Skip to content

Providing the trader details

In the standard import declaration, you must provide the details of at least three traders: the declarant, importer and exporter. Further, you can also enter the details of other traders, such as the representative, seller and buyer.

The instructions on this page tell you how the trader details are provided in a standard import declaration, when the requested customs procedure is “40 – Release for free circulation.” You can use the same instructions for other import declarations as well, if no separate instructions are provided for the customs procedure or the declaration you are using.

Who is responsible for declaring the goods?

The declarant, i.e. the trader entered in the customs declaration, is responsible for the following:

  • the details entered in the customs declaration and their correctness (UCC Art. 170)
  • supporting documents for the customs declaration
    • The documents must be in the declarant’s possession and the declarant must submit them to Customs upon request (UCC Art. 163).
  • providing proof of origin
    • If a preferential origin of the goods has been indicated in the customs declaration, the customs authorities may require the declarant to prove the origin of the goods (UCC Art. 61).
  • Possible customs duty or tax consequence resulting from a post-clearance control by Customs
  • ending a customs procedure (UCC Art. 150)
  • presenting the goods
    • The declarant must be able to present or arrange for the physical presentation of the goods to Customs.
  • customs debt (UCC Art. 77)
    • Please note that in the case of indirect representation, the importer on whose behalf the declarant i.e. the representative lodged the customs declaration is primarily responsible for the customs debt.

The declarant in the customs declaration must also make sure to archive the customs clearance documents, when the customs declaration was submitted electronically. Read more about the archiving of import clearance documents

The importer is often the same actor as the declarant (except in the case of indirect representation), in which case the declarant’s responsibilities are in practice the importer’s responsibilities.

The company is regarded as established in the customs territory of the EU if any of the following is located in the customs territory of the EU (UCC Art. 5):

  • registered office
  • central headquarters
  • permanent business establishment

The company’s permanent business establishment means a fixed place of business, where both the necessary human and technical resources are permanently present for carrying out transactions. Furthermore, Customs must be able to carry out customs related operations via this establishment. A business establishment in an EU country cannot be considered permanent, if the company only has occasional activity there or has personnel working occasionally (e.g. a project manager).

Multinational company

A multinational company or group of companies can have several other offices in addition to the parent company. If you are using the office of a multinational company or a group of companies as declarant in the customs declaration, find out if the company or office is established in the customs territory of the EU:

  • If the multinational company or group of companies are their own legal entities, each legal entity can be registered as their own places of business in the EU country in question. The legal entity can act or be a party in the customs transactions, for example make a customs declaration. The legal entity has registered itself in Finland in the business register, for example as a limited company.
  • If the offices of a multinational company or a group of companies are not their own legal entities, rather the parent company only is regarded as a legal entity, the EORI number will only be granted to the parent company. In that case, all these other offices use the parent company’s EORI number. Please note that if the parent company is established outside the EU, but is active in several EU countries, the parent company is regarded as established in the customs territory of the EU. However, check if the parent company and the offices need to be registered in the Member State.

In which country should you register for EORI?

The company must apply for the EORI number and registration in the EU country where it is established.

If the company is not established in the customs territory of the EU, it must apply for the EORI number from the customs authority of the EU country, where the company lodges its first declaration or applies for a decision. In the future, the company must use the EORI number it obtained from the first EU country, even when it conducts business in other EU countries. (Union Customs Code Article 9)

Read more about the EORI number and how to apply.

If a company is not established in the EU territory, but it has a Finnish EORI number

The EORI number applied for from Finland, by a company not established in the EU territory, can be identified by its format. EORI numbers granted in Finland begin with Finland’s country code, followed by the country code of the country where the company is established. For example, if a Norwegian company not established in the EU territory applies for an EORI number from Finland, the EORI number granted begins with FINO followed by a number sequence. The official definition of the EORI number is that it begins with the two-letter country code and has at most 15 characters, which can be letter and numbers. However, the number may be shorter and there is no uniform EU policy on the format of the EORI number.

Please note the following before you submit a declaration with a foreign EORI number:

  • Even though the company is not established in the EU territory, it can receive a Finnish VAT number, which is provided as additional fiscal information with the code FR1. However, the company must always provide the EORI number in the customs declaration.
  • The headquarters of a group of companies can e.g. be located outside the EU territory, but the company can still be established in Finland and receive a Finnish EORI number, if the company has an office in Finland. In that case, the EORI number consists only of the Finnish country code followed by the business ID. If the office is established in Finland, the EORI number has the format FI + Business ID (e.g. FI1234567-8).
  • Even if the company has a Finnish business ID but no office in Finland, instead, the office is established in another EU country; in that case, the EORI number is applied for from the other EU country where the company has an office.
  • If the company already has been granted an EORI number and you receive a new VAT number from another country, remember to link it to the granted EORI number. If you are only now applying for an EORI number, remember to enter in the application all the VAT numbers that you use in EU countries. When you have linked to your EORI number all the VAT numbers that you use in the EU territory, you can use the EORI number in customs declarations throughout the EU territory.

Read the detailed instructions for providing the EORI number on the webpage: How do I submit a customs declaration.

Read more about applying for an EORI number.

Declarant

The declarant is the submitter of the customs declaration. In the import declaration, the declarant is usually the same as the importer (e.g. the buyer of the goods):

  • The declarant is the importer, if the importer submits the customs declaration and does not use a representative.
  • The declarant is the importer, if a direct representative or direct representative under the guarantor’s responsibility is used.
  • The declarant is a representative if an indirect representative is used.

The declarant has many responsibilities. The declarant must e.g. have all the details and documents required for submitting a customs declaration. Further, the goods must be in the declarant’s possession, i.e. the declarant must be able to arrange the presentation of the goods to Customs. Read more on the responsibilities in the previous section “Who is responsible for declaring the goods?”

Please note that if a direct representative or direct representative under the guarantor’s responsibility submits the declaration, the representative must have a power of attorney. Otherwise, the representative will be seen as acting in his own name and taking on the responsibilities of the importer.

If lodging a customs declaration results in special obligations for the declarant (e.g. in special procedures for the authorisation holder), the company must be the declarant, i.e. the customs declaration can be issued by the company itself or a direct representative. However, if you still wish to use an indirect representative, find out when applying for the authorisation whether or not you can use an indirect representative to submit the declaration.

The declarant must always have an EORI number. The declarant must as a rule be established in the customs territory of the EU. Read more about providing the EORI number in the customs declaration.

The declarant must also have an authorisation, if using the procedure requires an authorisation or if the company wants to use a simplified declaration. However, please note that you can lodge a simplified declaration occasionally without an authorisation (additional declaration type B).

In addition to the trader details, the customs declaration must always contain the transaction value; customs duties will usually be levied based on this value. The customs value is usually the transaction value of the goods, i.e. the price actually paid for the goods.

To determine the customs value of the goods, the declarant (usually the importer) must enter the invoice in the customs declaration and present it to Customs when necessary. For an invoice to be used, the following conditions must be met:

  • The goods of the invoice were sold for export to the customs territory of the EU.
  • Except in the case of an occasional import, the importer must have legal capacity in the customs territory of the EU.

Trader details in chain transactions

The sale of goods may involve chaining, i.e. the goods may have been sold several times before they were imported to the EU. If the goods were sold more than once, the customs value is determined based on the last sale that took place before the goods were imported to the customs territory of the EU. Even in a chain transaction, you must be able to present an invoice based on which the customs value is determined.

The declarant lodging the customs declaration (usually the same as the importer) must be able to fulfil the importer’s responsibilities that is, to present the goods and the invoice, among other things. Therefore, when you enter the trader details in the customs declaration based on a chain transaction, please note the following:

  • temporal allocation, i.e. whether the sales in the chain transaction took place before or after the arrival of the goods in the EU territory
  • the physical location of the goods, i.e. were the goods, for example, sent directly to the consignee
  • what was agreed in the trade agreement between the companies about submitting customs declarations
  • which transaction value can be used, i.e., which invoice is available to the declarant

Example: A company (A) outside the EU first sells the products to a company (B) located in the EU. After this, the company (B) sells them onward to another company (C) in the EU. The declaration in question is based on a chain transaction where, depending on the situation, the declarant (importer) can be either company B or company C:

a) In the trade agreement, the agreed upon importer of the goods is company B. The goods first arrive in the possession of company B, after which they are delivered to company C. In this case, the importer can be company B.

b) In the trade agreement, the agreed upon importer of the goods is company C. The goods are delivered directly to company C. Furthermore, the trade between the companies B and C took place before the goods were imported to the EU. In this case, the importer can be company C.

Read more about providing value information in a customs declaration and on the customs value.

Importer

You can only enter the details of one importer in the customs declaration. Where a consignment contains goods from several importers, separate customs declarations must be submitted for each consignment.

The importer is usually the buyer of the goods. Usually, the importer in the customs declaration is the same as the declarant in the customs declaration. An exception to this is indirect representation, where the represented company is the importer and the indirect representative is the declarant. Please note that if you are submitting a customs declaration for low value goods, the importer must always be the consignee of the goods.

When the importer is also the declarant, the importer has the responsibilities of the declarant, i.e. the importer is responsible, e.g. for the details in the customs declaration, for the documents and for presenting the goods. In indirect representation, the representative has the responsibilities of the declarant; however, the importer is primarily responsible for the customs debt (UCC Art. 5(15)).

The party liable to pay VAT on import is usually the declarant. However, in indirect representation the party liable to pay VAT is not the representative, but the importer. In practice, the party responsible for the VAT on import is always the importer, i.e. the party in whose name the declaration is submitted.

If the importer is established outside the EU

The importer can be established outside the EU, but in that case, the company must find out if the importer needs to register in Finland. The importer must find out, which authorities they must register with. The need for registration can be affected e.g. by the customs procedure and the goods to be imported.

For example, the import of certain products requires a registration with the Finnish Food Authority. Read more on the Finnish Food Authority’s website.

Concerning VAT, enquire about the registration requirement from the Tax Administration. If the importer is established outside the EU and the company is not registered for VAT in Finland, Customs will levy the VAT on import with a customs invoice. In this case, read about the refund of VAT to foreign entrepreneurs established outside the EU on the Tax Administration’s webpage:

If the importer is established in another EU country

The importer can be established in another EU country and declare himself as an importer. The importer must find out, whether registration with some authority in Finland is required for importing goods directly to Finland.

For example concerning VAT, the registration requirement must be enquired from the Tax Administration. VAT on import is levied in different ways, depending on whether or not the importer is registered for VAT in Finland:

  • If the importer is not registered for VAT in Finland, Customs levies the VAT on import with a customs invoice.
  • If the importer is registered for VAT in Finland, the importer declares the VAT on import to the Tax Administration.
    • If the importer has an EORI number granted in another EU country and the importer is registered for VAT in Finland, enter the EORI number in the importer’s details of the customs declaration. In turn, enter the Finnish VAT number with the additional fiscal reference role code “FR1 – Importer”.
    • Enter on your own initiative the details of the goods import in the VAT declaration to the Tax Administration. Read more about how to declare the VAT on import (vero.fi).

Please note that if the company wishes to use, for example, its subsidiary that is registered in the VAT register in Finland as an importer of goods acquired for its business, the VAT on the importation cannot be deducted with the importer's VAT declaration to the Tax Administration. For more information on the right to deduct VAT on import, contact the Finnish tax Administration. Check the contact information and services of the Tax Administration (vero.fi).

 

Exporter

You can only provide the details of one exporter in the customs declaration. Where a consignment contains goods from several exporters, separate customs declarations must be submitted for each consignment.

The exporter is the last seller, who has sold the goods prior to their importation into the custom territory of the EU.

Example: A company in the United States buys the goods from China, but sells the bought goods directly from China to Finland. The last seller of the goods before they are imported into the EU territory is the US Company, which is also the exporter of the goods. However, the country of origin and dispatch is China.

Please note that if you are submitting a customs declaration for low value goods, the exporter is an individual or a company that has ordered the transport and has sent the goods specified in the transport document.

The seller is also a separate actor in the customs declaration. The details of the seller are only entered if the seller of the goods is not the exporter entered in the customs declaration.

Representative

There are three types of representation: direct representative, direct representative under the guarantor’s responsibility and indirect representative.

A direct representative or direct representative under the guarantor’s responsibility are not declarants, even though they submit the customs declaration on the importer’s behalf. In that case, the represented company is both the importer and declarant, which means that the company also has the responsibilities of the declarant. Please note that the representative must have a power of attorney from the company on which behalf it submits customs declarations. If the representative acts without a power of attorney, the declarant’s responsibility is transferred to the representative.

In indirect representation, the representative is also the declarant. This means that the indirect representative is responsible, e.g. for submitting the declaration, the correctness of the information and documents, as well as for presenting the goods to Customs. However, the represented company, i.e. the importer (e.g. the buyer of the goods), is primarily responsible for the customs debt. The importer is also responsible for the VAT on import. It pays to have some kind of a written agreement between the importer and the representative, also when it comes to indirect representation.

Read more on the different forms of representation and the guarantee.

If you act as an indirect representative, please note that you have more responsibilities than a direct representative has. An indirect representative has all the responsibilities of a declarant. If a representative is also the importer in the customs declaration, he is also responsible for the VAT.

If the indirect representative represents an exporter established outside the EU

If the exporter, i.e. the seller, is not established in the EU territory, he cannot be the declarant in the customs declaration. In that case, the exporter must use an indirect representative. The exporter of the goods can assign the representative to submit the customs declaration, e.g. when using the delivery term DDP (DDP (Delivered Duty Paid).

Please note the following concerning the responsibilities of the indirect representative:

  • If the representative only has a power of attorney from the exporter, i.e. the seller of the goods, the representative must always be an indirect representative. The representative is the declarant in the customs declaration. The seller of the goods is the importer and the exporter in the customs declaration. The buyer of the goods or the consignee is entered under “buyer” in the customs declaration.
  • If the representative wants to use the buyer of the goods as importer (e.g. a Finnish buyer of the goods), the representative must have a power of attorney from the importer. In the customs declaration, the declarant is the indirect representative and the importer is the buyer of the goods. The exporter is an exporter established outside the EU.
  • If the representative does not have a power of attorney from the importer, rather he acts in his own name and the goods as well as the required information and documents are in his possession, then the representative carries all the responsibility. In that case, the representative enters himself as the declarant and importer in the customs declaration. However, the buyer of the goods or the consignee must be entered under “buyer” in the customs declaration.
    • Please note that if the goods are customs cleared for free circulation in the name and on behalf of the indirect representative, there is no right to deduct or be refunded VAT paid for the importation of the goods. For more information on the right to deduct or be refunded the VAT on import, contact the Finnish tax Administration. Check the contact information and services of the Tax Administration (vero.fi).

If the representative does not want to take on the importer’s responsibility, the representative must acquire a power of attorney regarding this from the importer (e.g. a Finnish buyer of the goods), who is established in the EU territory. With the power of attorney, the importer must take on the declarant’s responsibilities, in which case it is not a question of an indirect but of a direct representation. In that case, the representative can be entered as the declarant as well as importer in the importer’s customs declaration.

When the indirect representative has submitted a customs declaration for CBAM goods, the CBAM report can be submitted either by the indirect representative or by the importer.

If a form of representation other than indirect representation has been used in the customs declaration (e.g. direct representation under the guarantor’s responsibility), the importer must submit the CBAM report.

However, please note that an importer established outside the EU must always use an indirect representative to submit the CBAM report. This representative must be the same as the one in the import declaration.

Read more about the Carbon Border Adjustment Mechanism (CBAM) .

 

Buyer

The buyer is only entered in the customs declaration in certain situations.

When the exporter of the goods, i.e. the seller, established outside the EU territory is entered as importer and exporter in the customs declaration, the declarant in the customs declaration must be an indirect representative. This situation would be possible, for example, when the representative has received a power of attorney only from the exporter, i.e. the seller of the goods, and the term of delivery DDP (Delivered Duty Paid) is used in the commercial contract. The consignee or buyer of the goods must always be entered as actor under “buyer” in the customs declaration.

You can only enter the buyer in a standard import declaration for free circulation. Please note that if submitting the declaration results in special obligations for the declarant (e.g. in special procedures for the authorisation holder), you cannot enter yourself as only the buyer.

If the customs value is determined in accordance with a secondary valuation method, i.e. according to Article 74 of the UCC, the buyer’s information must be entered, if known.

Seller

If the seller of the goods is someone other than the exporter entered in the customs declaration, the seller’s details must be entered in the customs declaration.

If the customs value is determined in accordance with a secondary valuation method, i.e. according to Article 74 of the UCC, the seller’s information must be entered, if known.

With the additional fiscal reference role code, you can provide more information on the trader. The additional information can be e.g. the VAT number granted by Finland or some other EU country.

You can use the following codes:

  • FR1 – Importer
    • Use the code when the trader is a company registered for VAT with the Finnish Tax Administration and it has an EORI number granted by some other EU country. Enter under “Parties” the EORI number granted by the other EU country, for example in the declarant’s or the importer’s details. In turn, enter the VAT number granted by the Finnish Tax Administration with the additional fiscal reference role code “FR1”.
  • FR2 – Customer
    • Use the code when the requested procedure is ”42 – Release for free circulation and home use of goods exempt from VAT to another Member State” or ”63 – Re-importation with simultaneous release for free circulation and home use of goods which are the subject of a VAT-exempt supply to another Member State and, when applicable, an excise duty suspension.” If you import is subject to VAT in addition to this, read more Declaring excise products in import declarations Examples of the use of the code “FR2”:
      • The importer of the goods is a trader registered in the Tax Administration’s VAT register, who has sold the imported goods as direct intra-Community trade from one company to another in the EU territory. The company, which has bought the goods as intra-Community trade and which receives them in the Member State of destination, must be registered in the VAT register of the Member State of destination.
        • Always enter the VAT number, which the Member State of destination has granted the buyer, with the additional fiscal reference role code “FR2 –Customer.”
        • If the company has a Finnish EORI number, enter the Finnish EORI number in the importer details of the customs declaration. Based on this, the company is identified as having a Finnish VAT number granted by the Tax Administration.
        • However, if the importer has an EORI number granted in another EU country that should be provided as the company’s identifier in the customs declaration, enter with the code “FR1 – Importer” the Finnish VAT number granted by the Tax Administration.
      • The importer of the goods is a trader registered in the Tax Administration’s VAT register, who delivers the goods for use by the company in another EU country, where the transport ends. The company is also registered for VAT in this other EU country.
        • Always enter the VAT number, which was granted by the other EU country where the transport ends, with the additional fiscal reference role code “FR2 –Customer.”
        • If the company has a Finnish EORI number, enter the Finnish EORI number in the importer details of the customs declaration. Based on this, the company is identified as having a Finnish VAT number granted by the Tax Administration.
        • However, if the importer has an EORI number granted in another EU country that should be provided as the company’s identifier in the customs declaration, enter with the code “FR1 – Importer” the Finnish VAT number granted by the Tax Administration.
      • Read more on how to declare when the transport of the imported goods ends in another Member State.
    • FR5 – Vendor (the VAT special scheme for import, IOSS)
      • When an IOSS consignment is in question and you have an IOSS number, enter the vendors IOSS number with the code FR5.

The fiscal additional reference code FR3 cannot be used, since there is no tax representative in Finland. Neither can the fiscal reference code “FR4 – Holder of the deferred payment authorisation” or “FR7 – Taxable person or of the person liable for payment of VAT” be used in the import declaration.

Union Customs Code (Regulation (EU) No 952/2013 of the European Parliament and of the Council), Articles 5, 9, 61, 74, 77, 250, 163 and 170