The EFC field notes
Market access and IOR
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September 2026
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
August 2026
- 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.
- 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.
- 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.
- 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.
- 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.
- 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
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
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