MARKET ACCESS / IMPORTER OF RECORD
Can a non-EU brand sell in the EU, without its own European entity?
Under the EU Union Customs Code, goods imported into the EU must have a declared importer responsible for the import. EFC handles this as the Importer of Record inside its operation, so a non-resident brand can bring goods into the single market legally without forming its own European entity.
THE MECHANISM
The named importer, run inside one operation.
The Importer of Record is the party legally responsible for goods entering the EU customs union: the declarations, the import obligations, and compliance with import formalities.
A non-EU brand without a European entity has no party to name here, and without it the goods stop at the border. EFC carries the Importer of Record function inside the same operation that holds and ships the stock, so the import is part of the running base, not a separate arrangement the brand has to build.
Because the goods enter through the bonded customs warehouse, duty and import VAT defer until each order ships. The Importer of Record function and the bonded intake work together: legal import on the way in, tax deferred until the way out.
THE BOUNDARY
Precise about the function.
What it is
- The Importer of Record function carried inside the operation, so a non-resident brand can import into the EU legally.
What it is not
- Not a customs-broker licence claim about EFC.
- Not MDR, CE, or device certification.
- Not a separate vendor the brand contracts on the side.
- The GPSR Responsible Person credential is a separate, consumer-products-only role.
IN ONE SENTENCE
EFC acts as the Importer of Record inside its operation,
so a non-resident brand can import goods into the EU legally without forming its own European entity.
Under the EU Union Customs Code,
Regulation (EU) No 952/2013.
Questions
Frequently asked questions
Do we need a European entity to import and sell in the EU?
No. With EFC acting as the Importer of Record, a non-resident brand can bring goods into the EU and sell across the single market without forming its own European entity. The Importer of Record function carries the import responsibility, and the bonded warehouse, fiscal representation, and OSS VAT cover the rest of the operation.
Who is the importer of record in the EFC model?
EFC is the Importer of Record, carrying the function inside its operation. That means the import declarations and import obligations sit with the operation that also holds and ships your stock, rather than with a separate vendor you have to appoint and coordinate yourself.
How does the Importer of Record obligation sit alongside fiscal representation and OSS VAT?
The Importer of Record carries the Union Customs Code import responsibility: it is the declared importer for goods entering the EU customs union. Fiscal representation then gives the brand its standing for VAT, and OSS VAT covers the VAT obligations across the 27 member states as orders ship. The import obligation is this leaf’s regime; the other two functions sit alongside it inside the one operation.
Is the Importer of Record the same as a customs broker?
No, and the page makes no customs-broker licence claim about EFC. The Importer of Record is the party legally responsible for the import. Customs clearance and import handling are activities run inside the operation. They are related parts of the same import event, but they are not the same thing.
Does acting as Importer of Record give EFC ownership of our goods or customers?
No. The Importer of Record function is about legal responsibility for the import, not ownership of your product or your customer. You retain the client and the margin is entirely yours; the operation carries the import so your goods can enter the EU legally.
If EFC is the Importer of Record, what does our company still own and run?
You keep the brand, the product, and the customer relationship, and the margin stays entirely yours. The Importer of Record function covers the legal responsibility for the import event, while your own product compliance and any certification your goods require stay with you as the maker. EFC carries the import and the operation around it, not your product approval.
Does this cover selling across all 27 EU member states, or only the country of import?
The import brings the goods into the EU customs union once, and the single market then lets them be sold across all 27 member states. The Importer of Record function handles the import responsibility on the way in, while OSS VAT covers the VAT obligations as orders ship to customers in any member state, so one operation reaches the whole bloc rather than a single country.
Import into the EU, without a European entity.
See how goods enter bonded and clear on the way out.
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