The European Commission has recently amended the definition of “exporter” for EU purposes. The new definition allows greater flexibility, although still postulates that non-EU established companies may not act as an EU exporter.
Article 1(19) of the UCC DA now requires a company that wants to act as an “exporter,” to be a person established in the EU customs territory and:
- Has the power to determine that the goods are to be brought outside the customs territory of the Union
or
- Is a party to the contract under which goods are to be taken out of that customs territory
In summary, the EU supply chains should be reviewed re: whom is acting as an exporter, as well as how the new rule may simplify such actions.
EY’s Global Tax Alert provides additional details for this important change:
Strategizing Multinational Tax Risks 
Comments on: "EU exporter: New definition" (2)
Hi Keith, I was wondering if it would be possible to regularly reprint your articles, particularly as they might relate to emerging & frontier markets in the web site for the Emerging & Frontier Markets Assoc. https://www.emerging-frontiermarkets.org/ We have a large audience that I am sure would be interested in your articles and have done conferences together with Baker McKenzie, PWC and Deloitte.
Thanks for your interest; this is fine accompanied by a reference to my blog as the initial source. Your site is an excellent resource.