Who Is the Importer of Record for Your China Parcels?

The question behind the question

Sellers who take their accounting seriously eventually ask a version of this: my goods are entering the EU or the UK, import VAT must be involved somewhere, so where are my import documents and why can my accountant not reclaim anything? It is a good question, it is asked more often as a business grows, and the honest answer is usually not the one the seller expects.

The short version is that for small parcels moving on the ordinary cross-border channels, there is normally no import VAT standing in the seller's name to reclaim — not because the paperwork is missing, but because that model does not create it.

Two different ways goods cross a border

In the parcel model, each order ships individually from China to the end customer. Clearance is handled in bulk by the carrier or its clearance partner, typically under a scheme designed for low-value consignments. The seller is not named on an import declaration. There is no per-parcel customs entry in the seller's name, and consequently nothing for the seller to deduct.

In the importer model, goods move as a commercial consignment into a warehouse in the destination market. Somebody is formally the importer of record on that entry. If that party is the seller's own company, holding the entry document in its own name, then import VAT paid at that entry is generally recoverable through its VAT return in the normal way, subject to the rules of the country concerned.

Why the low-value scheme changes the picture

The EU's Import One-Stop Shop applies to distance sales of imported goods in consignments not exceeding €150. Under it, VAT is charged to the customer at the point of sale and declared through a monthly return rather than collected at the border. That is output VAT on a sale, not import VAT paid by the seller. Nothing was paid at import, so nothing is reclaimable — the amount was collected from the customer and remitted.

When a logistics provider clears parcels under its own arrangements rather than the seller's, the same conclusion follows for a different reason: the seller is not the importer, so the seller has no entitlement to the entry or to any deduction based on it.

The 2026 per-consignment customs charge is a separate thing

Sellers frequently conflate VAT with the fixed EU customs handling charge that applies per consignment. They are different instruments with different bases. The handling charge is not VAT, is not recovered through a VAT return, and applies per distinct commodity code in a parcel rather than per unit — so a mixed-product parcel can carry it several times. Treat it as a landed-cost line, not a tax position.

What becoming the importer of record actually requires

• An economic operator registration for customs purposes in the destination territory.
• VAT registration where the model requires it, which frequently means registering in the country of importation.
• A customs broker or freight forwarder instructed by you, with the entry made in your company's name.
• Commercial invoice, packing list and correct commodity classification and valuation for the goods.
• Retention of the import entry document — this, not the freight invoice, is what supports a deduction.
• Acceptance of the compliance exposure: classification, valuation, origin and product-compliance obligations sit with the importer.

A supplier can quote goods on ex-works or free-on-board terms so that you or your forwarder take control at origin. That is the practical mechanism by which a seller becomes the importer rather than a recipient.

Which model fits which seller

The parcel model suits testing, unproven products, wide catalogues and sellers who do not want a tax registration in another country. It costs more per unit and produces no recoverable import VAT, but it carries almost no fixed overhead and no inventory risk.

The importer model suits proven, concentrated demand: a small number of SKUs selling reliably in one market, at a volume where bulk freight and local dispatch beat per-parcel economics. It produces clean documentation, it can improve delivery times, and it introduces registration costs, professional fees, inventory risk and real compliance duties. It is a business-structure decision, not a shipping preference.

Get advice before you restructure

VAT recovery rules, registration thresholds and low-value import treatment differ by country and change over time, and this guide is general information rather than tax advice. Before moving to an importer-of-record model, confirm the current requirements with an accountant or tax adviser in the destination country and with the relevant tax authority. What a fulfilment partner can tell you reliably is which model your goods are actually moving under today, and what documents that model does and does not generate.

Choose the import model before promising the tax treatment

Ask your partner one direct question: on my current shipments, who is named as the importer? If the answer is not your company, there is no import VAT of yours to reclaim, and the route to changing that is a different shipping model rather than better paperwork.