Includes import documentation and other requirements for both the U.S. exporter and foreign importer.
The TARIC, database described in the Import Tariffs article, is available to help determine if a license is required for a particular product. Moreover, the EC maintains an export helpdesk with information on import restrictions of various products: https://trade.ec.europa.eu/tradehelp
The Single Administrative Document
The official model for written declarations to customs is the Single Administrative Document (SAD). The SAD describes goods and their movement around the world and is essential for trade outside the EU, or of non-EU goods. Goods brought into the EU customs territory are, from the time of their entry, subject to customs supervision until customs formalities are completed. Goods are covered by a Summary Declaration, which is filed once the items have been presented to customs officials. The customs authorities may, however, allow a period for filing the Declaration which cannot be extended beyond the first working day following the day on which the goods are presented to customs.
More information on the SAD can be found at:
Economic Operator Registration and Identification (EORI)
‘Economic Operators Registration and Identification number’ (EORI number) is an identification number, unique in the customs territory of the Union, assigned by a customs authority to an economic operator or to another person in order to register him for customs purposes.
Since July 1st, 2009, all companies established outside of the EU are required to have an EORI number if they wish to lodge a customs declaration on the customs territory of the EU or an Entry/Exit Summary declaration. All U.S. companies should use this number in relation with EU customs. Along with the application for an EORI number, the following documents must also be submitted:
1. the registration document issued by the competent authority of the third country in photocopy;
2. the VAT registration certificate(s) issued by the Competent Authority in the Member States of the European Union, where applicable.
3. documents showing the address of the registered office or the current fiscal domicile, where applicable, if it does not correspond to the one entered in the documents mentioned above issued by the responsible authorities within the Trade registry or by the Chambers of Commerce from the European Union or from the third country, in original form or a legalized copy, no later than 6 months before the date of submission of the application;
4. a photocopy of the valid passport or other travel document in the case of natural persons.
In specific cases, economic operators and other persons which are not established in the customs territory of the Union shall register with the customs authorities responsible for the place where they first lodge a declaration or apply for a decision.
Once a company has received an EORI number, it can use it in relation with the EU customs authorities to any of the 28 EU member states. There is no single format for the EORI number. Once an operator holds an EORI number, he can request the Authorized Economic Operator (AEO) status, which can give quicker access to certain simplified customs procedures.
More information about the EORI number can be found at:
U.S. - EU Mutual Recognition Arrangement (MRA)
Since 1997, the United States and the EU have had an agreement on customs cooperation and mutual assistance in customs matters. For additional information, please see: www.ec.europa.eu/taxation_customs/customs/policy_issues/international_customs_agreements/usa/index_en.htm
In 2012, the United States and the EU signed a new MRA aimed at matching procedures to associate one another’s customs identification numbers. The U.S. customs identification numbers (MID) are recognized by customs authorities in the EU, as per Implementing Regulation 58/2013 (which amends EU Regulation 2454/93 cited above):
Revised AEO guidelines (published March 2016):
The EU Battery Directive adopted in 2006 (Directive 2006/66) applied to all batteries and accumulators placed on the EU market including automotive, industrial, and portable batteries. The Directive seeks to protect the environment by restricting the sale of batteries and accumulators that contain mercury or cadmium (with an exemption for emergency and alarm systems, medical equipment, and cordless power tools) and by promoting a high level of collection and recycling. It places the responsibility on producers to finance the costs associated with the collection, treatment, and recycling of used batteries and accumulators. The Directive also includes provisions on the labeling of batteries and their removability from equipment. The EC publishes an FAQ document – last updated in May 2014 - to assist interested parties in interpreting its provisions. For more information, see our market research report:
Registration, Evaluation and Authorization and Restriction of Chemicals (REACH)
REACH applies to all chemicals manufactured in or imported into the EU in quantities exceeding one metric ton. The regulation came into force in 2007 (Regulation 1907/2006) and touches virtually every industrial sector, from automobiles to textiles. REACH imposes a registration requirement on all entities affected by the one-metric-ton criteria by May 31st, 2018. The European Chemicals Agency (ECHA) is the agency responsible for receiving and ensuring the completeness of such registrations: https://echa.europa.eu
U.S. companies without a presence in Europe need to rely on an EU-based partner, typically either an importer or a specialized ‘Only Representative.’
In addition to the registration requirement, U.S. exporters should carefully review the REACH ‘Candidate List’ of Substances of Very High Concern (SVHCs) and the ‘Authorization List’. Under certain conditions, substances on the Candidate List are subject to communication requirements prior to their export to the EU. Companies seeking to export chemicals on the ‘Authorization List’ will require an authorization.
The Candidate List can be found at:http://echa.europa.eu/web/guest/candidate-list-table
The Authorization List is available at: https://echa.europa.eu/information-on-chemicals
Waste Electrical and Electronic Equipment (WEEE) Directive
EU rules on WEEE, while not requiring specific customs or import paperwork, may entail a financial obligation for U.S. exporters. The Directive requires U.S. exporters to register relevant products with a national WEEE authority or arrange for this to be done by a local partner. The WEEE Directive was revised on July 4th, 2012, and the scope of products covered was expanded to include all electrical and electronic equipment.
Romania’s initial obligation was to implement the Directive by February 14th, 2014; however, it did not comply, and, as a result, the EC started a preliminary procedure against Romania on March 31st, 2014 and applied significant fines until the WEEE Directive was finally implemented in 2015. The revised scope will apply starting on August 14th, 2018, with a phase-in period that has already begun. U.S. exporters seeking more information on the WEEE Directive should visit: http://ec.europa.eu/environment/waste/weee/index_en.htm
This Directive is designed to tackle the rapidly increasing waste stream of electrical and electronic equipment and complements EU measures on landfills and waste incineration. Increased recycling of electrical and electronic equipment, in accordance with the directive requirements, limits the total quantity of waste going to final disposal. This directive affects the following product categories:
• Large and small household appliances
• Consumer equipment
• Lighting equipment
• IT and Telecommunications equipment
• Electrical and Electronic Tools
• Toys and Sports equipment
• Medical Devices
• Monitoring and control equipment
• Automatic dispensers
The symbol indicating that a given product is not to be discarded with normal household waste must be displayed on all products that fall under this directive. It is a required mark on batteries. In instances where this symbol cannot be displayed on the equipment itself, it should be included on the packaging.
Directive 2012/19/EU is available online at:
Restriction on Hazardous Substances (RoHS)
The RoHS Directive imposes restrictions on the use of certain chemicals in electrical and electronic equipment. It does not require specific customs or import paperwork; however, manufacturers must self-certify that their products are compliant and affix a “CE” Mark. The 2011 revisions to the RoHS Directive significantly expanded the scope of covered products. Generally, U.S. exporters have until July 22nd, 2019 to bring products into compliance that were once outside the scope. U.S. exporters seeking more information on the RoHS Directive should visit: www.export.gov/europeanunion/weeerohs/index.asp
The EU legislation harmonizing the regulation of cosmetic products has applied since July 11th, 2013. The most controversial element of the regulation was the introduction of an EU-wide system for the notification of cosmetic products to the EC prior to their placement on the EU market. Only an EU-established entity may submit such a notification. Therefore, U.S. exporters must either retain a “Responsible Person” to act on their behalf, rely on their exporter, or establish a presence in the EU.
For more general information, see: https://ec.europa.eu/growth/sectors/cosmetics_en
Phytosanitary certificates are required for most planting seeds, fresh fruits, vegetables, and other plant materials. Sanitary Certificates: For commodities composed of animal products or by-products, EU countries require that shipments be accompanied by a certificate issued by the competent authority of the exporting country. This applies regardless of whether the product is for human consumption, for pharmaceutical use, or strictly for non-human use (e.g., veterinary biologicals, animal feeds, fertilizers, research). The vast majority of these certificates are uniform throughout the EU, but the harmonization process is still ongoing. Most recently, certificates for a series of highly processed products including chondroitin sulphate, hyaluronic acid, hydrolyzed cartilage products, chitosan, glucosamine, rennet, isinglass, and amino acids are being harmonized. Until harmonization is finalized, certain member state import requirements continue to apply. In addition to the legally required EU health certificates, a number of other certificates are used in international trade. These certificates, which may also be harmonized in EU legislation, certify origin for customs purposes and certain quality traits.
Up-to-date information on harmonized import requirements can be found at the following USDA ebsite
Sanitary Certificates (Fisheries)
In April 2006, the EU declared the U.S. seafood inspection system as equivalent to the European one. Consequently, a specific public health certificate must accompany U.S. seafood shipments. The U.S. fishery product sanitary certificate is a combination of Commission Decision 2006/199/EC for the public health attestation and Regulation 1012/2012 for the general template and animal health attestation. Unlike for fishery products, the U.S. shellfish sanitation system is not equivalent to that of the EU. The EU and the United States are currently negotiating a veterinary equivalency agreement on shellfish. In the meantime, the EU still has a ban in place (since July 1st, 2010) that prohibits the import of
U.S. bivalve mollusks, in whatever form, into EU territory. This ban does not apply to wild roe-off scallops.
Since June 2009, the only U.S. competent authority for issuing sanitary certificates for fishery and aquaculture products is the U.S. Department of Commerce National Marine Fisheries Service (NOAA-NMFS). In addition to sanitary certificates, all third countries wishing to export fishery products to the EU are requested to provide a catch certificate. This catch certificate certifies that the products in question have been caught legally.
For detailed information on import documentation for seafood, please contact the NOAA Fisheries office at the U.S. Mission to the EU (firstname.lastname@example.org) or visit the following NOAA-dedicated web site: