Selling goods outside the EU from an Estonian OÜ: EORI, customs, Intrastat
Ship a pallet to New York and the rules are nothing like shipping the same pallet to Munich. The moment a sale leaves the EU, you’re outside the single market’s customs and VAT territory, and three different things start to matter: an EORI number, a customs export declaration, and — for most sellers — nothing else, because Intrastat does not apply. That last point is the confusion baked into the title of this article: EORI and customs cover exports outside the EU; Intrastat covers movements inside it. Mixing the three up is the single most common mistake founders make when they start selling outside the EU from an Estonian OÜ.
The short answer
An EORI number is free, applied for through e-MTA, usually issued in 1–3 business days, and valid across the whole EU. You only need one if you move physical goods across the EU customs border.
Exports are zero-rated for VAT, but only against proof of exit — the confirmed export declaration’s MRN. No proof, no zero rate.
Intrastat only covers trade between EU countries. If you sell exclusively to the US, UK, Switzerland or anywhere in Asia, you never file it.
If you also sell inside the EU, the 2026 Intrastat dispatch threshold is €325,000, filed monthly with Statistics Estonia by the 14th; arrivals reporting was abolished from 1 January 2025.
The US ended its $800 de minimis exemption on 29 August 2025 for every country. Every parcel into the US now needs a formal customs entry.
Incoterms decide who pays foreign import VAT and duty: DDP means the OÜ does, DAP pushes that cost and hassle onto the buyer.
What actually changes when you ship outside the EU rather than inside it
Selling outside the EU turns an ordinary invoice into an export, and that swaps out almost the entire compliance stack behind it. Inside the EU, goods move under the single market’s VAT and customs union: no border checks, VAT handled through the reverse charge, OSS, or your normal domestic invoice, and the details of running that side of the business are covered in selling in the EU from Estonia. Outside the EU, the shipment crosses a real customs border, needs a declaration, and the VAT treatment flips to zero-rated-with-proof instead of taxed-at-destination. Many Estonian OÜs run both models at once — EU customers under one set of rules, non-EU customers under another — and the table below lines the two up side by side so you can see exactly where they diverge.
Selling inside the EU | Selling outside the EU | |
|---|---|---|
What the shipment is | An intra-EU supply of goods | An export |
Customs border | None — free circulation | Yes — export declaration required |
Do you need an EORI number | No | Yes |
VAT treatment | Reverse charge (B2B), or OSS/local VAT for consumer sales | 0%, against proof of exit (MRN) |
Statistical reporting | Intrastat, above the dispatch threshold | None — customs data covers it |
Typical destinations | Germany, France, Poland, Lithuania | US, UK, Switzerland, Japan, UAE |
Do you need an EORI number, and how do you get one
You need an EORI number only if you physically move goods across the EU’s external customs border — a pure services business never needs one. If your Estonian OÜ sells software, consulting, or agency work, skip this entire section; there is nothing to register. If you export or import physical goods, EORI registration is your first practical step, and it’s simpler than founders expect.
Apply through e-MTA (EMTA’s e-services portal), under customs rights and obligations.
It’s free of charge — there is no state fee for the number itself.
Issuance typically takes 1–3 business days.
One EORI number is valid across the entire EU — you register once, not per country.
How an export declaration works, and why most small sellers let someone else file it
An export declaration is the electronic form that tells EMTA what’s leaving the EU, its value, and its destination, and it’s filed through Estonia’s Complex declaration environment inside e-MTA. A clean, correctly coded declaration clears in hours, not days — the delays people complain about almost always come from wrong HS codes or missing invoice detail, not from the system itself. Most small exporters never touch the declaration form directly: the courier (DHL, FedEx, UPS) or a customs broker files it as your direct representative, for a modest fee baked into the shipping cost. That’s normal and cheap, but it doesn’t change who’s legally responsible — your OÜ remains the exporter of record, and it’s your business that answers for errors, not the courier’s. Keep a copy of every declaration and its MRN in your own records rather than relying on the courier’s portal, since you’re the one who needs to produce it if EMTA ever asks.
VAT on exports: 0%, but only against proof you actually left the EU
Goods you export outside the EU are zero-rated for Estonian VAT, but that 0% is conditional, not automatic. The condition is proof of exit — the confirmed export declaration carrying an MRN (movement reference number) that shows customs actually released the goods and they left the EU. Without that document on file, an EMTA audit will treat the sale as a normal taxable supply and assess VAT retroactively, which is the single most common way exporters get caught out. The sale still appears on your KMD VAT return as a 0% supply — it isn’t invisible, it’s just taxed at zero, and it needs paperwork behind it exactly like any other line. For the wider mechanics of getting VAT right after incorporation, see how to handle VAT after you incorporate in Estonia.
Does Intrastat apply to you?
Here’s the correction this whole article is built around: Intrastat is a statistical survey of goods moving between EU member states, and nothing else. Goods leaving the EU are already captured by the export declaration you just filed with EMTA — a second, statistical filing for the same shipment would be redundant, and the system doesn’t ask for one. If your Estonian OÜ ships exclusively to the US, UK, Switzerland, or anywhere in Asia, you will never file an Intrastat return, no matter how large your export volumes get.
Where Intrastat does bite is the common case: a company that sells inside the EU as well as outside it. For 2026, the Estonian dispatch threshold is €325,000 (down from €350,000), filed with Statistics Estonia — not EMTA — on a monthly basis, by the 14th calendar day of the month following the reference month. Arrivals reporting was abolished from 1 January 2025, so if you’re still budgeting time for an arrivals return, stop — only the dispatch flow is reported now, and your incoming-goods data is reconstructed from other member states’ own dispatch filings. If your EU-side sales sit below €325,000 a year, you’re under the threshold and file nothing at all.
If every parcel you ship leaves the EU, Intrastat isn’t a form you’re missing. It’s a form that was never yours to file.
Shipping to the UK after Brexit — a third country like any other
A shipment to London follows exactly the same rules as a shipment to Tokyo, because Brexit moved the UK outside the EU’s customs and VAT territory entirely. That means you need an EORI number for UK-bound goods, you file a full export declaration, and the sale is zero-rated against proof of exit — the same three requirements as any other non-EU destination. UK import VAT and any duty become the buyer’s or your problem depending on the Incoterm you agreed, covered in the next section. Don’t treat the UK as a special or lighter case just because it was an EU member a few years ago; for customs purposes, it isn’t anymore.
Shipping to the US in 2026 after de minimis ended
The US ended its $800 de minimis exemption on 29 August 2025, and this is the single change that hits small Estonian e-commerce sellers hardest. Before that date, low-value parcels under $800 could enter the US duty-free with minimal paperwork; China and Hong Kong lost that treatment even earlier, on 2 May 2025. Since 29 August 2025, every parcel into the US, from every country, needs a formal customs entry and is exposed to whatever tariffs apply to its HS code, regardless of value. A temporary flat postal duty (roughly $80–$200 per package) covered the gap until 28 February 2026, and a new postal entry process for shipments up to $800 is being phased in during 2026. Treat that detail as moving: check CBP’s current process before you quote US shipping costs or promise delivery timelines, because the mechanics have already changed twice in a year.
Incoterms: DDP vs DAP, and who ends up owing foreign import VAT
The Incoterm on your commercial invoice decides who deals with import VAT and duty at the other end, and getting it wrong is how sellers end up eating costs they never priced in. DDP (Delivered Duty Paid) means your OÜ arranges and pays the destination country’s import VAT and duty before the buyer ever sees a bill. DAP (Delivered at Place) delivers the goods but leaves customs clearance, duty, and import VAT to the buyer, who often gets an unwelcome surprise invoice from the courier.
Incoterm | Who clears customs at destination | Who pays foreign import VAT and duty | Best for |
|---|---|---|---|
DDP | Seller (you), via a broker or courier | You | Predictable checkout pricing, B2C, marketplaces |
DAP | Buyer | Buyer | B2B, experienced importers, high-value or bespoke goods |
DDP costs more upfront and requires you to register for VAT or use a broker in some destination countries, but it protects the buying experience — nobody likes a surprise customs bill on their doorstep. DAP is simpler for you and works well when your buyer is a business used to handling its own imports. Whichever you choose, state it explicitly on the commercial invoice; couriers default to whatever their standard service is, and that isn’t always the one you meant.
HS codes, commercial invoices, packing lists, and origin
Every export needs a correct HS (Harmonised System) code, because it determines the duty rate, whether the item needs a licence, and how fast customs clears it — a wrong code is the most common cause of a stuck shipment. Alongside it you need a commercial invoice (value, currency, Incoterm, HS code, buyer and seller detail) and a packing list (weights, dimensions, contents per box). For goods with EU origin, you can often claim preferential duty rates under an EU free-trade agreement with the destination country, but only with correct proof of origin on file — check the specific agreement, since coverage varies by product and country. If what you’re shipping falls into a regulated category — alcohol, tobacco, or certain chemicals — a licence or MTR/Tarvik registration may sit on top of the export paperwork; see Estonia’s business licences and MTR registration for what that adds. None of this paperwork is optional once goods are moving, but none of it is hard either — get the HS code and origin right once per product line, and every future shipment reuses the same answer.
Returns and re-imports
A returned item coming back from outside the EU is technically an import, and without the right paperwork you can end up paying import VAT and duty on goods you already own and already paid Estonian VAT on once. Returned goods relief exists precisely for this: keep your original export declaration and be ready to show the goods are the same ones that left, unaltered, within the relief period your destination customs authority sets. Build a returns process before your first international sale rather than after the first expensive surprise — a labelled RMA number and a copy of the original export paperwork travelling with the parcel solves most of it.
IOSS is not this
IOSS (Import One Stop Shop) is worth naming only to rule it out: it’s a simplified VAT scheme for low-value consignments (≤€150) coming into the EU from outside, not for goods leaving the EU. An Estonian OÜ exporting to the US, UK, or Asia has no use for IOSS at all. It becomes relevant only in the opposite scenario — a non-EU seller shipping small parcels into the EU — which is a different business model from the one this article covers.
What a small Estonian OÜ should actually set up, in order
Confirm you’re actually exporting goods, not services — services never need EORI, customs, or Intrastat.
Register for an EORI number through e-MTA before your first non-EU shipment; it’s free and takes days, not weeks.
Agree your Incoterm (DDP or DAP) with each courier or buyer and put it on the commercial invoice.
Set up HS codes for your product range once, so every shipment reuses the correct classification.
Decide who files the export declaration — your courier, a broker, or you — and confirm they’ll return the MRN to you.
File every export’s MRN alongside the invoice so your KMD 0% supply is backed by proof of exit.
Track EU-side sales separately from non-EU sales so you know if you’re approaching the €325,000 Intrastat dispatch threshold.
Watch CBP’s current process if the US is a meaningful market — the rules have moved twice in the past year and will likely move again.
Frequently asked questions
Do I need an EORI number if I only sell services outside the EU?
No. EORI only applies to companies that move physical goods across the EU’s external customs border. A SaaS, consulting, or agency business selling to non-EU clients never needs one, regardless of how much revenue comes from outside the EU.
Is Intrastat the same thing as a customs export declaration?
No, and confusing the two is the most common mistake exporters make. The export declaration is what you file with EMTA to move goods outside the EU. Intrastat is a separate statistical survey that only covers goods moving between EU member states, and it doesn’t apply to non-EU shipments at all.
What is the 2026 Intrastat threshold in Estonia?
The 2026 dispatch threshold is €325,000, reduced from €350,000 in 2025. It applies only to goods sent from Estonia to other EU countries, filed monthly with Statistics Estonia by the 14th. Arrivals reporting was abolished from 1 January 2025.
If I only sell to the US or UK, do I need to file Intrastat at all?
No. Intrastat covers intra-EU trade only. A company shipping exclusively to non-EU destinations like the US, UK, Switzerland, or anywhere in Asia never files Intrastat, no matter its export volume.
How is VAT charged on goods I export outside the EU?
Exports are zero-rated for VAT, but only when you can prove the goods actually left the EU — the confirmed export declaration’s MRN is that proof. The sale still appears on your KMD return as a 0% supply; without the MRN on file, EMTA can assess VAT as if the zero rate never applied.
What changed with US customs rules in 2025 and 2026?
The US ended its $800 de minimis exemption for all countries on 29 August 2025, so every parcel into the US now needs a formal customs entry regardless of value. A temporary flat postal duty applied until 28 February 2026, and a new postal entry process for shipments up to $800 is being introduced during 2026 — check CBP’s current process before quoting US shipping.
Is the UK still treated like an EU country for customs purposes?
No. Brexit moved the UK outside the EU’s customs and VAT territory, so a shipment to the UK needs an EORI number, an export declaration, and zero-rated VAT with proof of exit, exactly like a shipment to any other non-EU country.
Should I ship DDP or DAP?
DDP means your OÜ pays the destination country’s import VAT and duty upfront, which keeps the buyer’s experience simple and is common for B2C and marketplace sales. DAP leaves clearance and import costs to the buyer, which suits B2B sales to buyers used to handling their own imports.
Does IOSS apply to an Estonian OÜ exporting goods outside the EU?
No. IOSS is a simplified VAT scheme for low-value goods imported into the EU from outside, not for goods leaving the EU. It’s irrelevant to an Estonian company exporting to the US, UK, or Asia.
