Not willing to lodge the EX1 yourself? What happens with EXW — and how remote export clearance works

19 September 2026

Many EU suppliers decline to lodge the EX1 export declaration or sell only EXW. Here is why this creates a deadlock for a buyer outside the EU, and the working solution: remote export clearance by a customs agent, with no customs work on your side.

What the EX1 is and why goods cannot leave the EU without it

EX1 is the common name for the export customs declaration lodged in the country of dispatch when goods leave the European Union. Once the documents are checked, the export customs office assigns an MRN (Movement Reference Number), by which the movement is tracked until the goods physically leave EU territory.

The export customs office passes the release data to the office of exit, and the declaration is closed only after exit is confirmed. For you as the seller, this same document is the proof of export that allows VAT zero-rating on the sale, so it is in both parties’ interest that the declaration is closed correctly and on time. If it is not closed, the tax authority may later charge VAT on a sale you treated as an export — one more reason to settle the EX1 question before dispatch, not afterwards.

For the buyer in Russia, the practical point is different: without a correctly opened and closed export declaration the goods cannot lawfully leave your warehouse, however ready the Russian side is.

Why suppliers decline export clearance

Declining to lodge the EX1 is common, especially among smaller manufacturers and distributors that have never handled their own exports: it means extra administration, a separate contract with a customs broker and a responsibility that is easier to pass to the buyer.

A second pattern is selling only EXW (Ex Works), under which Incoterms put export clearance on the buyer. On paper this looks neutral, but for a buyer outside the EU it is a real problem: the buyer is not present at your warehouse and cannot lodge the declaration without a local intermediary. A third, rarer case is a supplier who has already faced delays or VAT reassessments on exports and prefers to pass all responsibility to the buyer with the goods.

EXW or FCA: the underlying cause

The difference between EXW and FCA (Free Carrier) under Incoterms 2020 lies exactly in who handles export clearance. Under EXW the buyer formally takes on the whole export process, including the declaration in the seller’s country; under FCA the seller delivers the goods cleared for export.

The problem with EXW in cross-border deals is well known: a buyer with no registration or presence in the seller’s country cannot act as declarant under local EU customs law — the exporter of record is normally a person established in the country of dispatch. This is why FCA is recommended instead of EXW for international deals between different customs territories. If a supplier insists on EXW and also refuses to handle the export, the parties are stuck; in practice the deadlock is resolved by bringing in an independent customs agent in the country of dispatch.

How the EX1 is lodged remotely without your involvement

We lodge export declarations remotely through customs agents in the country of dispatch — from €450 without transport, so the service does not depend on which route the goods take next. The agent needs a set of documents from you: commercial invoice, packing list and the exporter’s company details — but not your participation in the filing itself.

If the goods go through our Rotterdam warehouse anyway, the services are combined and the EX1 costs €150, because the documents are lodged on site by the specialists who receive and consolidate the consignment. The €300 difference is essentially the difference between a stand-alone remote procedure and clearance built into an existing warehouse process.

In short, you provide the documents and confirm the transaction; the administrative burden that made you decline export clearance moves to our side.

T1 and closing the declaration at the border

A separate case is goods that are not of EU origin, for example previously imported from a third country and resold without release for free circulation in the EU. They travel under a T1 transit document, which accompanies the consignment under customs control from one office to another until it leaves the Union.

T1 is used, in particular, when goods cross several EU countries on the way to the border without customs clearance at an intermediate point. It is closed, like the MRN of an EX1, at the office of exit where customs records the physical departure. T1 cases need more careful preparation and more time, so tell us at the quoting stage whether the goods are of EU origin or were imported from a third country — this determines whether T1 is needed and changes both cost and timing.

Groupage from several suppliers

When goods from several suppliers in different EU countries are consolidated in one warehouse, each seller’s consignment generally needs its own export declaration, even if all pallets then travel in one truck or container. Documents can be combined in one declaration only if all goods formally belong to one consignor or exporter.

That is why our consolidation warehouses in Rotterdam, Warsaw and Vilnius handle the EX1 as a separate service for each incoming consignment. Trying to save by declaring several sellers’ goods on one declaration does not work: if the actual consignor differs from the declaration data, export customs halts release until the matter is resolved, delaying the whole consolidated shipment. Let us know in advance how many separate consignors are involved, so the number of declarations and their cost are clear before dispatch.

Questions and answers

Can the buyer in Russia lodge the EX1 instead of the supplier?

No. The declarant must be a person established in the country of dispatch with an EORI number, so the procedure is always handled by a local agent, not by the buyer directly.

I am willing to provide documents but not to lodge the declaration myself. Is that enough?

Yes, that is exactly what remote EX1 filing is for: we need your invoice, packing list and company details, and the agent handles the filing.

How long does remote EX1 filing take?

It depends on the country of dispatch and the workload of the local customs office. Start preparing the documents before the collection date rather than at the last moment.

Must the EX1 be lodged by the same forwarder that carries the goods to Russia?

Formally they are independent services, but it is cheaper and easier when the customs agent and the carrier work in one chain and synchronise documents directly.

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Keywords
  • EX1 export declaration
  • Export declaration filed by agent
  • EXW vs FCA export clearance
  • MRN export number
  • Proof of export VAT zero rating
  • Export clearance EU to Russia
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