Guides / Importer of record UK · Updated 19 October 2026

Importer of record in the UK: who takes on the role and why it matters

Importer of record is a contract term, not an HMRC one. Here is what the role means in UK customs terms, who can hold it, and what changes if your business is not established in the UK.

This guide is also available in Polish.

The short answer

"Importer of record" is a commercial label, not a role you will find defined in HMRC's import guidance. When suppliers, marketplaces or freight forwarders use it, they usually mean the business in whose name the goods enter the UK: the one whose details go on the import declaration as the importer, who carries responsibility for the duty and import VAT, and who receives the evidence needed to reclaim that VAT.

GOV.UK describes the same ground with different words. It talks about the importer, the declarant (HMRC's technical glossary calls the declarant the person or company responsible for making a declaration) and the person you appoint to deal with customs on your behalf. If someone asks you to "act as importer of record", translate the request into those official pieces and check each one separately.

The pieces that make up the role

An EORI number

GOV.UK's step-by-step import guide says you need an EORI number starting with GB to import goods into England, Wales or Scotland, and you may also need one starting with XI for Northern Ireland movements. If you appoint someone to deal with customs and you are established in the UK, you still need your own EORI number.

A customs declaration

You can make import declarations yourself or hire someone to do it. GOV.UK notes that most businesses that import goods use a transporter or customs agent. Hiring an agent does not hand over the whole role: HMRC is clear that you remain responsible for due diligence on your declarations, and the agent cannot act for you without written instructions.

Liability for duty and import VAT

Who is liable depends on how the agent represents you. Under direct representation the agent acts in your name and you are solely liable for record-keeping, the accuracy of the declaration and any duty or import VAT due. Under indirect representation the agent acts in its own name and is jointly and severally liable with you. Our guide to direct vs indirect customs representation explains the written authority and the practical differences.

The import VAT evidence

This is often the real reason people care who the importer of record is: only the right business can recover the import VAT. There are two routes.

• Postponed VAT accounting. Your business must be registered for VAT in the UK, but you do not need any approval to account for import VAT on your VAT Return. You must be importing the goods for use in your business and have the right to dispose of them, usually as the owner. An agent acting for you must use your EORI number or VAT registration number on the declaration, and the import then appears on your monthly postponed import VAT statement.
• C79 certificates. Where import VAT is paid at import, HMRC publishes import VAT certificates online every month, usually by the 10th working day, covering the previous month. Access is linked to your EORI number, and the certificates help you recover the VAT as input tax.

If a declaration is lodged under the wrong EORI or VAT number, the evidence ends up with the wrong business. Our page on C79 certificates and postponed VAT statements covers what to keep.

Who can be importer of record in the UK if you are not established here

This is where most cross-border sellers get stuck. HMRC's test is fairly specific. A company is established in the UK if it is incorporated at Companies House; limited partnerships and LLPs if registered there; an individual if they have a residence or are usually resident in the UK; and an unincorporated business if it has a permanent place in the UK where it carries out business activities. HMRC adds that holding a UK VAT or EORI number does not necessarily prove you are established.

If your business is not established in the UK, three things follow from GOV.UK guidance:

• When importing into Great Britain, you can only ask someone to act indirectly on your behalf, which means the agent shares liability with you.
• If you are not eligible to apply for an EORI number yourself, you need to appoint someone to deal with customs, and that person gets the EORI number instead of you.
• If you want to use postponed VAT accounting, you must tell the person dealing with customs to select it on the import declaration and enter your details.

Some customs facilities are also tied to establishment. HMRC lists special procedures authorisations, simplified customs declarations, Authorised Economic Operator status and a customs comprehensive guarantee among the rules that need it.

Typical situations

Selling to UK businesses

When the UK buyer imports, the buyer is effectively the importer: its GB EORI, its choice of agent, and its VAT evidence. This is often the simplest arrangement for an overseas supplier, because the buyer usually already has an EORI and, if VAT-registered, can use postponed VAT accounting.

Delivering duty paid to consumers

For consignments of £135 or less sold directly to customers, GOV.UK says the seller must charge and account for VAT at the point of sale, unless it is a business-to-business sale where the customer has given its UK VAT number. Above that value, normal VAT and customs rules apply at import. A seller that promises duty-paid delivery is therefore taking on the importer's side of the transaction and needs the EORI, representation and VAT arrangements described above.

Holding stock in the UK

GOV.UK states that an overseas seller who owns goods of any value located in the UK at the point of sale must register and account for VAT on sales made directly to customers in Great Britain or Northern Ireland. If you ship stock to a UK warehouse and sell from there, plan the import and the VAT registration together.

Before your first shipment

• Agree in writing who will be the importer for each type of sale.
• Check whether that business is established in the UK under HMRC's test.
• Confirm a GB EORI exists, or that the appointed person will hold one.
• Give the agent written instructions, including direct or indirect representation.
• Decide between postponed VAT accounting and paying VAT at import, and make sure the right identifiers go on the declaration.
• Know where the postponed VAT statement or C79 will appear and who will download it.

Easy Clearance has a longer explainer on who acts as importer of record in the UK, with separate scenarios for business sales, marketplace stock and duty-paid e-commerce.

Related guides

• Import VAT evidence: C79 certificates vs postponed VAT statements

• UK VAT registration for EU businesses: when it is required

• Postponed VAT accounting for first-time importers

Sources

• Import goods into the UK: step by step (GOV.UK)
• Check what you need to consider before getting someone to deal with customs for you (GOV.UK)
• Check if you are established in the UK or EU for customs (GOV.UK)
• Check when you can account for import VAT on your VAT Return (GOV.UK)
• Get your import VAT certificates (GOV.UK)

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.