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As of the 1 December 2019, non-EU companies can no longer be the 'exporter'


Since the implementation of the UCC and the introduction of the new definition of 'exporter' there has been a lot of discussion around this subject.

Dutch Customs has now published a news message stating that as of 1 December 2019 it is no longer possible to include a non-EU company as the 'exporter' of the goods in box 2 of the export declaration.

What does this possibly mean for your company?

We advise companies to check whether in their setup, a non-EU company is mentioned in box 2 of the export declaration. If so, it will be essential to review your supply chain and to see which party could act as the 'exporter' as of December 1st and which steps need to be taken to make this happen, e.g. contract between non-EU company and the party who will be included in the export declaration.


From a VAT point of view, the export declaration is often used as evidence to apply the 0% VAT-rate for export.

Since it is not possible anymore from the 1st of December to include the name of the non-EU company as the ‘exporter’ on the export declaration, this could cause difficulties in providing proof they have exported the goods and as such rightfully claimed the 0% Vat at export.

Possible solutions

Belgium has provided a practical solution. It is possible in the Belgian export declaration to mention the exporter for VAT purposes in box 44. This ensures that the non-EU company will still be mentioned in the export declarations. Such a solution could also work for other Member States.


Please note that in case of a No-Deal Brexit, UK-based exporters, exporting goods from the EU will also qualify as non-EU companies. As such, the aforementioned implications will also affect these companies exporting goods from the EU.

Let’s talk

If you have any questions regarding the above or require any assistance, please do not hesitate to contact Claudia Buysing Damsté or Suzanne Bras.

Contact us

Claudia Buysing Damsté

Claudia Buysing Damsté

Partner, PwC Netherlands

Tel: +31 (0)65 103 04 63

Suzanne Bras

Suzanne Bras

Senior Manager Customs & International Trade, PwC Netherlands

Tel: +31 (0)65 395 86 76

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