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Indonesian seller → EU declarant

EU importer of record consultant for Indonesian sellers

Decide who enters your goods into the EU or UK, who holds the EORI and who carries EUDR operator duty.

One customs role, two kinds of weight

The importer of record is the party named on the customs declaration when goods enter the EU.

Customs identity

Owes the customs debt, holds the EORI on the entry, answers to customs.

EUDR operator duty

Whoever first places in-scope goods on the EU market must prove compliance.

EU customs law generally requires the declarant to be established in the EU. A seller in Denpasar cannot declare its own container.

Sell FOB or sell DDP: who carries what

EUDR assigns duties by role, not by contract label. Your Incoterms decide which role lands on you.

Sell FOB or CIF to an EU buyer

Importer of record
Your buyer, under its own EORI
EUDR operator
The buyer, who files the DDS
Your job
Supply the geolocation, legality and origin data

Sell DDP into the EU

Importer of record
You, via a jointly liable indirect customs representative
EUDR operator
Usually you
Your exposure
Penalties up to 4% of EU turnover, plus confiscation

An operator may mandate an authorised representative to submit the DDS, but responsibility does not transfer with the login.

What sits behind a Due Diligence Statement

The operator files the DDS in TRACES NT before goods are placed on the market. It rests on these.

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01

HS code and origin

The tariff line and the country where the commodity was produced.

02

The filer's EORI

The EORI of the party placing the goods on the market.

03

Plot geolocation

A polygon for plots over 4 ha, a single point for smaller ones.

04

Forest-cover check

Coordinates tested against forest cover as of 31 December 2020.

05

Farmer and tenure records

Farmer identity, national ID and land tenure documents.

06

Risk assessment

A shipment-level review of legality and deforestation risk.

Four structures, matched to your sales terms

Each fits a different volume and appetite for EU-side duty.

  • EXW, FOB or CIF sale

    Your buyer imports and acts as operator. You deliver the data pack.

  • DDP via indirect representative

    You import through a jointly liable EU representative and usually become operator.

  • Own EU subsidiary

    Your EU entity imports and files. Fits when volume justifies it.

  • UK entry

    The GB EORI holder imports. UK forest-risk rules still pending as of mid-2026.

As of Q1 2026, only 18-22% of independent smallholder hectares had verified geolocation in mill supply chains. The data burden is real.

Consultation fees

Quote-based. Indicative figures dated July 2026, subject to change. Commodity, plot count, volume and member state move the quote.

IoR structure consultation 90 minutes, memo within 5 working days IDR 4.5-7.5 million
Structure mapping and partner referral 2-3 weeks IDR 15-35 million
DDS-readiness dossier support 4-8 weeks per commodity IDR 25-60 million

The consultation memo maps operator, trader and IoR roles for one product line. Vetted licensed EU partners execute the structure.

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From trade profile to structure

  1. 01

    Trade profile

    Commodity, HS code, Incoterms and target member state.

  2. 02

    Scoped quote

    A fixed quote and consultation slot within 2 working days.

  3. 03

    90-minute consultation

    Operator, trader and DDS roles mapped against your contracts.

  4. 04

    Structure memo

    The recommended structure, its risks and who can execute it.

  5. 05

    Execution by partners

    Indirect or fiscal representative, or incorporation agent, carry the regulated work.

Importer of record questions

All 100 answers

Book a structure consultation

Send your commodity, HS code, Incoterms and target member state. You get a fixed quote and a slot within 2 working days.

Compliance information, not legal advice. Structures are executed by vetted licensed EU partners; no one can guarantee a customs or EUDR outcome.