Goods · customs, VAT and product rules

Importing from India:
what applies at the border today.

The EU–India trade agreement closed negotiations in January 2026 and is not yet in force, so ordinary tariffs still apply. Here is what governs a consignment from India today, the EORI number and its deadline, import VAT and how not to finance it, bonded warehousing, and the rule that can make a European entity a legal requirement rather than a convenience.

How we know this
Statutory provisions are cited so you can check them yourself. Figures we describe as verified come from documents in our own files. Anything drawn from our own casework is marked as what we see, not presented as a general rule. Where we cannot support a claim, we leave it out rather than repeat what other guides assert. Rules, fees and bank policies change; verify the current position before you rely on anything here.

At a glance

  • The EU–India free trade agreement closed negotiations on 27 January 2026, and it is not in force. Until Council decision, signature, European Parliament consent and Indian ratification are complete, imports from India stay on ordinary MFN tariffs. Do not price on preferences yet.
  • An EORI number is free, comes from the Generaldirektion of Customs in Dresden, and takes three to four weeks. Apply before the first shipment, not when it is at the port.
  • Deadline in four weeks: from 1 October 2026 the customs portal becomes compulsory for EORI applications. The paper and email forms only work until 30 September.
  • With a deferment account under Art. 110(b) UZK, import VAT is due on the 26th of the second following month (§ 21(3a) UStG) while being deductible as input tax when it arises. Handled properly the cash-flow effect approaches zero.
  • For a range of CE-marked products, Art. 4 of Regulation (EU) 2019/1020 permits placing them on the EU market only if there is an economic operator established in the Union. That is a legal reason for a European entity, not a sales argument.

The trade agreement that is not yet in force

This is the most consequential development in India–Germany trade in years, and it is being misread in both directions.

The EU and India concluded negotiations on 27 January 2026. The agreement removes or reduces tariffs on more than 90 % of goods traded between them: India is to eliminate or reduce duties on 96.6 % of EU goods exports, and the EU is to liberalise 99.5 % of its tariff lines on imports from India over seven years.

It is not in force. After political conclusion the text goes through legal review, a Council decision, signature, the consent of the European Parliament and ratification on the Indian side. Until then, goods arriving from India are dutiable at ordinary MFN rates and the usual border procedures apply.

Two practical consequences. Do not build a landed-cost calculation on preferential rates that do not yet exist, we have seen quotations to German customers priced on the assumption that they do. And start understanding rules of origin now, because when the agreement does apply, preferences will go only to goods that can prove origin under it. That is a documentation exercise with a long lead time, and the companies that prepared for it will have a real advantage over the ones that discover it afterwards.

EORI, and the deadline in four weeks

An EORI number: Economic Operators Registration and Identification, identifies you to customs across the EU. Without one you cannot lodge a customs declaration, which means your goods do not move.

  • It is free. Issued on application by the Generaldirektion of Customs, Dresden office, master data management.
  • One per legal entity, valid throughout the EU.
  • It takes three to four weeks as a rule. This is the number that surprises people who assumed it was an online formality.
Changing on 1 October 2026. From that date, applying for an EORI number, ending one, or changing the master data must be done through the customs portal at zoll-portal.de, which requires a one-off registration. The transitional route using forms 0870a and 0870c by email, post or fax is available only until 30 September 2026. If your German company exists now, the portal registration is worth doing in the next few weeks rather than at the moment you need a number quickly.

The sequence that matters: the EORI is issued to a legal entity, so the company has to exist first. Formation, then EORI, then the first shipment, and since formation takes four to eight weeks and the EORI another three to four, the customs step is not the one to leave until last.

Import VAT, and the cash-flow point most importers miss

Goods entering Germany from India attract customs duty and import VAT at the German rate. The duty is a cost. The import VAT usually is not, and the difference is worth understanding properly, because getting it wrong ties up working capital for no reason.

If your company is entitled to deduct input tax, the import VAT is deductible as input tax at the time it arises, that is when customs clearance takes place and the import VAT assessment is issued. Economically it should be a pass-through rather than a cost.

The problem is timing. Paid at the border and recovered through a later VAT return, it can sit with the tax office for weeks while your money is elsewhere. The instrument for that is a deferment account.

Without deferment

  1. Import VAT payable at clearance.
  2. Recovered later through the advance return.
  3. The gap is financed by you, on every consignment.

With a deferment account

  1. Granted under Art. 110(b) of the Union Customs Code by the competent main customs office.
  2. Import VAT becomes due on the 26th day of the second month following clearance (§ 21(3a) UStG), payable to the federal cash office.
  3. Deductible as input tax when it arises. Handled properly the two roughly cancel.

This is a conversation for your tax advisor and your customs agent, not something to arrange from a web page. But it is worth knowing the instrument exists before you have financed import VAT out of your own pocket for a year.

The bonded warehouse

A customs warehouse holds non-Union goods in the EU with duty and import VAT suspended until they are released for free circulation. You pay when the goods leave for a customer, not when they arrive at the port.

For an importer building up stock in Germany before demand is proven, that is the difference between financing an entire container on arrival and financing each order as it ships. It also makes re-export straightforward: goods that leave the EU again without entering free circulation do not attract EU duty at all.

What that looks like in money. Take a consignment with a customs value of €60,000 and a duty rate of four per cent. On arrival in free circulation you owe €2,400 in duty and €11,856 in import VAT, so €14,256 leaves your account before a single item is sold. Through a customs warehouse, nothing is due on arrival. You release goods in batches as orders come in, and each release carries only its own share.

Straight into free circulation

  1. Duty and import VAT due at the border, on the whole consignment.
  2. You finance the full amount until the goods sell.
  3. Unsold stock has already been cleared and taxed.

Through a customs warehouse

  1. Nothing due on arrival. Goods sit under customs supervision.
  2. You clear and pay batch by batch, as you sell.
  3. What does not sell can leave the EU again with no duty at all.

Be precise about what is saved. For a German company registered for VAT, the import VAT is recoverable as input tax either way, so on goods that do sell it is a timing difference rather than a cost. The duty is not recoverable, and that is where the warehouse earns its keep: on stock that turns out not to sell in Europe, and on the months of working capital you would otherwise have tied up at the border.

How we handle it. We work with a logistics partner in the region who operates a real bonded warehouse — not a bonded arrangement bought in from elsewhere — alongside fulfilment in the same building. That combination is what most of our importing clients actually need: customs status and order-by-order dispatch in one place, rather than a customs agent at one address and a fulfilment provider at another. It pairs with the EORI number and the German entity, which is why these three questions usually arrive together.

Article 4: when EU law requires an operator here

This provision is the strongest reason for a European entity that we know of, and almost nobody selling company formations mentions it, presumably because it applies to a defined list rather than to everyone.

Art. 4 of Regulation (EU) 2019/1020 on market surveillance provides that products within its scope may be placed on the Union market only if there is an economic operator established in the Union responsible for specified tasks. It applies to a defined set of CE-marked product categories.

An importer established in the EU can be that operator where the manufacturer is not established here. The tasks include holding the declaration of conformity and the technical documentation available, being the single point of contact for market surveillance authorities, informing them where a product presents a risk, and cooperating on corrective action.

The practical reading for an Indian manufacturer: for products in scope, selling into the EU without an established operator here is not a commercial disadvantage, it is not permitted. Whether your specific product falls within scope is a question for someone competent to answer it, the categories are defined and the answer is not obvious from the outside. Ask before you ship, because the enforcement point is the border.

You are the manufacturer

Alongside market surveillance sits product liability, and here the position is unambiguous.

§ 4(2) ProdHaftG treats anyone who imports a product into the European Economic Area for sale in the course of business as its manufacturer. Not as a distributor. Liability under the Product Liability Act does not depend on fault, and an indemnity from your Indian supplier gives you a claim against them without standing between you and the injured party.

§ 4(3) adds a documentation duty that is easy to satisfy in advance and impossible to satisfy afterwards: where the manufacturer cannot be identified, every supplier counts as the manufacturer unless it names its own source within one month of being asked. Keep records that let you answer that question, per batch, for years.

The insurance response is product liability cover, usually with extended product liability for recall and reinstallation costs. It is covered in our article on business insurance.

Rules of origin

Two different questions travel under the word "origin" and mixing them up is expensive.

Non-preferential origin determines where goods count as coming from for statistics, labelling and trade measures. It applies now, agreement or no agreement.

Preferential origin is what determines whether goods qualify for a reduced tariff under a trade agreement. It has its own criteria, typically about how much processing happened where, and its own proof requirements. When the EU–India agreement enters into force, only goods that can prove preferential origin under its rules will get the preference. Goods assembled in India from components made elsewhere may or may not qualify, and the answer depends on the rule for that specific product.

The work of establishing this, supplier declarations, bills of materials, calculations, takes months and cannot be done retrospectively. Starting it before the agreement applies is the cheapest competitive advantage available in this whole area.

What to do, in which order

  1. Form the company first. The EORI is issued to a legal entity, and the entity has to exist.
  2. Register in the customs portal and apply for the EORI number. Three to four weeks, and the portal becomes compulsory on 1 October 2026.
  3. Classify your goods, the tariff code decides the duty rate, the import VAT base and which product rules apply. Get it right before the first declaration, because correcting it later means correcting everything filed since.
  4. Ask whether Art. 4 applies to your product. Before shipping, not after.
  5. Sort product liability cover and the supplier records that answer the § 4(3) question.
  6. Discuss the deferment account with your tax advisor and customs agent, and a bonded warehouse if you will hold stock.
  7. Begin the preferential origin work now, so that you can use the agreement on the day it applies rather than six months later.

Formation, the address and the bank are covered in forming a German company from India, and the document chain in documents for a German company from India.

Questions

Sources

Conclusion of the EU–India free trade agreement negotiations, 27 January 2026: European Commission
Applying for an EORI number, competent office and the portal requirement from 1 October 2026: Zoll online
Payment facilities and deferment of duties and import VAT: Zoll online
§ 21 UStG, special rules for import VAT: gesetze-im-internet.de
Regulation (EU) 2019/1020 on market surveillance, Article 4: EUR-Lex
§ 4 ProdHaftG, importers treated as manufacturers: gesetze-im-internet.de

Written by Christoph Schuler
Founder, Business Center Reutlingen. Fifteen years in international automotive at Daimler, two of them living in Bengaluru.

Published 29 August 2026 · Last reviewed 5 September 2026

Business Center Reutlingen provides administrative and organisational support and introduces you to licensed professionals. We do not give legal or tax advice, in Germany only admitted lawyers (Rechtsanwälte) and tax advisors (Steuerberater) may do so.

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