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FPS Finance, FPS Economy, NBN
Dutch, French, German
End to End IOR
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We navigate the logistics, regulations, and compliance, connecting global businesses to a growing digital economy. We help you import compliantly, reduce risks, and accelerate your time to market.
An Importer of Record (IOR) service can help a non-Belgian business that needs to import commercial goods into Belgium, but cannot supply the lawful customs, VAT or product-compliance role for that deal. An EORI number or a DDP term is not enough on its own.
Before cargo moves, the parties should confirm who is the customs importer and declarant, whether representation is direct or indirect, who is the Belgian VAT recipient, which IDMS procedure applies, and who carries the product-market duties. One Union Solutions reviews each shipment. When the goods, parties and route are acceptable, we provide direct IOR service support through our own country-specific operating structure. Acceptance still depends on a review of documents, product, sanctions, value, origin and end use.
For accepted shipments, One Union Solutions provides the IOR service directly through its own country-specific operating structure. We do not present an unrelated third-party IOR service as One Union Solutions. Customs declarations and specialist filings may still involve duly appointed brokers or professionals where the approved route requires them.
An EORI number identifies a company. It does not decide who may be the declarant, which type of representation applies, or who carries the customs debt. First identify the Belgian VAT recipient and the transaction. Only then consider ET 14,000 or an onward procedure. A tariff result does not prove that the product may go on the market. The product law, language, records and producer role still need owners.
A Belgian IOR service route should be built from the facts of the deal, not from a generic country checklist. At minimum, the pre-shipment file needs the commercial parties and ownership flow, a product description and TARIC classification you can defend, customs value and origin support, the intended customs procedure, the representation mandate, the Belgian VAT treatment, and the product evidence that applies.
The word importer can mean different legal and operational roles. Treating them as the same thing is one of the main causes of DDP and IOR service plans that do not work. Record each role, and do not assume one label covers another.
FPS Finance issued detailed April 2026 guidance that distinguishes the customs importer from the VAT recipient in IDMS and maps buyer, owner and supplier scenarios. The note says its production activation date is set separately. The role principle is useful for planning, but the exact live data rule must be confirmed before filing. Official note
An assessment is a fit check, not a default. It may conclude that the customer should import, that another customs procedure is a better fit, or that the shipment should not move until a licence, registration or product file is corrected. An IOR service is a controlled role. It is not a way to bypass a rule that has not been met.
The commercial outcome decides which route to assess. The evidence can change the answer. IDMS supports several declaration types. These include H1 for release for free circulation or end use, H2 for customs warehousing, H3 for temporary admission and H4 for inward processing. The correct procedure must follow the actual transaction and any authorisation. A code cannot be chosen only to get a preferred tax result. FPS IDMS
Five decisions need to be locked in before goods move:
Once those decisions are clear, the assessment itself follows a controlled handoff:
Customs acceptance and product-market legality are related, but they are separate. A low or zero duty rate does not prove that equipment may be placed on the market or put into service. Finish these checks before dispatch.
One Union Solutions can review the stated product route and coordinate evidence checks for an accepted shipment. The service does not manufacture missing conformity, issue a manufacturer’s declaration, guarantee authority acceptance, or silently assume an authorised-representative or producer role that has not been agreed and legally supported.
Identify the acts that actually apply — EMC, low-voltage, RoHS, ecodesign or product-safety rules — and check the manufacturer’s evidence and markings. Do not apply a generic “all EEE” checklist. The role and records follow the applicable act. FPS Economy
Confirm RED conformity, frequency and interface conditions, CE/DoC, records and importer identification. Screen current cybersecurity requirements. BIPT states that required instructions and information must be in French, Dutch and German. Some equipment also needs a holder’s licence. BIPT
Map battery category, conformity and label data, producer responsibility, dangerous-goods transport and end-of-life route. EU Batteries Regulation duties are phased and role-specific. Belgian EPR implementation also matters. EU batteries
Identify gas and quantity, prohibitions, F-gas Portal status, quota authorisation and any non-EU only-representative need. Covered equipment can be checked through the portal and customs single-window controls. F-gas Portal
Confirm device status, MDR/IVDR importer and authorised-representative roles, CE, UDI/EUDAMED and relabelling or repackaging. FAMHP states medical-device importers have registered in EUDAMED Actors since 28 May 2026. FAMHP
Determine the placing-on-market date and the applicable machinery framework. Assess declaration, instructions and integration. Do not treat a product as machinery — or not — by description alone. The 2027 transition needs a date check.
Screen the exact CN code against CBAM scope and exemptions. Obtain emissions data if covered. CBAM’s definitive regime applies from 1 January 2026 to selected sector goods. “Rack” does not decide coverage. EU CBAM
Screen parties, origin, destination, end use, sanctions and potential later export or re-export controls. Dual-use status is not automatically an import ban, but it can change acceptance and later movement. EU dual-use
Belgium applies the EU tariff. Duty and measures depend on the exact TARIC code, origin, value, date and any preference, suspension, trade defence, quota or relief. “IT hardware” is not a tariff classification. A product-specific BTI may be appropriate where genuine uncertainty remains. Belgian BTI
The invoice price is not always the final customs value. Freight, insurance, assists, royalties, relationships and other additions or exclusions may matter. Preferential origin needs the applicable agreement rule and proof. The shipment country is not necessarily the origin.
The standard VAT rate is 21%, with reduced and exceptional rates for qualifying cases. Rate, taxable base, liable party, reporting and deductibility depend on the actual goods and transaction. FPS VAT rates
An ET 14,000 authorisation postpones payment of import VAT from customs to the authorised party’s periodic Belgian VAT return. Eligibility requires periodic returns and an EORI linked to the Belgian VAT identification. The authorisation is effective only from grant and does not apply retroactively. It does not itself prove that the VAT is deductible. FPS ET 14,000
If goods are imported in Belgium and then supplied or transferred to another EU Member State, procedure 42 may be considered only when its VAT-number, onward-supply or transfer, and transport-evidence conditions are met. It is not a shortcut for goods whose actual destination or use is Belgium.
A pre-shipment landed-cost estimate should show its assumed TARIC code, origin, value method, procedure, VAT route and exclusions. It is not a binding customs or tax ruling. It should not be presented as “exact” until filing facts and current measures are verified.
The first request should stay light. Sensitive records belong in a secure second-stage review after the shipment is provisionally in scope. Do not put passports, identity documents, complete technical files, bank records or confidential licences into the public web form. Sensitive files should move through an approved secure channel after contact.
For initial triage, we need your name, company and business email. We also need the origin, the Belgium destination and the target date. Give a broad product category and a plain-language description. Tell us whether this is a sale, deployment, lease, loan, repair, return or onward movement. Include the approximate value, quantity and mode, and say whether the goods have wireless, battery, cooling, medical or controlled features.
For commercial and customs review, we need the legal parties, buyer, owner, consignee and end user. Share the invoice or PO, or the intercompany basis, plus packing and transport drafts. Include model descriptions, proposed TARIC, origin and preference proof. We also need value support, Incoterm, currency, EORI/VAT and mandates, plus the procedure, resale or use, and prior entries for returns or repairs.
For product and controls, we need declarations of conformity and a technical-file index. Include labels, manuals and importer or responsible-operator details. Share product registrations, licences and authority correspondence, plus end-use and party-screening records. Add serials and prior export evidence where relevant.
The assessment can cover a shipment-fit review of parties, ownership, route, end use and destination. It can set a Belgian role map for the customs importer, declarant, representation, VAT recipient and product roles. It can also include a document-gap review and a pre-shipment checklist.
We can review the proposed classification and landed-cost assumptions. That review is not a binding ruling. We can coordinate the IDMS procedure and filing data, and review the import-VAT route, including ET 14,000 or procedure 42 relevance. We can screen product triggers for the stated goods and transaction. Where the route is accepted, we can coordinate clearance, manage exceptions and provide an agreed post-entry pack. Freight, warehousing or white-glove coordination can be added when separately scoped.
For an accepted shipment, One Union Solutions can check truthful transaction data for consistency and ask for gaps. We can agree the customs route and coordinate filing under the approved role and mandate. We can review proposed classification and valuation evidence, map the Belgian VAT recipient and planned payment or deferment route, and screen stated product triggers and agreed evidence. We can coordinate ENS and transport data with appointed logistics parties, and we can coordinate delivery or installation when that work is separately scoped.
Seller, buyer, owner, manufacturer and information provider remain responsible for accurate records and disclosures. Declarant and represented-party duties follow the UCC. Indirect representation can create more than one customs debtor. Customs controls classification and value. A review is not a BTI or a valuation ruling. Tax liability, reporting and deductibility depend on facts, VAT status and any representative mandate. Manufacturer, importer, authorised representative, distributor and producer duties follow each law. Missing technical evidence cannot be replaced by customs clearance. Carrier or filer duties and transport liability follow the filing arrangement and contract. Transport, site acceptance, installation, title and damage risk follow logistics and sales contracts.
One Union Solutions does not promise customs release, a fixed clearance time, zero inspection, a specific duty rate, VAT recovery or acceptance of incomplete or non-compliant goods. Authorities keep their powers to inspect, request evidence, reassess, detain or refuse goods.
A shipment can be held if EORI, importer, declarant, representation and VAT-recipient data do not match the approved role map. It can also be held if the invoice says only “parts”, “equipment” or “samples” and omits models, function or transaction basis. Value that conflicts with purchase, freight, insurance or payment evidence is another hold trigger. Preference claimed without meeting the origin rule or proof will also stop the work.
A hold can follow if ENS, commercial and customs data do not align. It can follow if CE appears on the product but the declaration, records, importer details or language information is missing. It can follow if WEEE, battery, F-gas, medical-device, CBAM or other product responsibility is unallocated. DDP, a consignee field or a broker appointment is not treated as proof of a lawful importer role.
We typically pause or decline for sanctioned or unverifiable parties. We also pause or decline for prohibited origin, destination or end use, counterfeit goods, intentional undervaluation or false origin, and missing licences or conformity routes. We will not take goods outside the agreed capability, or medical devices without a lawful MDR/IVDR structure. We will pause if a commercial or tax structure conflicts with the actual movement, or if cargo is sent before the remaining risk can be controlled.
Some of your burning questions answered.
Yes, in the circumstances described by FPS Finance, a non-EU-established operator can apply in Belgium when Belgium is the Member State of its first qualifying customs operation. But an EORI only identifies the operator. It does not automatically make that company an eligible declarant for every route, provide a Belgian VAT solution or satisfy product-market duties. FPS EORI FAQ
A direct representative acts in the name and on behalf of another person. That represented person is the declarant. An indirect representative acts in its own name on behalf of another person and is the declarant. Customs-debt and mandate consequences differ, so the chosen status must match the declaration and the contract.
Not by itself. DDP allocates import-clearance tasks, costs and risk between buyer and seller, but customs, VAT and product law decide whether the seller — or another approved party — can hold the required roles. Access2Markets DDP
No. It postpones payment of import VAT to the authorised party’s periodic Belgian VAT return. The authorisation, linked Belgian VAT and EORI data, the correct declaration method and the separate right to deduct VAT all matter.
Yes, but the route must match the commercial and physical movement. Options can include transit to the final Member State, or Belgian import followed by a qualifying onward supply or transfer. Procedure 42 has detailed VAT-number and evidence conditions. It is not appropriate merely because the truck continues across a border.
Possibly, but free circulation may be the wrong procedure. Temporary admission, inward processing or returned-goods relief should be assessed before shipment, using ownership, purpose, serial-number and re-export or prior-export evidence.
Material customs, VAT and product claims are linked to official Belgian or EU sources. These sources are checked for this transaction page, but current law and authority decisions always control.
This page is prepared by: the One Union Solutions Trade Compliance Editorial Team.
Reviewed by: Wahid Azeem, Trade Compliance Manager.
Source check: 2 September 2026.
Corrections: info@oneunionsolutions.com
Operational disclaimer: This page gives general operational information. It is not legal, tax or regulatory advice. The applicable rule depends on the goods, parties, origin, value, end use, transaction, movement and date. Authority decisions and current law control. A request or preliminary assessment is not shipment acceptance.
