Why Most Non-EU Companies Cannot Clear Goods Through German Customs



Germany is the EU’s largest import market, but it has a structural barrier that most non-EU companies don’t discover until their first shipment stalls at customs.

The problem is representation. Under the Union Customs Code, German customs brokers filing on behalf of a non-EU principal face joint and several liability for any declaration error. Most German freight forwarders refuse to proceed under indirect representation because of this personal financial exposure. This means a foreign company without a German-established Importer of Record has no practical route to clear goods through ATLAS, Germany’s electronic customs declaration system.

On top of this representation problem, 2026 has introduced new compliance layers.

CBAM entered its definitive phase on 1 January 2026. Importers bringing in steel, aluminum, cement, fertilizers, or hydrogen above 50 tones annually must register as authorized CBAM declarants, purchase certificates priced at EU ETS auction rates, and declare embedded emissions. The first certificate surrender for 2026 imports is due by 30 September 2027.


Mandatory B2B e-invoicing took effect in January 2025 for domestic transactions between VAT-registered German businesses, requiring structured electronic invoices in XRechnung or ZUGFeRD format.

Import VAT is 19% on CIF plus duty. Germany does not operate a full at-border deferment system like the UK’s Postponed VAT Accounting. However, the §15 UStG amendment effective 30 December 2025 now allows deduction as input tax as soon as the liability arises, regardless of physical payment.

Most IT hardware enters at 0% duty under WTO ITA commitments, but anti-dumping duties on steel, ceramics, solar panels, and chemical compounds from China can significantly increase the landed cost.

A German-established Importer of Record solves the representation problem entirely — holding the DE EORI, filing as principal declarant via ATLAS, managing German VAT registration and import VAT recovery, and handling CBAM compliance.

For the complete 2026 compliance framework including FTA preferences, CE marking requirements, BAFA dual-use controls, and document checklists, read our full guide: [Importer of Record in Germany]

Carra Globe provides Importer of Record, DDP shipping, freight forwarding, Global Warehouse logistics, and Global Trade Compliance services across 170+ countries. Learn more at carraglobe.com

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