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Customs, trade and export controls · Knowledge centre · 01 of 6

Customs registration and importer of record

Before goods can cross a border, someone must be registered with customs in that country and must take legal responsibility for the import declaration. Each market uses its own identifier: the EORI number in the EU and UK, the Importer-Exporter Code in India, FASAH registration in Saudi Arabia and an emirate-level customs code in the UAE. Deciding early which entity will be importer of record, and whether it is resident or not, shapes duty cash flow, VAT recovery and who carries liability for errors.

Source-checked research100% of statements checked against a source59 checked against an official source7 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed

Before goods can cross a border, someone must be registered with customs in that country and must take legal responsibility for the import declaration. Each market uses its own identifier: the EORI number in the EU and UK, the Importer-Exporter Code in India, FASAH registration in Saudi Arabia and an emirate-level customs code in the UAE. Deciding early which entity will be importer of record, and whether it is resident or not, shapes duty cash flow, VAT recovery and who carries liability for errors.

Every market needs a registered trader

In the EU, any economic operator established in the customs territory needs an EORI number from the customs authority of the member state where it is established; a non-EU operator lodging declarations registers in the member state of its first customs operation. Great Britain uses its own EORI numbers beginning GB, with XI numbers for movements to and from Northern Ireland.

India requires an Importer-Exporter Code granted by the Directorate General of Foreign Trade for any import or export, and since GST the code is the same as the business PAN. Saudi Arabia registers importers and exporters on ZATCA's FASAH platform using their commercial registration, and Dubai Customs issues a business code against a trade licence. Singapore Customs registers traders, who may authorise declaring agents.1234567

The importer of record carries the legal risk

The importer of record is the party that makes the declaration in its own name and answers for classification, value and origin. In the United States, entry must be made by a party qualifying as importer of record, using reasonable care; the owner or purchaser, or a licensed customs broker they designate, may file. Goods are not released unless a single-entry or continuous customs bond is on file.

A foreign seller that agrees to deliver duty paid becomes responsible for import formalities in the buyer's country and usually needs its own registration there. A seller that sells on terms where the buyer imports avoids this but loses control of the clearance and of the evidence used to claim preferences.89

Timing and documents at the border

Some markets set firm pre-arrival steps. In Saudi Arabia the customs declaration must be completed on FASAH at least 48 hours before the shipment arrives, supported by a commercial invoice, a bill of lading and a certificate of origin. Missing these steps is a common cause of demurrage and storage charges.1011

Who registers with customs, by market123456897
MarketRegistrationWho needs itSource
EU (France, Germany)EORI numberOperators established in the EU; non-EU operators in the state of first customs operationEuropean Commission
United KingdomEORI starting GB (XI for Northern Ireland)Businesses moving goods into or out of Great BritainGOV.UK
IndiaImporter-Exporter Code (same number as PAN)Any person importing or exportingDGFT
Saudi ArabiaFASAH registrationCommercial importers and exportersZATCA
United Arab Emirates (Dubai)Dubai Customs business code, AED 100Any business using Dubai Customs servicesDubai Customs
United States (federal)Importer of record plus customs bondOwner, purchaser or designated licensed broker19 USC 1484; 19 CFR 142.4
SingaporeSingapore Customs registrationTraders importing or exportingSingapore Customs

Decisions to make

  • Which entity will be importer of record in each market: the buyer, a local subsidiary or the foreign seller?89The importer of record files in its own name, carries liability for errors and, in the United States, must have a customs bond on file.
  • Does the exporting entity in India hold an Importer-Exporter Code?34No import or export from India may be made without one.
  • In which EU member state will the first customs operation take place?1A non-EU operator obtains its EORI number in that state.
  • Which emirate or port will goods enter the UAE through?6Customs registration is run at emirate level; Dubai issues its own business code.

Documents usually needed

  • Commercial registration or trade licence of the importing entity
  • EORI, IEC, FASAH or emirate customs code confirmation
  • Commercial invoice, packing list and bill of lading or air waybill
  • Certificate or statement of origin where a preference or origin marking applies
  • Customs broker or declarant authorisation, and a customs bond for US entries

Common mistakes

  • Agreeing to deliver duty paid without a registration or agent in the buyer's country
  • Assuming one EU EORI number covers Great Britain or the reverse
  • Leaving Saudi FASAH declarations until the goods arrive
  • Letting a freight forwarder act as importer of record without understanding who is liable for errors
  • Using an Indian entity without an IEC for a cross-border sale

Questions businesses ask

Can a foreign company be the importer of record?

Often yes, but it must register with customs in that market. In the EU a non-EU operator obtains an EORI number in the member state of its first customs operation; in the United States the importer of record must have a customs bond on file before goods are released.19

Is India's Importer-Exporter Code a separate number?

The DGFT still issues it separately, but since GST the IEC is the same as the business's PAN.4

What this guide does not yet confirm

These points need checking with a qualified local professional before you rely on them.

  • Import-side EORI rules for Great Britain were not confirmed on a page opened; the GB claim covers exports and Northern Ireland movements.
  • Customs registration in Abu Dhabi and the other emirates, and the validity of the Dubai business code, were not confirmed.
  • Germany-specific registration practice and US customs bond amounts were not researched.
  • Non-resident importer and fiscal representation rules for import VAT differ by market and were not compared.

Sources and review status

Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.

  1. Any economic operator established in the EU customs territory needs an EORI number, assigned by the customs authority of the member state where it is established. Non-EU operators lodging declarations apply in the country of their first customs operation.

    European Commission (DG TAXUD) — Economic Operators Registration and Identification number (EORI) · Who needs an EORI number · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Reused from market guide claim it-trade-002.

  2. A business needs an EORI number starting with GB to export goods from England, Wales or Scotland, and may need one starting with XI to move goods to or from Northern Ireland. EU-established businesses use an EU EORI number for Northern Ireland movements.

    HM Revenue & Customs — Export goods from the UK: step by step · Get your business ready · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Reused from market guide claim gb-trade-002.

  3. No person may make any import into or export from India except under an Importer-Exporter Code (IEC) granted by the DGFT. Applies to proprietorships, partnerships, LLPs, companies, trusts, HUFs and societies. Exemptions, if any, were not confirmed. Central rule.

    Directorate General of Foreign Trade (DGFT), Ministry of Commerce and Industry — DGFT online services portal (home page) · IEC services · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Reused from market guide claim in-trade-g01.

  4. Since GST was introduced, the IEC number is the same as the business's PAN, although the DGFT still issues the IEC separately. Central rule.

    Directorate General of Foreign Trade (DGFT), Ministry of Commerce and Industry — DGFT online services portal (home page) · IEC services · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Reused from market guide claim in-trade-g02.

  5. Importers and exporters register on ZATCA's FASAH platform to start import and export activity, using their commercial registration number and ID number. Commercial importers and exporters.

    Zakat, Tax and Customs Authority (ZATCA) — Customs Journey · Registration of New Importer or Exporter · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Reused from market guide claim sa-trade-g07.

  6. Any business using Dubai Customs services must register and obtain a Dubai Customs business code based on its trade licence, supplying a trade licence copy and the authorised person's passport and Emirates ID copies; the published fee is AED 100. Dubai Customs. Other emirates run their own customs registration (Abu Dhabi through its TAMM portal). A separate renewal service exists; validity is not stated.

    Dubai Customs — Dubai Customs Services Guide 2025 · Request Business Registration; FAQ · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Reused from market guide claim ae-trade-g03.

  7. Importing goods into Singapore requires the correct permits, classification and documentation, and traders register with Singapore Customs and may authorise declaring agents.

    Singapore Customs — Doing Business · Getting Started; Import Operations · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Landing-page summaries only; detailed permit rules on the subpages could not yet be checked. Reused from market guide claim sg-trade-003.

  8. Entry of imported goods must be made by a party qualifying as importer of record, using reasonable care; the owner or purchaser of the goods, or a person they designate who holds a customs broker licence under 19 USC 1641, may file. Federal, 19 USC 1484(a). The statute does not define reasonable care.

    Legal Information Institute, Cornell Law School — 19 US Code 1484 - Entry of merchandise · Subsections (a)(1) and (a)(2)(B) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Statutory text read on the Cornell Legal Information Institute reproduction of the United States Code; the official text is published at uscode.house.gov. Reused from market guide claim us-trade-g02.

  9. Imported merchandise is not released from CBP custody at entry unless a single-entry or continuous bond on CBP Form 301, executed by an approved corporate surety or secured by cash or US government obligations, is on file. Federal, 19 CFR 142.4(a). The port director may waive surety for merchandise valued at no more than 2,500 US dollars where estimated duties are paid before release and the importer has no record of delinquency; the waiver does not apply to quota merchandise, merchandise that is hard to appraise or classify, or where redelivery may be needed (142.4(c)).

    Office of the Federal Register (eCFR) — 19 CFR 142.4 Bond requirements at the time of entry · Section 142.4(a) and (c) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register. Reused from market guide claim us-trade-g04.

  10. Importers must complete the customs declaration on the FASAH platform at least 48 hours before the shipment arrives at the port of entry. Commercial imports.

    US International Trade Administration — Saudi Arabia Country Commercial Guide: Import Requirements and Documentation · Import Requirements and Documentation · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary (foreign government) source; ZATCA's clearance guidance could not yet be checked. Reused from market guide claim sa-trade-g09.

  11. Importers must present a commercial invoice, a bill of lading and a certificate of origin, and shipping documents from the United States are authenticated by US chambers of commerce. Commercial imports; product registrations with the relevant authority may also be required.

    US International Trade Administration — Saudi Arabia Country Commercial Guide: Import Requirements and Documentation · Import Requirements and Documentation · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary (foreign government) source; authentication practice for other countries of export was not confirmed. Reused from market guide claim sa-trade-g10.

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