What Is an Importer of Record? (And Do Overseas Brands Need One in the UK)

An importer of record is the name on the UK customs entry, and for an overseas brand the practical question is whose name your warehouse will accept before the stock arrives.

Checked against HMRC guidance on 8 October 2026. Customs and VAT rules change. Confirm your own setup with a customs agent or a tax adviser. The pages this follows are getting someone to deal with customs for you, EORI numbers, and the Fulfilment House Due Diligence Scheme.

The Short Answer

An importer of record is the person or business named as the importer on the UK customs declaration. That name is responsible for the declaration being right, and for the duty and import VAT.

Your 3PL will ask whose name that is before the stock arrives. It is not automatically the warehouse. It is not automatically the carrier.

This is who goes on the form, why the warehouse asks, and what using someone else's name does and does not solve on the first shipment. The definition is the easy part. The part that slows a launch is the warehouse waiting on a VAT number, an EORI, and the freight forwarder's documents.

What is an importer of record?

HMRC's test is practical. The importer is whoever owns or holds the goods between arrival and clearance, whoever has the right to instruct that they be imported, or whoever the goods have to be delivered to.

On the declaration that shows up as a name, an address, and usually an EORI number.

That name is on the hook for the commodity code, the value, the origin, whether the goods are allowed in, and the duty and import VAT. A freight forwarder or a customs agent can file the paperwork. Filing it does not make them the importer. If they act in your name, you stay solely liable. If they act in their own name as well, you are jointly liable. HMRC calls that second arrangement indirect representation. A business that is not established in the UK, and is importing into Great Britain, can only appoint someone to act that way.

The principal row is the one that gets blurred into "just use their importer for a bit". That is a different setup, and it is below.

Why your 3PL asks for a VAT number and an EORI

This is the part I actually see.

Before a UK warehouse will receive stock for an overseas brand, they ask for your VAT number and your EORI number. On each import they also ask for the freight forwarder's documents.

They are collecting those because they have to know who the goods belong to. If they store imported goods for a seller established outside the UK, before those goods have been sold here, they sit inside HMRC's Fulfilment House Due Diligence Scheme. That scheme is still live. Once a warehouse is approved, it has to keep your VAT number, or a VAT exemption number, check it, and keep the import entry number. It has to tell you your UK tax and duty obligations. If you stay non-compliant, it has to stop storing for you.

The EORI is what the customs entry needs. The VAT number is what the scheme tells the warehouse to hold. In practice they ask for both, and they ask before the goods arrive.

Authorised Economic Operator is a separate status, and the name is worth knowing if your warehouse holds it. It means HMRC has checked that the business meets standards on customs compliance, records, and financial solvency, and on security too if they hold that version. It is voluntary. The due diligence scheme is what creates the document request. An AEO warehouse is usually stricter about the pack on every inbound, because the status depends on those controls staying tight.

Importer of record is not the same as DDP

Delivered duty paid says who pays the duty, the import VAT, and the clearance. The importer of record is whose name is on the entry.

You can be responsible for the bill and still have a different name in the box. A carrier can pay HMRC and invoice you back, and still not be the importer. Who pays, and the setup mistakes around that, is in how to ship into the UK duty-paid.

Can someone else be the importer while you get set up?

A customs agent acting indirectly can clear the goods before you have your own EORI. You can move the stock. You stay on the hook with them.

I have seen a number of brands use a third-party importer for the first shipment. Think of it as a waiting room. The importer of record brings the goods through customs. The brand still owns them. The stock sits in the warehouse while the VAT registration comes through. Once that registration exists, the brand starts selling, and later shipments usually come in under their own name.

The waiting room is for holding. It is not a shop you can open early. If the goods are yours and they are already in the UK, you start selling when the registration is through. For a business with no UK establishment the duty to register starts with the first UK sale, or when you expect to make one in the next 30 days. Sell before that and HMRC can date the registration back to the first sale. Why the domestic £90,000 threshold does not apply here is a later post.

The name on the entry does not make the importer the owner. Ownership stays with you unless the contract actually moves it. They also do not file your sales VAT because they cleared the container. They deal with the import: the declaration, the duty, and the import VAT on the way in. Once you are the seller, you charge UK VAT and you file the returns. An agent can send those returns in for you. The liability stays yours.

The arrangement that can change the VAT position is narrower. A UK business that is already VAT-registered imports the goods in its own name and sells them in its own name, and accounts for the VAT. That is section 47 of the VAT Act. It has to be set up on purpose. Confirm it with a tax adviser before anything ships. It is a structure, not a name you borrow for a few weeks while your own store sells the stock.

One related trap, then I will leave the VAT mechanics. HMRC's position is that the owner of the goods should be the importer on the declaration if the import VAT is going to be reclaimed. When those are two different businesses, the import VAT certificate sits with the wrong one.

You do not need to be VAT registered to get an EORI. HMRC says that directly. If you are VAT registered, the EORI mirrors the VAT number. If you are not, you get a separate number, and that one is replaced when you later register. A straightforward UK application often comes back immediately, or within five working days if they run extra checks.

Whether an overseas brand can hold that GB EORI themselves is less tidy. HMRC's technical guidance limits a non-established business to a short list of customs activities and otherwise points you to an indirect representative, while the public application form will still let a non-UK business start an application. How you actually get the number is a later post. Until then, ask the customs agent which side of that you are on.

Get a freight forwarder who will also put a customs agent in place

This is the tip I would actually give you.

Get a freight forwarder who will walk you through the inbound and put a customs agent in place to act for you. That pair is how the first shipment moves: the forwarder on the documents, the agent on the declaration. Sort that before you go looking for a borrowed importer.

The warehouse and the operation around this paperwork sit in the UK fulfilment guide for overseas brands.

What to sort before the first inbound

Three things, before the stock sails.

• Whose name is on the entry. You, or a UK business that has agreed to be the importer.
• The VAT number the warehouse will check. They have to hold it if they are storing unsold imported goods for you.
• The EORI the declaration needs. Yours, or your agent's.

A merchant of record is a different job: who is treated as the seller for VAT on the sale. That is the next post in this series. The UK VAT threshold for overseas sellers, and how to get a UK EORI number, are the two that follow. They are where the registration detail lives.

Before the first inbound: a three-line check

• Name on the customs entry, agreed in writing.
• VAT number ready for the warehouse.
• EORI ready for the declaration, yours or your agent's.

If any of those is fuzzy, that is the work. The newsletter is where I send the next practical bit of this, one a week.

Importer of record: frequently asked questions

What is an importer of record?

An importer of record is the person or business named as the importer on the UK customs declaration. That name is responsible for the declaration being right, and for the duty and import VAT.

Do overseas brands need an importer of record in the UK?

Someone has to be named on the entry. That can be you, or a UK business that has agreed to be the importer. If they are also the seller, that has to be set up properly. A warehouse will not receive the stock against a blank name.

Is my 3PL the importer of record?

Usually no. They are the delivery address. They ask for your VAT number and EORI so they know who they are storing for.

Is the carrier or the freight forwarder the importer of record?

No, unless they have agreed to be. Filing the declaration, or paying HMRC and rebilling you, does not make them the importer.

Is DDP the same as being the importer of record?

No. Delivered duty paid says who pays the duty, import VAT, and clearance. The importer of record is whose name is on the entry. The detail of who pays is in how to ship into the UK duty-paid.

Can I use an importer of record to test the UK before I have a VAT number?

They can get the goods in, and you can hold them until your VAT registration comes through. If you still own the stock, you start selling once you are registered. Confirm any setup where they import and sell in their own name with a tax adviser.

Do I need to be VAT registered to get an EORI number?

No. HMRC issues an EORI without VAT registration. If you later register, that EORI is replaced by one that matches the VAT number.

What is an Authorised Economic Operator?

An Authorised Economic Operator is a business HMRC has checked against an international standard for customs compliance, records, and financial solvency, plus security if they hold that version. It is voluntary. It is why an AEO warehouse is strict about documents on every import. The duty to know who the overseas seller is comes from the fulfilment house scheme.

Wrapping up

An importer of record is the name on the UK customs entry, and that name carries the declaration. For an overseas brand, the useful version of the question is whose name your warehouse will accept before the stock arrives.

Sort the name, the VAT number, and the EORI with a freight forwarder and a customs agent. A third-party importer can get the first stock into the waiting room. Selling it yourself starts once your own VAT registration is through.

About the author

I have spent five years helping overseas ecommerce brands get UK fulfilment working. I lead growth, sales and product at Gonini: I source the warehouse partners, the carriers and the technology, and I am usually the one who has to make them run together. The warehouse ask in this piece is what I see in that work. The tax structure is where I send a brand to a customs agent or a tax adviser. More on the About page.

Keep reading

• The UK Fulfilment Guide for Overseas E-Commerce Brands: how UK fulfilment works for overseas brands, what it costs you in control, and how to choose a partner you can trust with your stock.

Go deeper

• DDP Shipping Explained: How to Ship Into the UK Duty-Paid: who pays the duty and import VAT, and the setup mistakes that cost you customers and margin.
• Merchant of record: who is treated as the seller for VAT on the sale. Next in this series.
• Later posts cover how to get a UK EORI number, and the UK VAT threshold for overseas sellers.

I send one practical UK-fulfilment tip a week, under two minutes to read. If that's useful, subscribe and I'll send you the next one.

If you want the first UK inbound set up properly, connect with me on LinkedIn.