EORI, VAT and the Registrations You Need Before a First Import

28 August 2026 · The Glow Trade

A retailer's first Korean order is three weeks from landing when the forwarder asks for her EORI number. She does not have one. The number itself is free and, in her country, a fifteen-minute online form, but the form wants her VAT details first, and the VAT registration she assumed existed turns out to be the domestic kind, not the kind the customs system accepts. The shipment waits four days at the airport warehouse while three offices confirm what she is.

Every first importer runs some version of this. The registrations are few, mostly free and mostly fast, but they depend on each other, and doing them in the wrong order is what turns an afternoon of admin into a fortnight. Here is the order that works, with realistic times.

The short version

Four registrations cover a first cosmetics import into the EU: an EORI number from your national customs authority, a VAT registration valid for intra-EU and import transactions, a CPNP account via EU Login for the cosmetics side, and the packaging register of your country. Only the last one costs money, and only when you license volumes.
Sequence matters: VAT details feed the EORI application, the EORI feeds the customs declaration, and the CPNP notification has to exist before the product is placed on the market, not after the inspection.
None of these is optional at any scale. Germany's LUCID packaging register, for example, has no minimum threshold: the first carton makes you liable to register.

Step one: VAT, because everything asks for it

You almost certainly have a tax number. What the import process wants is the VAT identification that works across borders: in most countries it is the same registration, activated or confirmed for intra-EU trade, but it is worth a five-minute check with your tax adviser or the tax office portal before anything else, because the EORI application and the import-VAT deferral options both key off it.

While you are there, decide how you want to handle import VAT, because the choice changes a field in your future customs declarations. The options differ by country: Austria lets a registered business book import VAT to its own tax account under paragraph 26(3) of the Austrian VAT act, which makes the tax cash-neutral in a single return. Germany runs a deferment account that moves payment to the 26th of the second following month. Other countries have their own mixes, and how import VAT on Korean cosmetics actually behaves walks through the main ones. Knowing your answer now means the instruction goes into the first declaration instead of the fifth.

Step two: the EORI number

The Economic Operators Registration and Identification number is the ID every customs declaration in the EU keys on, required by Article 9 of the Union Customs Code for anyone lodging a declaration. It is issued by your national customs authority, it is free, and in most member states it is an online form that takes minutes to submit and hours to a few days to activate. In several countries it is simply your VAT number with a country prefix; in others it is a separate identifier.

Two practical notes. Apply at least two weeks before the shipment lands, because "active in the system" and "visible to your broker's software" occasionally lag each other. And one EORI covers the whole EU: you do not need a second one because your goods land in Rotterdam while you sit in Graz, though the country of first import can matter for VAT mechanics.

Step three: the cosmetics side, CPNP via EU Login

Customs is not the law that decides whether you may sell the goods. That is the cosmetics regulation, and its front door is the Cosmetic Products Notification Portal. If you import a cosmetic from Korea and no one else has validly notified that exact product for the EU market with a Responsible Person covering your import, you are the Responsible Person, and the notification duty is yours before the product is placed on the market.

The account is free: an EU Login, then access to CPNP through the Commission's portal. What is not free, and not fast, is everything the notification stands on: the product information file, the safety assessment, the labelling. So treat step three as a gate, not a form. The day you seriously plan a direct import is the day the compliance build starts, and the full weight of what the Responsible Person owes is laid out in who the Responsible Person is and what the role obliges. The alternative, buying inside the EU from stock that already carries all of this, is exactly the trade-off in the real math between Korea-direct and EU wholesale.

Step four: the packaging register

The registration everyone forgets. Whoever first places packaged goods on a national market owes extended producer responsibility for the packaging, and an importer is that "whoever" for their cartons, boxes and product packs. In Germany that means registering in the LUCID packaging register before the first shipment and contracting a dual system; the register entry itself is free, the licence costs money by weight, and there is no de-minimis threshold. Austria runs its own registration and licensing scheme, other countries theirs. The detail and the fees are in packaging EPR for cosmetics importers; the point here is that the register takes minutes and the penalty conversation takes years, so do it the same week as the EORI.

The sequence on one page

FIRST-IMPORT REGISTRATIONS, in order

WEEK 1
  1. VAT: confirm cross-border validity with tax office/adviser.
     Decide import-VAT handling (defer or pay-and-reclaim).
  2. EORI: online application at national customs. Free.
     Active in hours to a few days. One number, whole EU.

WEEK 1-2
  3. Packaging register: LUCID (DE) / national scheme (AT etc.).
     Register free, licence by kg. No minimum threshold (DE).
  4. Forwarder/broker chosen and briefed. Give them EORI + VAT
     + your import-VAT instruction.

BEFORE THE GOODS ARE PLACED ON THE MARKET (not after)
  5. CPNP: EU Login account, then notification per product.
     The account is fast; the file behind it is not.
     Start compliance the day you plan the import.

Total cost of the administrative part: zero to low hundreds of euros, plus the packaging licence by weight. Total time if sequenced like this: about two weeks, most of it waiting. Total time if sequenced badly: the four days your first shipment spends in a bonded warehouse at storage rates, which is how most people learn the order.

Questions buyers ask

Do I need an EORI in every country I import through?

No. One EORI, issued by your own member state, is valid for declarations anywhere in the EU. What can differ by country is the VAT handling of the import itself, which is why businesses that import frequently through a fixed foreign port sometimes look at local VAT registration there. For a first import through your home country, your home EORI and your home VAT registration are the whole answer.

I only buy from an EU wholesaler. Do I need any of this?

The EORI and CPNP duties sit with whoever imports from a third country; buying inside the EU means that is not you. What does not disappear is the packaging register: if you are the first to place packaged goods on your national market you owe it, and buying from a wholesaler in your own country means they owe it for those goods. The registration that always survives is the one you owe for anything you import yourself, including a single trial carton from Korea, which is why it belongs on this list regardless of where you expect most of your stock to come from.

How long is all of this valid, and what does it cost to keep up?

EORI and the CPNP account do not expire and cost nothing. Packaging registration is the one with homework: volumes are licensed and reported per year, the licence renews annually, and the cost scales with the kilograms you place on the market. Budget an afternoon a year for the reporting, and keep the registration confirmations with your customs documents, because marketplaces have started asking sellers for the register number the same way they ask for the VAT ID.