IOSS Registration Without an EU Company: A Guide for Non-EU Sellers

Reviewed by Michael Bauer, Cross-Border VAT Consultant Updated

If your company is registered in the United States, the United Kingdom, Hong Kong, China or anywhere else outside the European Union, and you sell low-value goods to EU consumers, you have probably come across IOSS: the Import One Stop Shop. It lets you charge EU VAT at checkout and report it in one monthly return, instead of dealing with 27 separate systems.

For non-EU businesses there is one extra step that often causes confusion: in most cases you cannot register for IOSS yourself. You need an intermediary established in the EU. This guide explains how that works, what you commit to, and when IOSS is not the right tool at all.

What IOSS does

Since 1 July 2021, every parcel imported into the EU is subject to import VAT, however small its value. IOSS was created so that sellers of low-value goods can collect that VAT at the moment of sale.

  • IOSS applies to consignments with an intrinsic value of up to €150. Excise goods such as alcohol and tobacco are excluded.
  • You charge VAT at the rate of the customer's country at checkout, for example 19% in Germany, 20% in France or 21% in the Netherlands.
  • The parcel carries your IOSS number, so customs releases it without collecting VAT from the customer.
  • You report and pay all IOSS sales in one monthly return, due by the end of the following month.

For the customer, the result is simple: the price paid at checkout is the final price, with nothing to pay on delivery.

Why non-EU sellers usually need an intermediary

A business established outside the EU generally has to appoint an IOSS intermediary: a person or company established in the EU that registers for IOSS on your behalf and is jointly responsible for your IOSS obligations. The only exception is a business established in a country with which the EU has a VAT mutual-assistance agreement, and that list is very short.

In practice, this means:

  1. You choose an intermediary in an EU member state. That member state becomes your member state of identification.
  2. The intermediary registers you and receives an IOSS number that is valid across the entire EU.
  3. Every month, you provide sales data; the intermediary files the return, and you pay the VAT.
  4. You keep records of every IOSS sale for ten years and make them available to any EU tax authority on request.

Because the intermediary shares liability for your VAT, expect them to ask for financial guarantees, detailed onboarding documents and reliable monthly data. That is not bureaucracy for its own sake; it is how they protect themselves.

What IOSS does not solve

IOSS is useful, but it is not a universal answer. It does not help you in these situations:

  • Consignments above €150. Higher-value parcels fall outside IOSS. Either you import the goods yourself, which usually means a VAT registration in the country of import, or your customer imports them and pays import VAT on delivery.
  • Stock held in the EU. If you ship from an EU warehouse, you need a VAT registration in the warehouse country, and cross-border sales are reported through the Union OSS, not IOSS.
  • Marketplace sales. For imported consignments up to €150 sold through a marketplace, the marketplace is usually treated as the supplier and handles the VAT itself.

IOSS or customer as importer?

There is a second legitimate model for low-value imports: the customer acts as the importer. In that case you do not charge EU VAT at checkout, and the customer pays import VAT on delivery, usually together with a handling fee from the carrier.

Both models are legal, and both have trade-offs:

  • IOSS gives your customer a clean checkout with no surprise charges, but it means a registration, an intermediary, monthly filings and shared liability.
  • Customer as importer avoids an EU registration for those sales, but the customer pays on delivery. That has to be communicated clearly, and some customers will refuse parcels.

What does not work is mixing the two: charging VAT at checkout without IOSS, or using an IOSS number while also letting the carrier collect VAT from the customer. That leads to double VAT for the customer and a mismatch in your reporting. We explain the difference in detail in DDP vs DAP for EU dropshipping.

Common IOSS mistakes by non-EU sellers

  • Publishing the IOSS number. Your IOSS number should only be passed to carriers and customs through the shipping data. If it leaks, others can misuse it.
  • Using the wrong VAT rate. The rate depends on the customer's country and on the product. A single flat rate across the EU is almost always wrong.
  • Splitting orders to stay under €150. Deliberately splitting one order into several parcels to use IOSS is not allowed.
  • Returns that do not match payments. Tax authorities receive payment data through CESOP. If your IOSS returns do not match what flows through your payment providers, questions will follow.

Frequently asked questions

Can a US LLC or UK limited company register for IOSS directly?

Generally no. Most non-EU businesses need an EU-established intermediary. The exception only applies to countries with a VAT mutual-assistance agreement with the EU.

Is one IOSS number enough for all EU countries?

Yes. One IOSS registration covers sales to consumers in all 27 member states.

Does IOSS remove customs duties?

IOSS deals with VAT, not customs duties. The EU has agreed to end the customs duty exemption for parcels under €150, so check the current rules before you set your prices.

What happens if I stop complying?

Repeated failures to file or pay can lead to exclusion from IOSS, after which you cannot use the scheme again for a period of time.

How we can help

Whether IOSS or a customer-as-importer model fits your business depends on your products, price points and markets. Our OSS and IOSS consulting covers the choice, the registration and the reporting setup. For cross-border dropshipping where you want to stop charging VAT at checkout, see the VAT Fix.

Not sure which model fits? Start the free VAT assessment.

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