Export freight enquiries: will you also act as customs representative?

A business asks you to arrange transport from Germany and adds, “You’ll handle customs as well, won’t you?” Your sales team now faces a decision beyond the route and vehicle. Does your company intend to act before customs authorities for another person? Or will the customer appoint its own customs representative and buy the agreed transport service from you? Both arrangements need a specific discussion with the people responsible.

This guide concerns commercial export enquiries starting in Germany. It helps you clarify the customer’s request, identify the businesses involved and establish what a competent specialist has actually checked. You can then offer a properly reviewed representation service, coordinate transport with a representative appointed by the customer or request a specific specialist clarification first. You do not need to walk a prospect through a customs declaration to make that sales decision.

Turn the customer’s request into a clear question

Start with what the prospect expects from your forwarding business. “Customs included” might mean that your company should act as representative for a declaration. Alternatively, the customer may simply want to know which transport details its existing representative needs. Ask the customer to describe the intended arrangement. That answer establishes whether you are discussing a new representation service or coordinating a task already assigned to somebody else.

Ask for the exact destination country and intended movement of the goods. “Europe” is not enough for this assessment. A destination category gives a geographical direction; the responsible customs specialist assesses the particular circumstances using the actual information. Do not infer a specific declaration requirement or its absence from a broad country group. Your useful next step is to collect the information that allows the competent person to assess the real case.

Record which business is making the enquiry and which business wants to be represented. Your contact might work in dispatch, purchase transport for a buyer or act as an intermediary. That function does not automatically identify the person in whose name a declaration should be made. Ask for the company concerned and the responsible contact for the requested customs service. Keep separate businesses separate in your notes rather than merging them under one customer label.

The webRichtung freight forwarding page describes shipment type, destination area, timing preference, a collection location in Germany and contact details as the information supplied. It does not promise a confirmed customs role or authority to represent a party. Use the enquiry to open your conversation and obtain the missing details yourself. An overseas destination creates a reason for further assessment, rather than evidence of an already prepared export or booked representation service.

Decide which role your company would take

For the position considered here on 17 October 2026, Article 18 of the Union Customs Code distinguishes direct and indirect representation. A direct representative acts in another person’s name and on that person’s behalf. An indirect representative acts in its own name but on another person’s behalf. These describe different roles. Put the intended form into your offer only after the responsible specialist has reviewed the proposed arrangement.

Check internally whether your company actually wants to offer the requested representation and who decides this. Offering transport does not by itself mean that a forwarding business has taken on a particular customs service. An individual employee’s experience also does not replace an agreed business decision about this enquiry. Have the actual case checked against what your company can genuinely provide before promising the prospect a particular form of representation.

If the customer has already appointed a customs representative, your task changes. Establish which information and confirmations your transport planners need to exchange with that representative and who will introduce the contacts. Describe your offer as transport with the agreed coordination. Providing useful transport information to a separate representative does not turn your company into the intended representative for that other party’s customs actions. Keep the business arrangement understandable to your customer and your own team.

The new Regulation EU 2026/2108 has specific application provisions in Article 287. Entry into force does not make all its provisions immediately applicable. The general application date is 21 September 2027, with expressly defined exceptions. Articles 18 and 19 of Regulation 952/2013 therefore provide the basis for the representation decision discussed at the stated date. Recheck the applicable position when using this guide at a later date.

Separate identification from authority to represent

An EORI number helps identify a participant. The German customs guidance on EORI use explains its purpose, uses and exceptions. A number alone does not establish the intended form of representation or whether your company has authority to carry out the particular action. Ask the competent specialist which participant details are actually required for this case. Identification and the decision to represent someone need to be addressed separately.

Article 19 requires a customs representative to disclose that it is acting for another person and whether representation is direct or indirect. It also addresses the consequences of missing authority or an undisclosed representative role. For sales, the practical task is to have the actual authority and its connection to this service reviewed before promising representation. A friendly assurance from your contact is not a completed specialist assessment for every action the customer might have in mind.

Under Article 19, customs authorities may require evidence of the authority to represent another person. The provision also contains exceptions and a rule for regularly performed actions. Do not claim that every sales conversation requires one specific new paper document, or that existing customer records remove every need for checking. Your responsible specialist establishes how authority should be clarified for the case and how it can be demonstrated if required. Sales should retain that conclusion accurately.

Request documents for an identified purpose. If the company to be represented is unclear, establish its identity first. If specialist assessment requires clarification of a particular authorisation, name the unresolved question and the appropriate recipient. Collecting every available document does not create a sound decision by itself. Tell the customer what is missing and which responsible person needs to assess it for the proposed service. This keeps the request useful rather than burdensome.

Connect the reviewed customs arrangement to your transport offer

Once the role is assigned, sales can prepare the required coordination with transport planning. Who provides information about the specialist’s confirmed position? Who answers questions about goods information supplied by the customer? Which outstanding response does your planning team need? Specify these handovers. “Customs sorted” tells the team very little if it identifies neither a responsible person nor a traceable case. A concrete reference gives colleagues something they can actually work with.

Distinguish information received from a service that has been agreed. A customer might say that its representative will deal with the matter. Your planners then need to know who confirms the contact and how the necessary coordination will work. Record whether you are repeating a customer statement or have received a specific response from the responsible person. Your offer can then reflect what is genuinely known without silently treating an expectation as a completed confirmation.

Define the limits of your own activity as well. A transport offer may include described coordination with a separate customs representative. An additional request for your own representation needs a reviewed service description and an appropriate business agreement. Your company’s actual calculation determines its remuneration. Neither a lead category nor this guide creates a standard surcharge or an automatically included amount of duty. Keep the commercial explanation connected to the service you have genuinely assessed and offered.

Give the customer a useful next decision. They may be able to review a transport proposal while their representative addresses a named outstanding point. Alternatively, clarification of the intended role may be needed before an offer has a reliable basis. Explain that specific dependency. Confirmed transport planning does not promise customs release, a particular assessment of duties or an unobstructed export. Those outcomes cannot be guaranteed from an initial sales conversation or from the arrival of a lead.

Two fictional conversations show the different routes

In the first explicitly fictional case, a commercial consignor requests collection in Germany for a delivery to a non-EU country. Its company already works with a named customs representative. It wants transport from your forwarding business and coordination of the necessary transport details. Sales asks for confirmation of the contact and the particular case. Your own service can consequently be described as transport with agreed cooperation, rather than an assumed additional representation service.

Your team asks which response the representative needs for this arrangement and who passes it between the parties. The responsible transport planners assess your operation using that information. You do not have to sell the customer a new representative or take over another party’s declaration as your own service. The appropriate offer follows the need actually described. Questions that remain open stay with the people who are competent to answer them for the particular movement.

In the second fictional case, the prospect has not named a customs representative. It sends only a company number and expects your business to include the declaration. Your salesperson records the request, asks which company would be represented and refers the matter to the responsible specialist. The number alone does not trigger a commitment. First, your company establishes whether it can offer the service and which role would be appropriate for the circumstances being considered.

The outcome may be a reviewed representation service from your own business. It may instead be transport alongside a representative separately appointed by the customer. If decisive information is missing, the prospect receives a specific follow-up question. These are different commercial responses to the same transport opportunity. None proves that a permit exists or that a particular authority will reach a certain decision about the shipment used in this hypothetical example. Keep that distinction visible in the discussion.

Record a decision your team can use

Summarise the enquiry with the businesses involved, requested customs role and known review status. Name the person who decides about your own representation or the confirmed representative appointed by the customer. Add the outstanding information and next responsible contact. The useful conclusion is clear: which service can sales now offer, and which answer is needed first? A long case note without that next step does little to move a genuine prospect towards an appropriate offer.

Use the same allocation of roles in the customer conversation. Explain, for example, that you are preparing transport based on coordination with the representative they named. Alternatively, say that your specialist first needs to review the requested representation by your company. Relate the answer to this case. Avoid suggesting that the whole export is dealt with when only the roles have been clarified. A clear, limited proposal is easier for the customer to assess and your team to support.

Additional transport enquiries for your sales team

You can register your business on the webRichtung freight forwarding page. The supplied information starts the transport conversation. Customs representation and its specialist assessment remain part of your own offer preparation. In webRichtung Customer, you see the current price before placing a lead order. Choose an enquiry intake that your team can genuinely handle and turn each suitable contact into a specific discussion about your services.

Sources and date of assessment

Read on 17 October 2026: Articles 18 and 19 of Regulation 952/2013, Articles 284 to 287 of Regulation 2026/2108, German customs EORI guidance and the freight forwarding page. This concerns exports from Germany and sales preparation, not customs-system instructions or individual licensing advice.