A foreign founder can have a French company, a French branch, or no French subsidiary at all and still face the same practical question at the border: which entity must be identified before the first shipment is cleared? The answer is usually the Economic Operators Registration and Identification number, known as the EORI number. It is a customs identity, not a French VAT number, not a SIREN, not a SIRET and not a Kbis. Using the wrong identifier can leave goods blocked with a carrier, a registered customs representative or a French customs office even when the company is otherwise properly incorporated.

In 2026 the question is more urgent because France is moving from establishment-based EORI numbers linked to the SIRET to the EORI SIREN model. French Customs states that EORI SIREN numbers must be used in European customs applications and that existing EORI SIRET numbers are scheduled to be deactivated during the second half of 2026. A foreign company must also distinguish the rules for an operator established in another European Union Member State from those applicable to an operator established outside the Union. This article gives a decision tree, a filing checklist, the interaction with VAT and customs representation, and the remedies to consider when the EORI is missing, inactive or attached to the wrong legal entity.

I. Does a foreign company need a French EORI number before importing?

A. What does EORI mean, who must register and when is the number required?

EORI means Economic Operators Registration and Identification. It is the unique customs identifier used to identify an economic operator in dealings with customs authorities in the European Union. The starting point is Article 9 of Regulation (EU) No 952/2013 establishing the Union Customs Code. The European Commission explains that an EORI number is mandatory for customs clearance of imports, exports and transit in the Union. The official European explanation is direct: “EORI registration is mandatory prior to carrying out any customs transaction in a Member State.” The practical consequence is that the number must exist before the customs operation, rather than being requested after a parcel or container has already been presented for clearance.

That rule concerns customs operations, not every cross-border sale. A French company buying ordinary services from a United States provider does not need an EORI merely because the invoice is international. A French company selling software to a customer in Germany does not normally create an EORI event either, because the transaction does not involve customs clearance of goods. The analysis changes when goods enter or leave the Union, pass through a customs transit procedure, or are subject to a safety-and-security filing. A shipment from the United Kingdom, the United States, Switzerland, China or another non-EU territory is the classic trigger for a French founder.

The EORI is not interchangeable with other business identifiers:

• SIREN is the nine-digit identification number of the French legal unit. It is allocated through the French business-registration system.
• SIRET is the fourteen-digit identification of a particular establishment: the SIREN followed by five additional digits. The distinction matters when a company has more than one site.
• VAT number identifies the taxpayer for value-added tax. A company may need a French VAT number for import VAT or intra-Community transactions without using that number as its customs identity.
• Kbis is the official extract traditionally used to evidence a commercial company’s registration in the French Commercial and Companies Register. It proves a corporate status; it is not an EORI certificate.
• RNE means Registre national des entreprises, the National Register of Enterprises. The RNE and the EORI serve different administrative functions.

The distinction is important in a shipping instruction. If the carrier asks for “the company tax number,” the foreign founder should not automatically send the French VAT number or the parent company’s local registration number. The person responsible for the import should confirm which entity is the declarant, which entity is the importer or consignee, and which EORI is authorised for the declaration. The answer affects customs debt, import VAT, product restrictions and the evidence available if the declaration is challenged.

For an operator established in France, the French Customs administration currently describes the national format as “FR + SIRET and/or FR + SIREN.” The official Customs page also states that the EORI SIREN must be used in European customs applications, that EORI SIRET numbers remain accepted in some contexts for the time being, and that the EORI SIRET population is expected to be deactivated in the second half of 2026. That transition is a live compliance issue: a number that worked for a previous shipment may fail in a European electronic system if the company has not obtained or activated the EORI SIREN.

The underlying French company identifiers are set out in Article R. 123-221 of the French Commercial Code. The provision distinguishes the nine-digit number of the legal unit from the additional five-digit establishment identifier. The EORI application should therefore be tied to the legal entity and establishment actually used in the customs flow, not to an informal trading name, a founder’s passport or a logistics provider’s account.

A foreign company should also read the French Customs rule together with the official French Customs EORI guidance and Article 9 of the Union Customs Code. That European framework is what allows one valid Union EORI to be recognised across the Union, while the national administration of the Member State of registration remains relevant to the application and the operator’s establishment.

B. Which rule applies to an EU company, a non-EU company, a French subsidiary or a branch?

The correct answer follows the legal establishment of the operator and the place of customs clearance. A foreign founder should work through the following four situations.

1. The operator is established in another EU Member State. The operator registers for EORI in its country of establishment. It does not request a second French EORI merely because its goods are cleared in France. The existing Union EORI can be used for customs operations in France, subject to the accuracy of the legal name, address and customs authorisations. A company already established in Belgium, Germany, Italy, Spain or another Member State should therefore check its existing EORI first instead of creating a duplicate French record.
2. The operator is established in France. A French SAS, SARL, EURL, branch or other entity with the relevant French establishment obtains its French EORI through the French Customs procedure. The legal entity’s SIREN and, depending on the stage of the transition and the electronic application, the SIRET of the establishment must be consistent with the registration data. A newly incorporated French subsidiary cannot safely assume that the issuance of a Kbis automatically activates an EORI.
3. The operator is established outside the EU and clears in France. A United States, Canadian, British, Swiss, Emirati or Asian company can require a French EORI when the customs clearance takes place in France, provided it has not already been registered for an EORI in another EU Member State. French Customs explains that the French number for a third-country operator follows the pattern “FR + the two-letter ISO country code of the country of establishment + the customs number” allocated by the administration. This route does not, by itself, require the company to create a French subsidiary.
4. The foreign parent uses a French subsidiary or branch as the importing entity. The EORI analysis follows the entity named in the customs declaration and the legal role it performs. If the French subsidiary purchases the goods, is the consignee and resells them in France, it may be the importer of record and should use its own French EORI. If the foreign parent remains the owner and the French entity is only a logistics or sales establishment, the declaration must reflect that structure and the relevant representation mandate. A group should not place the parent’s goods under the subsidiary’s EORI simply because the subsidiary has a French address.

Brexit creates a frequent error. A UK company is established outside the European Union for this purpose. A UK-issued number does not automatically replace an EU EORI for a shipment cleared in France. The UK company must verify whether it already has an EORI issued by an EU Member State under a valid establishment or customs arrangement. If not, and if France is the place of clearance, it should examine the French third-country route. The same reasoning applies to a company based in the United States, the United Arab Emirates or Switzerland.

None of these situations should be confused with the appointment of a registered customs representative, often called an RDE in French, for représentant en douane enregistré. A registered customs representative can lodge the declaration on behalf of the company, but the existence of the representative does not necessarily transfer the commercial role of importer or the underlying customs and tax risks. The mandate must state whether the representation is direct or indirect, who owns the goods, who pays duties and import VAT, and which entity’s EORI appears in the declaration.

The French formalities system also matters at incorporation. Under Article L. 123-33 of the Commercial Code, an enterprise generally files one electronic dossier with the designated single body for the creation, modification or cessation of its activity. That Guichet unique process supplies registration information; it does not eliminate the separate customs registration. The foreign founder should treat “company incorporated,” “VAT identified,” “EORI issued” and “EORI active in the European customs system” as four separate checkpoints.

There is a useful commercial reason to make this distinction early. A French business can be legally incorporated while its first container is still unable to clear because the EORI is inactive, linked to an old address, attached to a different establishment, or used in the wrong representation capacity. The cost is not limited to a delay. Storage, demurrage, carrier charges, return freight, abandoned goods and a missed customer delivery can quickly exceed the cost of a properly prepared application.

II. How do you obtain and use a French EORI number without a customs blockage?

A. What documents, filing steps and 2026 checks are needed?

The French application is made through the French Customs online service SOPRANO EORI. French Customs distinguishes the full SOPRANO access for an operator with the “Opérateur Douane” status from the simplified SOPRANO access for an operator without that status. A foreign company applying for a French EORI should identify the customs service designated for third-country operators, described by Customs as “EORI, OEA, RDE,” where the goods are to be cleared in France. The application is not a request for an ordinary French tax number and should not be filed with a random carrier account.

Prepare a single evidence pack before opening the form. It should normally contain:

• the exact legal name of the company, including punctuation and corporate suffix;
• the registered address in the country of establishment and, where applicable, the French establishment address;
• the foreign company registration certificate or French registration data;
• the SIREN and SIRET data for a French company or French establishment;
• the identity and authority of the director or representative completing the request;
• the planned customs office, port, airport or logistics route for the first clearance;
• the written mandate of the registered customs representative, freight forwarder or customs broker, if one is already appointed;
• the French or foreign VAT number where it is relevant to the import arrangement;
• the company’s email address and contact details for Customs correspondence; and
• the internal decision identifying the importer, owner of the goods, consignee and party responsible for customs debt.

A French company generally needs its SIREN and establishment information before applying. This is why incorporation and the EORI should be sequenced rather than treated as one click. Article 286 of the French General Tax Code separately requires a taxable person to file a declaration within fifteen days of starting operations and to provide information about its activity. That VAT declaration obligation is not the EORI application, but inconsistent activity, address or entity data can generate questions from the tax office or Customs.

VAT identification is governed by a different provision. Article 286 ter of the General Tax Code identifies categories of taxable persons that receive an individual VAT identification number, including certain persons liable for VAT on imports. A French VAT number may be essential to an import model, but it does not become an EORI merely because it starts with FR. The two identifiers must be checked separately in the carrier’s instructions and in the customs declaration.

After the application is accepted, do not assume that the number is immediately usable. French Customs states that, because of the processing time required at Community level, an issued EORI becomes active twenty-four hours after it is granted. The administration’s practical wording is that “all EORI numbers are active 24 hours after having been issued.” A founder planning a first import on Monday should therefore file before the final weekend, allow for any request for clarification, and ask the customs broker to validate the number in the European EORI database before the shipment departs.

The 2026 transition deserves a separate internal control. A French company that has only an EORI SIRET should:

1. confirm the legal unit’s current SIREN and every active establishment;
2. check whether an EORI SIREN has already been allocated;
3. request the EORI SIREN if it is missing;
4. validate both the number and the legal name in the European validation service;
5. update the number in the customs broker’s master data, carrier portal, freight-forwarder instructions and any safety-and-security filing;
6. replace old templates that still show only the EORI SIRET; and
7. keep a dated copy of the validation result and the allocation notice.

The migration is not merely a formatting issue. The SIREN identifies the French legal unit, while the SIRET identifies an establishment. A group importing through two French warehouses should decide whether the customs flow is intended to be managed at the legal-unit level or requires establishment-level data in the relevant systems. That decision should be consistent with the place of clearance, the VAT reporting process, stock ownership and the customs representation mandate.

The French Customs code was recodified in 2026. For the release of goods, Article L. 211-3 of the Code des douanes provides that goods may be made available after authorisation and after the applicable duties and taxes have been paid, consigned or guaranteed, the VAT base has been established, and, where applicable, the validity of the relevant identifiers has been verified. This is why a broker’s “EORI invalid” message should not be treated as a minor technical error. It can be one of the conditions preventing release.

B. What should you do if the EORI is rejected, inactive, misused or connected with an import-VAT problem?

The first step is to obtain the reason in writing and identify the exact data field that failed. “EORI rejected” can mean several different things: the legal name does not match the registration record; the company’s address is outdated; the number belongs to a different legal unit; the number has been issued but is not yet active; a French EORI was requested despite an existing Union EORI; the number is valid but the customs software does not yet recognise the EORI SIREN; or the company is trying to use a VAT number in the EORI field. Each case requires a different correction.

First scenario: a newly incorporated French company has no active EORI. Send the Kbis or RNE registration evidence, the SIREN/SIRET data and the allocation notice to the broker. Check whether the twenty-four-hour activation period has expired. If it has not, ask the carrier whether the goods can remain under customs supervision until activation. Do not ask the broker to use its own EORI as a substitute unless the legal representation and customs declaration clearly support that arrangement. A temporary workaround that misidentifies the importer can create a larger problem than the original delay.

Second scenario: the EORI belongs to a foreign parent, but the French subsidiary is named as importer. Stop the filing and reconcile the commercial invoice, transport document, purchase contract, Incoterms, customs mandate and declaration data. If the subsidiary bought the goods and bears the import obligations, it may need to use its own EORI. If the parent remains the owner and the French entity acts for it, the declaration may need a representation structure that reflects that fact. A group should not let the logistics department choose the EORI solely on the basis of which company has a French bank account.

Third scenario: the operator is a non-EU company with no French subsidiary. A lack of French incorporation does not automatically prevent a French customs clearance. The company should determine whether it is already registered in an EU Member State. If it is not, it can examine the French third-country procedure where France is the place of clearance. It should also decide whether it needs a registered customs representative and whether its product requires an authorisation, an economic-operator status, a safety-and-security filing or an import licence. EORI is a gateway identifier; it does not by itself authorise the product or solve the VAT, licensing or conformity analysis.

Fourth scenario: the EORI works, but import VAT does not. Import VAT is a separate tax assessment. Article 293 A of the General Tax Code governs the time at which import VAT becomes chargeable and identifies the relevant taxpayer in different situations. The article also reflects the legal connection between an import declaration and the customs treatment of the goods. A company may have a valid EORI but no French VAT identification, the wrong VAT regime, an incorrect importer on the declaration or no procedure for reporting import VAT. Conversely, a company may have a French VAT number and still lack a valid EORI.

On 25 August 2026, the General Tax Code provision remains the reference to check for the current import-VAT position, while Légifrance records future recodification provisions. The finance team should check the version in force on the actual import date rather than copy a paragraph from an old carrier guide. The same caution applies to a planned shipment around 1 September 2026, when several VAT recodification measures are scheduled to apply. The legal citation should be dated in the internal file, and the VAT return, import declaration and customs account should all identify the same taxable person.

Fifth scenario: an error was made in a declaration. The 2026 Code des douanes contains a right-to-error provision. Article L. 313-1 allows the debtor of a duty or tax to regularise, in specified circumstances, errors, inaccuracies, omissions or insufficiencies committed for the first time in timely declarations during the preceding three years. This is not a general immunity for an undeclared import, a false importer or a missing EORI. The company must establish that the statutory conditions are met and act before the administration’s rights and any control make the position more difficult.

The new code also defines an importation without declaration. Article L. 512-4 of the Code des douanes refers to the importation of goods through an authorised customs place without the declaration required by Article 158 of the Union Customs Code, among other situations. The provision is useful because it shows why the EORI issue must be corrected through the declaration process rather than by merely sending an email to a carrier after the goods have moved. If the problem involves a deliberate false statement or an intentional undeclared import, Article L. 513-4 provides criminal penalties for intentional smuggling or import/export without declaration outside the specific categories addressed by the preceding articles. Those provisions are not invoked for an ordinary administrative delay, but they explain why an importer should never improvise the identity of the declarant.

Where duties or taxes remain unpaid, Article L. 321-3 of the Code des douanes provides for late-payment interest. For eligible regularisations, Article L. 321-4 provides for reductions of the late-payment interest when the debtor regularises under the conditions set by the code, pays the amounts due and is not dealing with an offence that excludes good faith. A foreign founder should preserve the original declaration, the corrected data, the broker’s correspondence, the invoice, proof of payment and the chronology of the error.

The division of responsibility between the company and its customs representative is also settled by case law. In Cour de cassation, commercial chamber, 6 October 2015, no. 13-20.381, the Court recalled that the specialised customs representative must make a declaration that complies with customs law and advise its client, but also remains dependent on information supplied by the client. The decision uses the expression “veiller à faire des déclarations conformes à la réglementation douanière.” For a foreign founder, the practical lesson is two-sided: the broker must exercise its professional duty of advice, while the company must give complete and accurate information about ownership, origin, prior importation, value, use and the identity of the operator.

In Cour de cassation, commercial chamber, 24 January 2024, no. 21-17.776, published in the Bulletin, the Court examined import VAT and a customs representative acting under indirect representation. The decision states that the representative can be jointly liable with the tax debtor in the circumstances addressed by the applicable texts, and it discusses the statutory exemption from a guarantee. The quoted legal formula is “bénéficie, en tant que débiteur de la TVA à l’importation, solidairement avec le redevable de cette taxe, de la dispense légale de caution.” The case does not turn an EORI into a VAT number; it shows why the representation mandate, the importer’s identity and the tax treatment must be aligned before the goods are released.

Finally, prepare the substantive customs file. The EORI is only one field in a legally complete import. Keep the commercial invoice, packing list, transport document, origin evidence, commodity code, customs value calculation, Incoterm, insurance and freight evidence, product authorisations, conformity documents, sanctions screening and any preferential-origin proof. Confirm who is responsible for classification and valuation. An EORI that is valid but used with an incorrect commodity code or an unsupported customs value will not protect the company from reassessment.

When the carrier blocks a shipment, the foreign founder should send a concise escalation pack: the EORI allocation notice, a screenshot or dated validation result, the legal entity’s registration evidence, the invoice and transport documents, the customs mandate, the requested correction, and a written explanation of who is importer and who owns the goods. If the issue concerns a customs decision or a tax reassessment, ask the broker to identify the formal decision, the authority, the deadline and the available administrative or judicial route. Do not rely on a telephone promise that the goods will be released without a written record.

Conclusion

A foreign company importing into France must separate four questions: where the operator is established, where the goods are cleared, which entity is the importer, and which EORI is active for that entity. An EU-established operator normally uses the EORI issued in its Member State of establishment. A non-EU operator may need a French EORI when France is the place of clearance, even without a French subsidiary. A French subsidiary or branch must not borrow its parent’s identifier without a representation and ownership analysis.

For a French company formed in 2026, the safe sequence is to obtain the registration data, file through SOPRANO EORI, wait for activation, validate the EORI SIREN transition, update every broker and carrier record, and reconcile EORI, VAT, importer, consignee and customs-debt information before the first shipment. If an EORI is rejected or import VAT is misaligned, preserve the chronology and correct the declaration through the documented customs route. The cost of a careful pre-clearance review is usually lower than storage, demurrage, a returned shipment or a dispute over customs debt.

For a broader overview of the legal and practical steps for a foreign founder, see our French company formation and business law page. It can be used as the hub for the incorporation, registered-office, VAT, employment and customs questions that follow the EORI application.

Need a quick opinion on your case

You can obtain a telephone consultation within 48 hours with a lawyer from our firm about your EORI, customs representation or import-VAT position.

Call Maître Reda Kohen at +33 6 46 60 58 22, or use our contact page to send the essential documents.