For Incoterms DDP DAP ecommerce: which term for EU sales?, choose the term that matches who can genuinely act as importer, make or arrange customs declarations, and bear duty and import VAT. DDP can support a duties-paid customer offer if you control the import set-up; DAP leaves import charges with the recipient; EXW rarely suits direct ecommerce delivery.
Key takeaways
- DDP, DAP and EXW allocate contractual costs, risks and transport formalities; they do not replace customs, VAT or product-compliance rules.
- Under DDP, the seller promises delivery with import duties and taxes paid, which requires an import arrangement that works in the relevant country.
- Under DAP, the recipient normally handles, or bears the cost of, import formalities, duty and import VAT on arrival.
- EXW transfers transport organisation to the buyer at a very early stage and is rarely appropriate where an ecommerce seller arranges international delivery.
- Before shipping, identify the importer, tariff code, customs value, VAT treatment and product requirements that apply to the goods.
Who needs to consider DDP, DAP and EXW in ecommerce?
Any seller moving goods across a border needs to consider the Incoterm, including sellers using Amazon, Shopify, eBay or Etsy. The selected term must reflect the actual flow, not simply the delivery promise shown to the customer.
Incoterms are commercial rules published by the International Chamber of Commerce. They determine matters including the agreed delivery point, when risk transfers and how certain costs and transport formalities are allocated. They do not, by themselves, decide who is the importer under customs law, who may recover import VAT, or which tax registrations are required.
You are directly concerned if you ship:
- parcels from China, the United States, Türkiye or another non-EU country to consumers in the European Union;
- pallets from Shenzhen to an Amazon FBA warehouse in Germany, France or Italy;
- stock from Great Britain to the EU, or in the other direction;
- EU-made products to a customer outside the EU where the sales contract includes transport arrangements.
The EU customs framework is based on the Union Customs Code, Regulation (EU) No 952/2013. In practice, customs authorities and the declarant will examine the transaction data, documents and each party's role, regardless of whether the invoice says “DDP” or “DAP”.
Example: a US brand sells lamps to consumers in France. It advertises “taxes included”, but the carrier asks the customer to pay duty and VAT before delivery. The commercial promise and the import arrangement do not match. The parcel may be refused, returned or held until payment is made.
For a first shipment, or a model combining import, storage and distance sales, use an EU Market Entry Compliance Assessment to map the checks needed for customs, VAT, product safety, packaging and country-specific obligations.
What do DDP, DAP and EXW mean in practice?
DDP, DAP and EXW offer different levels of customer service and place different operational burdens on the seller. Always state the rule with a precisely named place, for example: “DAP, customer address, Lyon, Incoterms® 2020”.
| Incoterm | Delivery and import position | Common ecommerce use |
|---|---|---|
| DDP | The seller arranges transport, export and import, and in principle bears import duty and taxes. | Consumer delivery without a payment request on arrival, where the import structure is controlled. |
| DAP | The seller delivers at the agreed place before unloading; the recipient usually handles import and amounts due. | Possible for informed business buyers; risky for B2C where charges are not transparent. |
| EXW | The seller makes goods available at its premises; the buyer arranges most transport and formalities. | Better suited to B2B where the buyer genuinely controls collection. |
DDP: a strong promise, not a shortcut
Under DDP, meaning “Delivered Duty Paid”, the seller takes on the greatest set of logistics obligations under the Incoterm. For B2C sales, this can prevent a customer receiving an unexpected payment link from the carrier. However, DDP does not mean that any overseas seller can import into any Member State without preparation.
You still need to establish who acts as importer, who submits or arranges the customs declaration, which EORI number is needed, how import VAT is handled and whether a local VAT registration is required. The European Commission explains the role of an EORI number in customs operations.
DAP: simple on paper, sensitive for customer experience
Under DAP, meaning “Delivered At Place”, the seller brings the goods to the agreed destination ready for unloading. Import is normally the buyer's responsibility. For a consumer, that can mean being asked to pay VAT, duty and carrier presentation charges before the parcel is released.
This is not prohibited in itself. However, you should present possible charges clearly and check consumer, VAT and marketplace rules. A customer who refuses to pay can create return, storage or abandonment costs.
EXW: rarely the right choice for direct delivery
EXW, meaning “Ex Works”, means you make goods available at your premises or another named place. The buyer takes responsibility for loading, transport, export and import unless the parties agree otherwise.
A common mistake is to show EXW while you book the transport, hand the parcel to the carrier and manage export documents. The contract then no longer describes the real transaction. For consumer sales, EXW is generally neither clear nor workable.
When should you choose DDP, DAP or EXW for your EU sales flow?
Choose the Incoterm after defining the dispatch country, import country, storage location and recipient's role. The right term may differ between B2C parcels and stock replenishment shipments.
B2C parcels from outside the EU
If you ship directly from a non-EU country to an EU consumer, DDP may fit a “taxes included” offer, provided your carrier and VAT arrangement can actually deliver it. For low-value consignments, IOSS may be relevant in some circumstances; it does not replace analysis of the import transaction or the conditions of your sale. The Commission explains the OSS and IOSS schemes.
DAP can work where the customer explicitly accepts responsibility for charges due on arrival. In practice, it increases the risk of surprise, refusal and support requests. Make the position clear before checkout, and ensure your website and carrier communications say the same thing.
Pallets to an Amazon FBA warehouse in the EU
Imagine a Chinese manufacturer sending 2,000 units to an Amazon warehouse in Germany. Amazon is not automatically your importer simply because its FBA centre is the delivery address. You need to determine, with your freight forwarder and tax adviser where appropriate, who legally imports, who holds the EORI number, who bears import VAT and which obligations arise in the storage country.
DDP should only be considered here if you control the import process end to end. DAP may shift import responsibility to the recipient, but only if that recipient actually agrees to the role and can perform it. Read the EU stock import guide for ecommerce sellers before dispatching pallets.
B2B sales where the buyer imports
DAP or EXW can be appropriate where your business buyer understands transport and formally accepts the importer role. EXW is more coherent where the buyer genuinely arranges collection from your site. If you load the vehicle, arrange the main carriage or routinely complete export formalities, another Incoterm may better reflect the transaction.
EU Seller Kit — Before setting a delivered price or confirming a DDP shipment, use the HS classification assistant, customs cost simulator and EU VAT calculator to check the inputs behind your decision.
How do you set up a DDP or DAP flow step by step?
A reliable flow starts with customs and VAT data, then carries through into the contract, commercial invoice and carrier instructions. Do not choose the Incoterm at the end: it determines the promise made to your customer and the responsibilities you must organise.
1. Map the actual route and assign roles
Record the dispatch country, EU entry country, final destination, any storage location and the recipient. Then identify the seller, exporter, importer, customs declarant, carrier and, where relevant, indirect representative.
An EORI number is generally required for the operator carrying out customs formalities in the EU. You can use the EORI file preparation service to prepare an application file; the number itself is issued by the competent customs authority, and the service is a one-off preparation service unless included in a SaaS plan quota.
2. Classify the product and establish customs value
The HS code or tariff classification determines tariff measures, potential restrictions and applicable duty. Do not automatically reuse a supplier's code or one used on an old declaration. Check the classification in TARIC, the EU tariff database, and keep a record of your reasoning.
Customs value is not always limited to the unit price displayed in your shop. It depends on the applicable rules and transaction elements, including transaction value where the conditions are met. Use the guide to EU import commercial invoice requirements to prepare the information customs needs.
3. Check duty, VAT and reporting arrangements
Duty depends in particular on classification, origin and value. VAT depends on the country, sales model, import location and your status. VAT rules are harmonised by Council Directive 2006/112/EC, but their practical application often requires a country-by-country review.
DDP does not create a VAT number or an automatic right to deduct import VAT. If you store goods in a Member State, sell locally or use a marketplace, check your position with the relevant authority or a suitably qualified adviser.
4. Write the Incoterm unambiguously
State the rule, named place and version: “DDP, named warehouse, Hamburg, Incoterms® 2020” or “DAP, customer address, Madrid, Incoterms® 2020”. Set out separately in your terms of sale what the price includes, any delivery charges and how returns are handled.
5. Give the carrier consistent instructions
Your carrier needs data that matches the contract: shipper, recipient, importer where required, product code, description, value, origin, documents and instructions for billing duty and taxes. A vague DDP instruction can result in the carrier billing the recipient or suspending customs clearance.
Checklist before an ecommerce shipment to the EU
- I have identified the EU entry country, destination country and any storage location.
- I have named the importer and checked that it can take that role in the chosen arrangement.
- I have checked whether an EORI is needed and validated the number used through the official EORI validation tool.
- I have confirmed the tariff code, origin and customs value for each product reference.
- I have estimated duty, import VAT and logistics charges before setting a DDP price.
- I have selected DDP, DAP or EXW with a named place and Incoterms version.
- I have checked the commercial invoice, packing list and data sent to the carrier.
- I have checked the applicable product safety, labelling and representation requirements.
Which documents and data do you need to prepare?
Documents prove what you are shipping, its value, origin and compliance status. An incomplete invoice or vague description can delay clearance even where the Incoterm is correctly selected.
For a standard import, prepare at least:
- a commercial invoice describing the goods precisely, with quantities, currency, value, Incoterm and named place;
- a packing list matching the parcels actually handed to the carrier;
- tariff classification, origin and valuation data needed for the customs declaration;
- the relevant operator's EORI number where required;
- product-specific authorisations, certificates or declarations where legislation requires them.
A description such as “accessories” or “samples” is not enough if it does not identify the product. Use wording such as “USB-C 20 W mains charger” or “plastic children's puzzle”, then check the relevant sector rules.
For consumer goods, customs clearance is only one stage. Regulation (EU) 2023/988 on general product safety imposes obligations on economic operators and regulates distance sales. For CE-marked products, the manufacturer remains responsible for conformity assessment, technical documentation, required testing and the EU declaration of conformity; the practical CE marking guide helps distinguish these steps.
If you are a non-EU manufacturer of CE-marked products and a mandate is appropriate under the applicable legislation, a CE authorised representative may act only after acceptance, entity assignment, a signed mandate and active payment. That representation never replaces the manufacturer's testing, technical file, conformity assessment or EU declaration of conformity.
What effort and operational cost should you expect?
DDP concentrates more work with the seller; DAP often shifts it to the customer or recipient. EXW reduces your contractual transport obligations, but can create friction if you continue to control the shipment in practice.
When comparing options, do not look only at freight charges. Include:
- customs duty and import VAT;
- declaration, presentation, storage or document-correction charges;
- returns and refused parcels;
- VAT registrations or reporting that may be required;
- time spent on classification, documents and invoice reconciliation;
- product, packaging, WEEE or battery obligations relevant to your catalogue.
An underestimated DDP price can erode margin on every order. Conversely, a poorly explained DAP offer can reduce conversion and create disputes. Calculate landed cost by product reference, country and delivery method; the customs cost simulator structures known import costs and calculates duty only where a valid tariff rate is available.
To review SaaS plans and optional services without displaying a price in your commercial terms, see EU Seller Kit pricing and plans.
Which mistakes and special cases should you check?
The main mistake is treating an Incoterm as a complete compliance solution. It structures a sale and transport arrangement; it does not regularise VAT, import status or product compliance.
Confusing the recipient, importer and buyer
The parcel recipient, invoice buyer and importer can be different people or entities. In an FBA shipment, a warehouse address does not make the marketplace the importer. Document roles before dispatch and obtain written confirmation from your customs intermediary on the proposed arrangement.
Assuming DDP removes EORI or VAT requirements
DDP means the seller bears import duty and taxes under the commercial rule. It does not remove EORI, declaration-data, VAT or national requirements. Where your flows involve several countries, the EORI registration by EU country guide helps you identify the questions to assess for the relevant state.
Forgetting product obligations after customs clearance
A cleared product is not automatically permitted to be placed on the market. Market-surveillance authorities may request information, require corrective measures or restrict a non-compliant product under Regulation (EU) 2019/1020 on market surveillance and product compliance.
For consumer products sold by a non-EU operator, check whether an EU-established responsible economic operator is required under the GPSR. The GPSR Responsible Person service becomes active only after product review, entity assignment, a signed mandate and active payment; a SaaS subscription does not automatically appoint a responsible person.
Great Britain and Northern Ireland
Great Britain is outside the EU customs union. A France-to-England or China-to-England flow therefore follows different rules from an intra-EU movement, and a GB EORI may be required through HMRC. Check the UK EORI service and GOV.UK guidance on getting an EORI number before shipping.
Regulated products and packaging
Toys, cosmetics, electrical equipment, radio equipment and textiles have sector-specific rules in addition to the customs flow. For example, radio equipment is covered in particular by Directive 2014/53/EU on radio equipment. Packaging can also trigger extended producer responsibility obligations by country; an Incoterm does not remove them.
Before publishing a marketplace listing, use the Marketplace Product Compliance Scanner to flag traceability, safety and compliance information to check. It helps review a listing; it does not replace regulatory analysis of your product.
Tools and services to take action
- EU Market Entry Compliance Assessment — use it before your first shipment or entry into a new country to build a checklist of customs, VAT, GPSR, CE and packaging points to assess.
- EORI file preparation — use this service when you need to apply for an EORI number; it prepares the file, while the customs authority issues the number.
- HS classification assistant — use it to generate candidate HS subheadings, then confirm the classification in the CN or TARIC before costing a DDP offer.
- EU VAT calculator — use it to compare common domestic, intra-EU and import VAT scenarios using your transaction data.
- Country Compliance — use it before selling or storing goods in a specific country to organise customs, tax and product checks for that market.
Frequently asked questions
Does DDP mean the customer will never pay anything on delivery?
DDP is intended to deliver goods with import duty and taxes borne by the seller. The result still depends on correct customs instructions and a workable VAT arrangement. If data is incomplete or the carrier cannot charge the seller, the parcel may be held or charges may be requested from the customer.
Can I use DAP to sell to consumers in France?
DAP can be used contractually, but the consumer must be able to understand that they may need to complete or fund import on arrival. In practice, unexpected payment requests increase the risk of refusal. Also check applicable consumer-protection rules and transparency requirements for your sales channel.
Can Amazon be the importer for my FBA stock?
Do not assume that it can. The address of an Amazon warehouse does not automatically make Amazon the importer. Confirm each party's role with Amazon, your carrier or customs representative before sending pallets.
Is EXW suitable for a Shopify or Etsy sale?
EXW is rarely suitable for a direct consumer sale because the customer would need to arrange collection and formalities from the seller's premises. It is more coherent in a B2B relationship where the buyer genuinely controls transport. If you arrange shipment yourself, use a rule that reflects that arrangement.
Does an Incoterm replace an EORI number?
No. An Incoterm is a contractual delivery rule, while an EORI number identifies certain operators in EU customs formalities. Check whether an EORI is required based on your role in the transaction and the competent country.
Does DDP deal with GPSR compliance or CE marking?
No. DDP does not address general product safety, labelling, CE marking or technical documentation. Those duties depend on the product, its manufacturer and how it is made available on the European market.
Official sources
- Regulation (EU) No 952/2013 — Union Customs Code — the customs framework for EU imports and exports.
- European Commission — Economic Operators Registration and Identification (EORI) — the role of EORI identification for operators completing customs formalities.
- European Commission — TARIC consultation — EU tariff measures by goods classification.
- Council Directive 2006/112/EC — common system of VAT — the EU VAT framework relevant to commercial transactions.
- European Commission — VAT One Stop Shop (OSS / IOSS) — information on VAT one-stop-shop schemes for certain distance sales and imports.
- Regulation (EU) 2023/988 — General Product Safety Regulation — product-safety obligations and distance-sales requirements.
- Regulation (EU) 2019/1020 — market surveillance and compliance of products — market-surveillance powers and product-compliance requirements.
- GOV.UK — Get an EORI number — applying for an EORI number for UK customs operations.
This content provides general information and is not legal, tax or customs advice.