppose the first container of a pump manufacturer based outside the EU lands in Portugal, and its first declaration is lodged there. Portugal issues its EORI. A year later, a second container arrives in Rotterdam. The declaration there uses the same Portuguese number. The Netherlands does not issue a second one.
What is an EORI number not?
It is not a VAT number. The EORI is a customs registration; VAT registration is a separate register with separate rules. Because the Portuguese EORI is PT followed by the NIF, it is easy to read as a tax registration. It is not one. Under article 31.º n.º 1 of the Código do IVA, a business that carries on an activity subject to VAT must file a declaration of start of activity before it begins. Obtaining an EORI does not file that declaration.
It is not a licence. The EORI identifies a business; it does not authorise anything. Customs permissions are separate decisions with their own conditions, such as the authorised consignor and consignee statuses described in T1 transit explained for importers.
It does not settle the VAT side of an import either. Where import VAT falls due, and how it is accounted for, depends on the route the goods take and on the VAT registrations the business holds. An EORI number has no bearing on either.
The EORI number tells customs who is making the declaration. It does not register the business with the tax authority, and it gives the business no right it did not already have.
EORI and the importer of record
“Importer of record” is a trade term. The Union Customs Code speaks of the declarant: under Article 5(15), the person lodging a customs declaration in its own name, or the person in whose name it is lodged. The EORI on the declaration identifies that person.
Article 18 of the Code defines two kinds of customs representation. In direct representation, the representative acts in the name of the other person, so the declaration is lodged in that person’s name. In indirect representation, the representative acts in its own name for another person, and is itself the declarant.
The difference matters for liability. Under Article 77(3), the declarant is the debtor of the customs debt. In indirect representation, the person for whom the declaration is made is also a debtor. So using a broker’s name on the declaration does not move the debt away from the business behind the goods.
The routes for standing as importer without an EU company are set out on importer of record and in importer of record without an EU entity.
Can a broker’s EORI number be used instead?
Only where the broker lodges the declaration in its own name, as indirect representative. The broker is then the declarant, and its EORI identifies it on the declaration. The business behind the goods still owes the customs debt, because Article 77(3) makes the person for whom the declaration is made a debtor too.
In direct representation, the broker acts in the business’s name. The business is then the declarant, and the declaration needs the business’s own EORI.
Common EORI mistakes
Treating it as a VAT registration. The Portuguese format makes this easy to do. The EORI does not start VAT activity, and it does not allow VAT to be charged or deducted.
Registering in several countries. Only one valid EORI number exists per person. A business from outside the EU registers where its first customs operation takes place, and uses that number everywhere else.
Assuming the EORI settles the route. The number identifies the declarant. Which procedure the goods enter, where duty is paid, and how VAT is handled are separate decisions. Where stock is sold on to VAT-registered business buyers in other member states, the import can be set up so that no import VAT is paid in Portugal, but that turns on the VAT position of the importer and its buyers, never on the EORI. The sales side is covered in zero-rated B2B sales from stock in Portugal.
This is general information, not legal or tax advice. The customs authority that registers a business decides each application.
How this runs at EFC
One question is settled with the client before the first shipment reaches EFC’s operation in Portugal: who stands as declarant. That choice decides whose EORI goes on the declaration and who carries the customs debt. Where the first declaration is lodged in Portugal, the EORI is built from the Portuguese tax number, so that number is obtained first. The full order of registrations is set out in who needs a fiscal representative in Portugal, and the function itself on fiscal representation.
Sources
| Label | Value | Source |
|---|---|---|
| EORI purpose and holders | mandatory for all customs operations in the EU; three groups of holders; non-EU operators register in the country of their first customs operation | European Commission, EORI number, opened 2026-07-16 |
| EORI format and validity | two-letter country code plus up to 15 alphanumeric characters; one valid number per person; no expiry; invalidated on request or when business activities cease; data kept 10 years after invalidation | European Commission, EORI number, opened 2026-07-16 |
| Registration rule | established operators register where established; non-established register where they first lodge a declaration or apply for a decision | Regulation (EU) No 952/2013, Article 9, as adopted, on legislation.gov.uk, opened 2026-07-16 |
| Non-established operators | registration before lodging customs, summary or temporary storage declarations, or acting as carrier | Delegated Regulation (EU) 2015/2446, Article 5, as adopted, on legislation.gov.uk, opened 2026-07-16 |
| Portugal | EORI equals PT plus NIF; automatic for established operators; non-EU operators request it via the Portal das Finanças | Autoridade Tributária e Aduaneira, EORI, opened 2026-07-16 |
| Declarant | person lodging a declaration in its own name, or in whose name it is lodged | Regulation (EU) No 952/2013, Article 5, as adopted, on legislation.gov.uk, opened 2026-07-16 |
| Customs representation | direct: in the name of the other person; indirect: in the representative’s own name | Regulation (EU) No 952/2013, Article 18, as adopted, on legislation.gov.uk, opened 2026-07-16 |
| Debtor | declarant is the debtor; in indirect representation the principal is also a debtor | Regulation (EU) No 952/2013, Article 77(3), as adopted, on legislation.gov.uk, opened 2026-07-16 |
| Portugal, start of VAT activity | declaration filed before the activity begins | Código do IVA, artigo 31.º, Portal das Finanças, opened 2026-07-16 |