Centralised clearance for import (CCI): the customs rules are uniform, the tax rules are not

Declare in the country where you are established for goods presented in another member state, then meet the tax rules of the country where the goods are

CustomsClear
CustomsClear
Expertise and AI analysis you can act on
Published 18 Aug 2026
Centralised clearance for import (CCI): the customs rules are uniform, the tax rules are not
Adobe Sock
Procedures
Duties & taxes
EU - European Union

Centralised Clearance for Import (CCI) allows a person to lodge a customs declaration at the customs office responsible for the place where the person is established, for goods presented to customs at a customs office in another member state. A company established in Poland can declare in Poland goods presented to customs in Hamburg.

Two customs offices take part:

  • the supervising customs office, where the declaration is lodged;
  • the presentation customs office, where the goods are.

Who can be authorised

The applicant must be an authorised economic operator for customs simplifications (AEOC). Article 149 of the UCC Delegated Act lists the procedures covered: release for free circulation, customs warehousing, temporary admission, end-use, inward processing, outward processing, export and re-export. The application goes through the EU Customs Trader Portal and a consultation procedure with each member state of presentation. That consultation is where national tax conditions are attached to the authorisation.

Check the guarantee first. Under Article 89(2) UCC a guarantee may be limited to one member state. A comprehensive guarantee covering only the country of establishment does not support a CCI authorisation used elsewhere.

CCI went live on 1 July 2024 with eight member states. Others are joining gradually, so check the current position. The European Commission publishes a practical guide with national contact points and requirements, last updated on 16 July 2026.

Why the tax rules are the difficulty

The UCC is a Regulation. It applies directly and in the same terms everywhere. VAT is governed by a Directive, and the Directive leaves the rate, the arrangements for payment and the person liable to each member state. National excise duties are also left to national law.

Import VAT is due in the member state where the goods are located when they enter the EU (Article 60 of the VAT Directive 2006/112/EC), or, for goods under a suspensive arrangement, where they cease to be covered by it (Article 61). CCI moves the declaration, not the goods. Two further provisions follow: Article 211 leaves the arrangements for payment to each member state, and Article 201 leaves it to each member state to designate the person liable, who need not be the customs debtor under Article 77(3) UCC.

A single authorisation covering three member states of presentation therefore means three sets of national rules.

What varies between member states

The national rules decide Examples
Which VAT payment method is allowed Postponed accounting only: Belgium, Denmark, Finland, Lithuania, Malta, the Netherlands, Poland, Slovenia, Slovakia. Deferred payment only: Germany, Greece, Italy. Both: Austria, Bulgaria, Croatia, Estonia, Hungary, Latvia, Luxembourg, Spain
What you must obtain first A VAT registration, usually through a tax or fiscal representative. A separate authorisation for postponed accounting in Belgium, the Netherlands, Hungary, Ireland, Luxembourg and Malta. An opt-in window in Spain and Portugal
Whether a VAT guarantee is needed Not needed under postponed accounting in most member states. Required for deferred payment in Austria, Croatia, Cyprus, Czechia, Estonia, Latvia and Spain. A bank guarantee even for postponed accounting in Malta
Who calculates the VAT, and who tells you Customs calculates it in most member states. The declarant supplies the figure in Spain, Italy, Slovenia and Portugal. There is a dedicated electronic message in Germany, Denmark, Hungary and Bulgaria, and no notification at all in Czechia, Poland, Romania, Slovenia or Sweden
Which national data must be in the declaration Germany: document 9DFJ, VAT number with role code FR7, an eleventh national digit on the commodity code, and delivery costs after entry in the 'Tax base' data group. Sweden: code 1MT for the customs value. Ireland: code 1PAY. Slovenia: FR7, and FR3 for a joint tax representative
Which national taxes apply Taxes that are not harmonised and exist in one country but not the next: the German coffee tax, the Dutch consumption tax on non-alcoholic beverages, the Swedish chemical, nicotine and snus taxes

Harmonised excise duty is divided in the same way. Poland excludes excise goods from cross-border centralised clearance (Article 7c of the Excise Duty Act). The Netherlands requires procedure code 45 for excise goods when it is the country of presentation.

Germany: the requirements in practice

Germany allows only deferred payment (code E) for import VAT under CCI, so the person liable must hold a German deferment account. From 1 January 2026, section 21b of the German VAT Act, introduced by the Steueränderungsgesetz 2025, states when a declaration lodged in another member state counts as the German import VAT declaration. Three conditions must all be met: the declaration has been transmitted to the competent German customs authority and recorded in an editable form; it contains all the information relevant to the assessment of import VAT; and the declarant, the representative or a permitted third party holds a deferred payment authorisation under Article 110(b) or (c) UCC for German import VAT.

Obtaining that authorisation takes two national steps. First the deferred payment authorisation, from one of seven main customs offices competent by region, chosen by the place where the goods are released for fiscal purposes rather than the company's registered office. Then the BIN code, without which deferred payment cannot be used in ATLAS. Both run through the German customs portal and generally require ELSTER, the German tax portal. The EU Customs Trader Portal grants the authorisation. A national portal decides whether you can use it.

This creates a role for customs representatives, who can provide their own guarantee and deferment account under Article 89(3) UCC. It also creates exposure for them. The member state where the goods were released keeps the right to verify that they were properly cleared and taxed, and the burden of proof lies with the importer (Case C-643/17, Suez II, judgment of 7 March 2019). That exposure lasts up to three years, until the time limit in Article 103 UCC expires. Where the authorisation holder is not established in the country of presentation, the representative is the party the authority can reach.

Article: 'Centralised clearance for import and deferred payment authorisations in Germany: practical challenges' by Michael Lux, CCRM Issue 36.

Before you apply: six questions for each country of presentation

  1. Is our comprehensive guarantee valid there?
  2. Which VAT payment method does it allow, and does that match the authorisation?
  3. Do we need a VAT registration, and can we obtain one without a tax representative?
  4. Who is the person liable for the import VAT under its law: we, our representative or our customer?
  5. Which national codes and documents must go into a declaration lodged in another country?
  6. What are the national VAT rates for our goods, and are there national taxes?

Questions 1 to 5 are answered by the Commission's practical guide.

What happens next

The Council and the European Parliament agreed the EU customs reform on 26 March 2026. It establishes the EU Customs Authority and the EU Customs Data Hub, and creates the Trust and Check trader, whose customs obligations are concentrated in the member state of establishment. The Commission had originally proposed to replace centralised clearance with that scheme. Whether the tax rules can follow remains open. As long as the VAT and excise Directives place the tax where the goods are, concentrating every aspect of an import in one member state stays legally difficult.

Use case

A CCI holder established in Germany declares in Hamburg a consignment of Brazilian roasted coffee presented in Hamburg and sold on the German market. Question to Smart Taric AI: "09012100 from Brazil to Germany, what is VAT?".

Now a second consignment of the same coffee, presented in Rotterdam and sold on the Dutch market. Question to Smart Taric AI: "09012100 from Brazil to the Netherlands, what is VAT? Any national taxes?".

The EU measures are identical. Everything else differs. Smart Taric AI shows you the differences in seconds. Try Smart Taric AI.

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