Who is an exporter?

The exporter is responsible for submitting the export declaration to Customs.

The exporter must be established in customs territory of the Union. A business that has its registered office or administrative head office outside the EU will be regarded as established in the customs territory of the Union if it has permanent staff and a fixed office in the EU for its business operations. Being registered for VAT or obtaining an EORI number do not alone constitute sufficient criteria for the trader to be regarded as established in the customs territory of the Union.

Furthermore, the exporter must have the power to decide on the export of the goods or be party to a contract that determines that the goods are to be taken out of the EU. For example, a transport operator can be party to such a contract. In such cases, it is possible to provide the transport operator as the exporter, and the name of the seller established outside the EU must then be provided using the new additional statement code FIXFY. The code is to be provided in the export declaration under Data on the item to be cleared. The number of the invoice that was obtained from the seller and that contains the details on which the export declaration is based is provided as the additional document.

An agreement party established in the EU is regarded as the exporter, even when the right of ownership of the goods has been transferred to a buyer established outside the EU in accordance with a term of sale or other agreement.

Re-exporters may still be established outside the EU. Likewise, private individuals carrying goods contained in their personal baggage need not be established in the EU.

Exporters can use representatives

Exporters can use representatives in lodging customs declarations when they so wish. The exporter and the representative choose the type of representation to be used in the export declaration. Either direct representation or indirect representation can be used.

Direct representation

A direct representative lodges customs declarations in the name and on behalf of an exporter.

  • Code 2 is to be entered in the customs declaration as the type of representation.

The exporter or the representative can request the correction of the declaration after the goods are released for the export procedure. If the declaration gives cause to any sanctions, for example a penalty fee, Customs imposes the sanction directly on the exporter.

Indirect representation

Indirect representatives lodge customs declarations in their own name and on behalf of the exporter.

  • Code 3 is to be entered in the customs declaration as the type of representation.

A representative can use indirect representation only when Customs has been notified about it in the details on registered customer status. A representative entitled to indirect representation can also act as a direct representative.

Indirect representation cannot be used in export declarations for discharging inward processing or starting outward processing, or in exports involving subsidies or intervention goods.

Only the representative who lodged the declaration can request for it to be corrected after the release of goods for the export procedure. If the declaration gives cause to any sanctions, for example a penalty fee, Customs imposes the sanction primarily on the representative who lodged the declaration.

Points to consider

The export declaration must be lodged in the Member State where the goods are packaged or loaded for export. However, in certain circumstances the goods may be placed under the export procedure in the country of exit. A Special Mentions/Additional Information code on an export declaration lodged on behalf of an exporter established in another EU country is used to justify reasons for why the export declaration is lodged in Finland.

Special Mentions/Additional Information codes for export declarations by exporters in other EU Member States

  • FIXFD For goods not exceeding EUR 3 000 in value per consignment, the goods can be placed under the export procedure in the country of exit. The goods may be placed under the export procedure at the place of exit, provided that they are not subject to prohibitions or restrictions. Please note: If you are using this additional code, the export country cannot be Finland; instead, you must enter the country of departure as the country of export in the export declaration. Enter 72 as the code for the nature of the transaction. In ship supply declarations, you should enter 11 as the code for the nature of the transaction.
  • FIXFE The goods have been purchased in Finland and are placed under the export procedure in Finland on behalf of an exporter established in another Member State.
  • FIXFF Goods in a consignment stock in Finland.

Exports subject to restrictions

Export movements from another EU country cannot be placed under the export procedure in Finland, if an authorisation is required for export of the goods and the authorisation has been granted in the country of export. In these cases, the export declaration must be lodged with the customs authority of the country of export, unless it is exceptionally allowed in the authorisation to lodge declarations also in certain other countries.

The use of an EORI number is compulsory in export declarations. Businesses registered as export customers of Finnish Customs automatically hold an EORI number. In Finland, a business ID in the format FI1234567-8 is used as the EORI number. Declarants who lodge export declarations sporadically need not apply for an EORI number in advance with Customs.

If the exporter and/or agent is established in an EU country other than Finland, the declaration must always contain that country’s EORI number. It must be given in the ‘exporter’/‘agent’ field.

According to EU legislation, each Member State provides their own businesses with EORI numbers. Finnish Customs can, however, still grant occasional declarants established in other EU countries case-specific EORI numbers if they file fewer than five declarations a year (sporadic declarants). If a declarant lodges more than five declarations per year, the declarations are classified as regular, in which case a separate EORI registration is required.

If goods are physically moved from another EU country to Finland prior to the goods being declared for the export procedure, the exporter must apply for a Finnish VAT number in advance. The Finnish VAT number may not be entered in the field for ‘exporter’; instead, it must be declared using the additional statement code FIXFH.