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
Without an export declaration the goods cannot leave the EU legally, and the seller may lack proof of export for a VAT-free sale.
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.
Sale terms: EXW Milano (Incoterms 2020). Goods leave the EU. Buyer has no EORI number.
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.
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.
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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.