Importing from China to Estonia: the setup that actually works

If you run an Estonian company that buys goods in China, six things need to be right: the EORI, import VAT, IOSS, OSS, classification, and who acts as importer of record. None is complicated alone. The order matters, and one has a timing trap that catches every new company.

Start with the EORI, because everything hangs off it

An EORI number is mandatory for any company that imports or exports. In Estonia the Tax and Customs Board issues it and it is valid across the EU, so you obtain it once. Your forwarder, customs agent and the carrier filing the entry summary declaration all need it. Get it before your first purchase order, not when the container is at Muuga.

Import VAT, and the 12-month rule that blocks new companies

Estonian VAT is 24% and payable on imports at the border. For a regular importer that is a substantial amount of cash tied up between paying customs and reclaiming the VAT on the next return.

The fix is import VAT deferment under section 38(2-1) of the Estonian VAT Act. Import VAT is then not paid at the customs office: it is declared in box 4-1 of the VAT return and deducted as input VAT in the same return, so the net cash effect is zero. You apply through the LUBA system in e-MTA, the decision comes within 30 days, and for goods the authorisation is indefinite.

There are three conditions and all must be met: registered for VAT for at least the preceding 12 consecutive months, no late VAT returns in those 12 months, and no tax arrears in those 12 months.

That second option is worth knowing. Goods under customs warehousing or temporary admission do not trigger import VAT until released for free circulation, which for a young company with a large first shipment can decide whether the cash position works.

IOSS and OSS: two different problems

IOSS is for goods coming into the EU. It is optional, covers distance sales of imported goods in consignments of EUR 150 or less intrinsic value, and lets you charge destination-country VAT at checkout and declare it monthly in one Member State. The import is then VAT-exempt under Article 143(1)(ca) of the VAT Directive. Without IOSS the fallback is the special arrangements in Articles 369y to 369zb: the postal or express operator collects VAT from the recipient and remits it monthly at the destination rate.

Two changes apply from 1 July 2028 under Council Directive (EU) 2025/1539. The special arrangements are repealed outright. And a new Article 201(2) makes the supplier or deemed supplier liable for import VAT where IOSS is not used, with Article 201(3) requiring a non-EU supplier to appoint a tax representative unless established in the EU or in a mutual-assistance country. IOSS becomes de facto unavoidable, not legally mandatory. The directive does not remove the EUR 150 IOSS ceiling: that was deferred to the customs reform and is not yet confirmed in adopted VAT law.

OSS is a different tool for a different flow: distance sales from stock already in the EU to consumers in other Member States, in a single return instead of registering in each destination country. It does not remove the need for an Estonian VAT number. The registration threshold is EUR 40,000 for established persons and nil for non-established persons.

Classification is now a cost lever, not paperwork

This is the part that changed on 1 July 2026 and that most sellers have not repriced. Within the EUR 150 band the flat duty is charged per tariff line, so the number of distinct commodity codes in a consignment sets your duty. Consolidating SKUs under fewer lines is a legitimate way to reduce it.

Above EUR 150 classification decides the ad valorem rate instead, which is more money on the same decision. For high-volume lines, get binding tariff information so classification is settled in advance rather than argued at the border. Valuation deserves the same care: freight and insurance to the EU frontier must be included, and assists, royalties and related-party pricing have to be defensible.

Anti-dumping duty: check TARIC before every product launch

This is the trap that turns a good margin into a loss overnight, and it is entirely avoidable. Anti-dumping duties are ad valorem and unaffected by the EUR 3 flat duty. Where goods carry one, an H1 declaration is required rather than H7.

The scale is not trivial. Commission Implementing Regulation (EU) 2026/1540, in force from 8 July 2026, imposes duties of 4.3% to 45.3% on passenger car and light truck tyres from China under CN codes 4011 10 00 and 4011 20 10. Investigations opened in 2026 on solid glass microspheres and polyether polyols, and in the polyol case imports were registered early, meaning retroactive duty exposure.

• Check TARIC by commodity code and by origin before every new product launch, not once a year
• Origin is not the shipping country. Goods routed through a third country keep their origin for anti-dumping purposes
• An open investigation is itself a risk, especially where imports are registered, because duty can reach back

ICS2: your job is data quality, not filing

ICS2 has been fully operational in all Member States for all transport modes since 1 September 2025, when ICS1 was decommissioned; Release 3, covering road and rail entry summary declarations, landed on 1 April 2025. Limited derogations granted to some Member States and Northern Ireland are transitional.

In almost all cases a small importer files nothing directly: the carrier submits the entry summary declaration before arrival. Your obligations are practical. Hold a valid EORI and give it to your freight partner, supply accurate six-digit HS codes and plain-language descriptions to your supplier and forwarder, and make sure the commercial invoice matches what is in the box. A final consignee established in the EU can be required to file in certain circumstances.

Vague descriptions are the most common cause of a rejected entry summary declaration and a border hold. Words like gifts, samples and parts are not descriptions. It is the cheapest problem here to fix and the one that most often costs a week.

DDP from China is now materially worse than your own EORI

For years DDP looked easy: the supplier quotes one all-in price and handles customs. Three things now make it a bad structure.

• You lose the classification lever. The shipper's line-splitting decides your EUR 3 multiplier, and they have no incentive to consolidate on your behalf
• You cannot reclaim import VAT when you are not the importer of record, and DDP pricing buries VAT and duty in an opaque all-in rate you cannot separate for the books
• Compliance risk is migrating to whoever sells into the EU regardless, through deemed-importer rules, Product Identifiers from 1 November 2026, and 6% penalties

The defensible structure is the opposite one. Import in bulk on your own EORI into an EU warehouse, clear once with proper valuation and, when you qualify, deferment, and sell from EU stock. That takes the transaction out of the low-value import regime, and out of the coming handling fee with it. Where you must ship direct from China, do it under your own IOSS with your own classification discipline, not DDP. Note also that under the reform deemed importers will need AEO or trusted-trader status, an application that takes months.

You may need none of this

If your company sells services, or buys only from suppliers inside the EU, nothing on this page applies to you. No EORI, no IOSS, no deferment application, no TARIC checks. The customs regime concerns goods crossing the EU border, and a consultancy invoicing a client in Germany is not doing that.

Even for a goods business, not all of it applies at once. A company selling only from Estonian stock to Estonian customers has no use for OSS; one that never ships a parcel below EUR 150 to a consumer has no use for IOSS. Set up what your flow needs and leave the rest until it changes.

Frequently asked questions

TagsEORI number EstoniaIOSS registrationimport VAT defermentDDP vs own EORIanti-dumping duty

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