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EXW sale to a buyer who cannot clear export

A seller in Italy sells EXW to a buyer in a non-EU country. The buyer has no EU export presence. Nobody can lodge the export declaration.

Case Studies / Case 4 · Export–Import Assistant

Status: Illustrative scenario — a typical situation with invented details. Last reviewed 8 October 2026.
What’s at stake

Without an export declaration the goods cannot leave the EU legally, and the seller may lack proof of export for a VAT-free sale.

Case 4 · 2 min read · Last reviewed 8 October 2026

Problem

A seller in Italy sells EXW to a buyer in a non-EU country. The buyer has no EU export presence. Nobody can lodge the export declaration.

Input

Sale terms: EXW Milano (Incoterms 2020). Goods leave the EU. Buyer has no EORI number.

What I did

  1. Enter the terms and route in the Export–Import Assistant.
  2. Read the document and responsibility checklist.
  3. Compare the result with the options FCA and DAP.

Result

Reference answer: under EXW the buyer handles export clearance, which is hard without an EU presence. FCA named place makes the seller responsible for export clearance. The sales contract must say which party is the exporter of record.

Where it can go wrong

Incoterms do not decide who is the exporter for customs or VAT purposes. A rule in the contract is not the same as customs law.

Human verification

  • The customs broker confirms who may lodge the declaration.
  • Check VAT exemption evidence for the export.
  • Update the contract and the invoice wording.
Next step

Check your own shipment with the same steps.

Open the Export–Import Assistant →
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Stuck on a similar case?

Send the details (without customer names) to contact@supply.training. Written by a logistics professional with 20+ years on the floor — about the author.

Cases are anonymised and practical. They are not legal, customs, tax or dangerous-goods advice. Verify the current rule and the carrier or authority requirement for every real shipment. Last reviewed: 8 October 2026.