EORI
Also known as: EORI number, Economic Operators Registration and Identification
An EORI number is the registration number with which customs in the whole EU identifies an economic operator. Anyone who files customs declarations or has them filed needs one.
What does a Dutch EORI number look like?
A Dutch EORI number consists of the country code NL followed by the RSIN or the VAT identification number without the letters. For a private limited company with VAT number NL123456789B01 the EORI number is NL123456789. The number is assigned once and applies in the whole EU. A separate registration per member state is not needed. The number hangs on the legal person, not on an establishment. A company with three warehouses in the Netherlands has one EORI number. Declarations from those three locations run under the same number. A branch in Belgium of the same company uses the Dutch number, unless there is a separate Belgian legal person. The number is visible in the EORI validation of the European Commission. There you check whether it exists, whether it is active, and whether the name matches. A number that sits in your master data but is not active in that validation produces a refused declaration. Check it before the first shipment, not after.
Who needs an EORI number?
Every company that imports or exports goods, files a declaration or has one filed, or applies for a customs authorisation. A foreign party that acts as declarant in the EU also needs one. The importer on the IMA, the exporter on the export declaration, the holder of a T1: all an EORI number. Private individuals as a rule do not need an EORI number; on an incidental shipment the declarant uses a collective number. That does not apply to a sole trader who imports regularly. As soon as you stand in the declaration as an economic operator, the number is mandatory. In representation both the principal and the declarant have a number, depending on the form. In direct representation the principal is the declarant and they must have the number. In indirect representation the representative themselves is the declarant. A power of attorney without the EORI of the right party is a file that stalls.
How do you apply for an EORI number?
In the Netherlands EORI numbers for companies with a Chamber of Commerce registration are created automatically on the basis of the RSIN. You then do not have to apply for anything, only check whether it is active. You check in the EORI validation of the European Commission. A number that is not active leads to a refused declaration, which is the most common cause of a rejected first declaration for a new principal. If the number is not there, or is not active, you apply for it at Customs. That is a separate step besides the Chamber of Commerce registration. A company that was founded yesterday does not automatically have a working EORI number on the first shipment of tomorrow. For the United Kingdom you need a British EORI number that starts with GB. Your EU number no longer works there since Brexit. A DDP shipment to the UK without a GB number does not get through CDS. That is a different registration, at a different customs, with a different application.
What do you check on an EORI number?
Check for every new principal whether the number exists and is active in the EORI validation of the European Commission. A number that does not exist or that has been withdrawn leads to a refused declaration without the error message always making clear why. DMS points to the element, not always to the underlying cause. Also check whether the name and the address in the EORI registration match the data on the declaration. A move that has been reported to the Chamber of Commerce but not to Customs produces a mismatch that only becomes visible at the first declaration. That mismatch is not a typing error, it is a registration that lags. On a merger, a split or a change of legal form a new RSIN arises and with it a new EORI number. Authorisations do not travel automatically, which means a warehouse or article 23 authorisation has to be applied for again. Declarations under the old number are refused from the moment it has been withdrawn.
What is the link with authorisations and powers of attorney?
All customs authorisations are registered on the EORI number. An article 23 authorisation, a warehouse authorisation or an AEO status hangs on that number and not on the company as such. If the number changes, the authorisations hang in the air until they have been linked again. In representation the power of attorney must also match. The declarant acts for the importer and needs a written power of attorney for that, stating whether it is direct or indirect representation. That distinction decides who is liable for the customs debt. Direct: the principal. Indirect: the representative, as joint debtor. In practice a missing or expired power of attorney is one of the most common reasons a file stalls. It is administration that gets little attention until the moment a control asks for it. Keep the power of attorney with the EORI number in the master data, with an end date, and refuse declarations if that date has passed.
What is the difference between EORI and a VAT number?
A VAT number is fiscal and an EORI number is customs-technical. The Dutch EORI number is derived from the VAT number, but without the B part at the end. NL123456789B01 is VAT, NL123456789 is EORI. On a declaration they belong in different fields, and filling in one number where the other belongs is a standard error. A company can have a VAT number without ever having filed a declaration. The EORI number is then created automatically, but is not always active. Conversely a foreign economic operator can have an EORI number without a Dutch VAT registration. DDP without a VAT position is then a cost, not an input tax. For article 23, the authorisation to reverse the VAT on import, you need both: an EORI number to be the declarant, and a VAT registration to carry the reverse charge. One number is not a replacement for the other. Check them separately.
What goes wrong with EORI numbers?
The classic error is a new principal whose number has not been checked. The first declaration is refused, the container stands, and the cause is a number that has never been active. Check the number in the EU validation when you take the customer on, not at the first IMA. The second error is forgetting the GB number on import into the UK, or using the NL number in CDS. The third is letting authorisations run on a number that has lapsed after a merger. The fourth is letting the name on the declaration differ from the name in the EORI registration, which at a document control is a finding. The fifth is a power of attorney on the wrong number: the parent instead of the subsidiary, or the old company instead of the new. The declaration sometimes still goes through, until a control asks for the power of attorney and it turns out not to cover who stands on the declaration. Record EORI, name, power of attorney and authorisation as one set.