EXW or FCA: who should lodge the EX1 export declaration

21 October 2026

Under Incoterms 2020, export clearance under EXW falls to the buyer, while under FCA it falls to the seller. Here is how that difference plays out for the EX1 export declaration, and what to check in the contract in advance.

In short

Under Incoterms 2020, on EXW terms export clearance is the buyer’s responsibility; on FCA terms it is the seller’s — that is, yours, as the EU supplier.

In practice, many suppliers selling on EXW do not lodge the export declaration themselves and are not registered as an exporter for it, which leaves the task to the Russian buyer.

Knowing in advance which delivery term is in the contract avoids the lot sitting at a warehouse because the declaration has not been lodged.

The difference between EXW and FCA

EXW (Ex Works) sets the seller’s obligations at the minimum: the goods are simply made available at the seller’s premises, and export clearance is the buyer’s task.

FCA (Free Carrier) requires the seller to hand the goods to the carrier already cleared for export: the seller is the one who lodges the declaration and is named as the exporter.

The difference looks small on paper, but it decides who actually files the declaration with customs in the country of dispatch and whose details appear on it as the exporter.

Both terms are equally common in contracts with European suppliers, and neither is inherently better — what matters is agreeing in advance which side takes on export clearance, rather than finding out after the goods have shipped.

Why this matters for the EX1 in practice

A buyer in Russia usually cannot be named as the exporter on an EU declaration — that requires an EU resident registration, which the supplier typically does not offer to share.

On EXW terms, it is worth checking early whether you, the supplier, are willing to lodge the EX1 yourself, or whether the buyer should hand it straight to a customs agent in your country — the same amount of work either way, but without the lot sitting idle at the warehouse while the question is settled.

On FCA terms, export clearance is normally already your obligation as the seller, and the declaration is lodged before the goods are handed to the carrier — more predictable for the buyer and a lower risk of delay.

For a consolidated lot made up of several suppliers, the delivery terms often differ supplier to supplier: some may sell on EXW, others on FCA, and then declarations have to be lodged separately for each lot rather than once for the whole consolidated shipment.

Sanctions screening comes first

We only handle goods that are not subject to EU, UK, Swiss or US sanctions. Before we quote, we check the HS code of every item and screen all parties to the deal; if a product or a party is restricted, we decline the order, whatever the route or the price.

How Tranzit3 helps

We lodge the [EX1](/usluga/ex1) remotely through a customs agent in the country of dispatch, from €450 — whether or not the supplier is willing to handle it themselves.

If the lot moves through our Rotterdam warehouse, the declaration is lodged together with the shipment for €150, and for a consolidated lot we keep the paperwork separate per supplier even when their delivery terms differ.

Before you agree EXW or FCA terms with a Russian buyer, we can advise how to word the delivery terms so the EX1 is not a surprise later — send us a request, or see our [guide to logistics within the EU](/usluga/logistika-po-evrosoyuzu).

Questions and answers

Which Incoterm makes export clearance the supplier’s job?

FCA — the seller must clear the goods for export before handing them to the carrier. Under EXW, that task falls to the buyer.

Can a Russian buyer be named as the exporter on the EX1?

Usually not — EU export declarations require an EU resident registration, so either the supplier or a customs agent in the country of dispatch has to be named.

What does remote EX1 lodging cost if there is no supplier willing to do it?

From €450 through a customs agent in the country of dispatch; €150 if the lot travels through our Rotterdam warehouse together with our shipment.

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