Since the Union Customs Code’s implementation in 2016, the definition of ‘exporter’ has been the source of interpretation uncertainties.
The rules stipulate that acting as exporter on a customs declaration requires establishment in the Union’s customs territory. This implies that a non-EU established company cannot act as exporter. Most Member States adopted transitional rules to enable non-EU established companies to act as exporter. Across all Member States however, these transitional rules are at an end, meaning that under no circumstances can a non-EU established company be an exporter for customs purposes.
Source Deloitte
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