Who Is the Importer? What Brands Need to Know Before Shipping Stock to a Dutch Fulfilment Centre
Almost every conversation we have with a new brand starts the same way. The commercial questions come first — pick and pack rates, storage, shipping to Germany and France. Then, usually in the second or third email, the real question arrives:
"Who actually imports the goods? Do we need a Dutch VAT number? Can you use your import licence for us?"
It is the right question to ask, and it is worth asking early, because the answer shapes your customs paperwork, your cash flow and your launch timeline. Here is how it works in practice.
Storing stock in the Netherlands creates a VAT obligation
This is the starting point that surprises many brands. The moment you hold your own inventory in a Dutch warehouse and sell from it, you are making supplies from the Netherlands. That generally means you need a Dutch VAT registration in your own name — regardless of where your company is established, and regardless of who operates the warehouse.
A fulfilment provider stores and ships your goods. It does not become the owner or the seller of those goods. Your customer buys from you, your invoice carries your name, and the VAT position follows you, not your 3PL.
So the practical answer to "can we just use your VAT number?" is no — and any provider who says yes is describing an arrangement you probably do not want to be part of.
You will need an EORI number
An EORI number is the identifier customs authorities use for any business importing into or exporting out of the EU. One EORI is valid across all member states, and you obtain it in the country where you are established, or — if you are outside the EU — in the first member state where you carry out customs activity.
Getting an EORI is usually quick and free. It is not the bottleneck. The bottleneck is deciding who acts as importer of record.
Importer of record: three realistic routes
Route 1 — You import in your own name. You register for Dutch VAT, obtain an EORI, and appear on the customs declaration as the importer. You keep full control and full visibility, and you carry the compliance responsibility. This is the standard route for brands with a longer-term European plan.
Route 2 — Your supplier or forwarder delivers DDP. Your Chinese, Turkish or US supplier ships Delivered Duty Paid and handles the import formalities. Simple on paper, but you often lose sight of what was declared, at what value, and under which HS code. If the declaration is wrong, the exposure usually finds its way back to you as the goods owner.
Route 3 — A limited fiscal representative acts for you. A Dutch fiscal representative handles the import declarations and VAT reporting on your behalf under their own licence. This is the common route for non-EU companies who want the cash-flow benefit of Article 23 without setting up a Dutch entity.
Article 23: the reason so many brands import through the Netherlands
Normally, import VAT is payable at the border. You pay it, then reclaim it later in your VAT return. The money comes back, but it sits with the tax authority in the meantime — and on a €200,000 container that is a meaningful amount of working capital parked for a quarter.
The Netherlands offers an alternative. Under an Article 23 licence (artikel 23 vergunning), import VAT is not paid at the border at all. It is reverse-charged to your periodic VAT return, where it is declared and deducted in the same filing. The net cash effect for a business with full deduction rights is zero.
Two things worth knowing:
- If your company is established outside the EU, you cannot hold an Article 23 licence directly. You access it through a fiscal representative, who applies it on your behalf.
- The licence covers import VAT deferment. It does not eliminate customs duty, which remains payable on import.
This deferment scheme is a genuine structural advantage of routing European inventory through the Netherlands, and it is one of the main reasons Schiphol and Rotterdam function as entry points for brands that sell across the whole continent.
After import, the picture changes again
Once your stock has cleared customs and sits on a shelf near Schiphol, every subsequent sale is either a domestic Dutch sale or an intra-EU distance sale. That means:
- OSS (One Stop Shop) is the relevant scheme for your B2C sales to customers in other member states. You charge the destination country's VAT rate and report everything through a single quarterly return, instead of registering in each country individually.
- IOSS applies to goods shipped to EU consumers from outside the EU with a value under €150. Once your inventory is already inside the EU, IOSS is no longer the mechanism you are using for those orders. Brands frequently mix these two up, and it leads to incorrect filings.
- B2B sales to VAT-registered businesses in other member states are typically zero-rated intra-community supplies, provided you hold a valid VAT number for the customer and proof of transport.
What your fulfilment partner should and should not do
A good 3PL will help you get this right. That means providing the warehouse address and details your fiscal representative needs, delivering accurate inbound and outbound records, working with your customs agent on documentation, and shipping under carrier and label configurations that suit your market.
It does not mean adjusting declared values, restating country of origin, or issuing commercial invoices that do not reflect the actual transaction. We say no to those requests, and we say it clearly. Neutral outer labelling and unbranded shipping are perfectly legitimate and we support both. Misrepresenting a customs declaration is a different thing entirely, and the liability lands on the goods owner long after the container has been unloaded.
A practical sequence
If you are three months out from a European launch, this is the order that works:
- Decide your import route — own registration or fiscal representation.
- Apply for your EORI number.
- Register for Dutch VAT and, if applicable, appoint a fiscal representative who can extend Article 23 to you.
- Confirm HS codes and duty rates for your product range.
- Register for OSS if you will sell B2C across borders.
- Book your first inbound shipment and share the paperwork with your fulfilment partner in advance.
Steps 1 to 3 take longer than most brands expect. Start them before the container is on the water, not after.
A note: the above is general information, not tax advice. Your specific position depends on your corporate structure, product category and sales channels — a Dutch tax advisor or fiscal representative should confirm the details for your case.
If you are evaluating the Netherlands as your European fulfilment base, we are happy to walk through the practical side with you — what arrives at our door, what we need from your customs agent, and how quickly we can get you live. Our facilities near Schiphol handle B2C and B2B fulfilment for brands from Asia, the Middle East, Turkey and across Europe, and onboarding takes two weeks from signature. Get in touch to discuss your setup.
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