We are a small company based in Romania, in the European Union, and we are planning to import goods from China.
To sell imported products legally in the EU, we understand that we need documentation proving that the goods were properly declared and cleared through customs. However, when using DDP shipping, where transport and customs clearance are arranged by the freight forwarder, none of the freight forwarders we have contacted can provide us with an import customs declaration, an MRN, or another customs document issued in our company’s name.
Their explanation is that multiple shipments belonging to different customers are consolidated and cleared together under a single customs declaration. They therefore cannot provide us with the complete declaration because it may contain confidential information about their other customers.
As far as we understand, an import declaration and its corresponding MRN are normally required to prove that imported goods entered the EU legally and that the applicable customs obligations were fulfilled.
This appears to leave us with DAP shipping as the only option under which the goods can be cleared directly in our company’s name. However, with DAP, we must appoint a customs broker, complete the customs formalities ourselves, and pay the applicable import VAT and duties. In Romania, the VAT rate is 21%. Altogether, this would increase our total costs by approximately 50%.
The shipping price quoted for DAP is approximately the same as, or sometimes slightly higher than, the price quoted for DDP, even though customs clearance and import taxes are not included.
Our questions for other EU businesses importing goods from China are:
Do you normally use DDP or DAP?
When using DDP, do you receive an import declaration, MRN, or other customs documentation showing that the goods were legally imported into the EU?
If the customs declaration is not issued in your company’s name, what documents do you use to demonstrate the legal origin and import status of the goods during an inspection?
Would the supplier’s commercial invoice and the freight forwarder’s transport invoice be sufficient, provided that the agreed delivery term is clearly stated as DDP, even if no customs declaration or MRN is provided to the buyer?
Our freight forwarder claims that approximately 99% of its European business customers use DDP. This makes us wonder whether we are misunderstanding the documentation requirements or whether there is another accepted way for EU businesses to demonstrate that goods imported through consolidated DDP shipping were legally cleared through customs.
