Logistics

DAP vs DDP for Phone Case Imports: Who Is the Importer of Record?

5 October 2026

Buyers compare quotations on unit price and freight, then sign off on an Incoterm without reading it properly. That is a mistake, because the Incoterm decides something far more expensive than freight: which company the destination market treats as the one that placed the product on the market.

The two terms that matter here

Why "importer of record" is the whole question

EU product rules bite on whoever places the goods on the Union market. If you clear the goods, that is you. Two consequences follow, and both are manageable once you know they exist:

• General product safety (GPSR, Regulation (EU) 2023/988). Goods need a responsible person established in the EU, and traceability information. For a passive accessory this is usually a name-and-address exercise, not a testing exercise — but it is still an obligation that has to be met by somebody.
• Packaging register (Germany: Verpackungsgesetz / LUCID). Anyone who puts packaged goods on the German market for the first time registers and pays a licence fee on the packaging. This catches importers who have never thought about it.

DAP is the normal answer for wholesale

For wholesale orders, DAP is the standard arrangement because it is transparent: you know your unit price, you know your freight, and you keep control of your own customs and VAT position — which, as a registered business, you generally want, because import VAT is recoverable and the packaging licence fee is your own cost of doing business anyway.

It also keeps the commercial relationship clean. A supplier acting as importer of record in a market it does not operate in is a fiction that falls apart the first time something is queried.

When DDP makes sense

DDP is genuinely useful in specific cases:

• You are a small buyer without a customs registration and want a landed-cost number you can trust.
• You are shipping samples or a pilot order to a fulfilment warehouse that will not accept uncleared goods.
• You have agreed, explicitly and in writing, who handles the EU-side obligations — including appointing a responsible person established in the EU and covering the packaging register.

What makes DDP dangerous is not the term. It is agreeing to it without deciding who does the work that comes attached to it.

Four questions to ask before you accept any quorum on Incoterms

1. Who is the importer of record for this shipment?
2. If that is you, who is the EU responsible person for the goods, and whose name and address will go on the packaging?
3. Who holds the German packaging register (LUCID) obligation — and does the other side know that?
4. If the goods are held at customs, who pays the storage and who talks to the broker?

Write the answers into the order confirmation. An Incoterm on its own is a delivery rule, not an allocation of regulatory duty.

Our default

Our quotations are normally issued DAP, with the buyer clearing in the destination market. That is set out in section 16 of our Terms & Conditions, and if you need DDP we will say in writing who is taking on the EU-side obligations on both sides.