What Is an RDE (Registered Customs Representative)?

Since May 1, 2016, the Union Customs Code (UCC) has replaced the Community Customs Code (CCC) with the RDE (Registered Customs Representative).

This is the party responsible for handling the formalities required to bring goods into or out of France and the European Union.

What Is an RDE?

Under Article 18 of the UCC, a customs representative may be appointed by any person, subject to 3 conditions:

• Being registered with the customs authorities and the French Customs and Indirect Tax Authority (DGDDI).
• Meeting the requirements set out in the Order of June 14, 2018.
• Being established in France or in a Member State of the European Union. Under certain conditions, representatives not established in the EU may also be appointed.

The Role of the Registered Customs Representative

The RDE specializes in managing customs procedures on behalf of others. They prepare the required formalities and present the goods to the relevant authorities.

Direct Customs Representation

Under direct representation, the RDE’s mandate allows them to handle all customs clearance operations in the name of and on behalf of another party. The importer or exporter therefore remains solely responsible for customs formalities, and the RDE does not assume legal liability.

Indirect Customs Representation

Here, the representative acts in their own name and assumes liability for all the procedures carried out.

What About CBAM Goods?

Since January 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) has entered its final phase. In practice, any import of CBAM goods — steel, aluminum, cement, fertilizers, electricity, or hydrogen — into the European Union triggers specific reporting and financial obligations that are directly tied to customs clearance.

This is precisely the context in which the choice of indirect representation becomes critical. When a Registered Customs Representative acts under indirect representation for goods subject to CBAM, they must also act as an indirect CBAM customs representative, meaning they must carry out the CBAM formalities in the name of and on behalf of the importer, while assuming their own liability.

This extended mandate covers in particular:

• Verifying the eligibility of imported goods against the 550+ customs nomenclature codes covered by CBAM
• Collecting greenhouse gas (GHG) emissions data from third-party suppliers
• Preparing and filing the annual CBAM declaration (due by May 31 each year)
• Purchasing and surrendering the corresponding CBAM certificates, priced in line with the EU Emissions Trading System (ETS)
• Deducting any carbon costs already paid in the country of origin, where applicable.

⚠️ Important: the 50-tonne annual exemption threshold is assessed at the importer level. Below this threshold, no CBAM obligation applies — something the customs representative systematically checks before initiating any procedure.

FISCALEAD handles this dual mission — customs and CBAM — through an integrated approach, ensuring consistency between your customs clearance and your climate-related obligations.

The Customs Representation Mandate: An Essential Document

What Is a Customs Representation Mandate?

The customs representation mandate is the legal document by which a company or individual (the principal) authorizes a Registered Customs Representative to carry out, on their behalf, all necessary customs formalities. This mandate formalizes the relationship between the client and the representative and precisely defines each party’s roles, rights, and responsibilities.

Why Is It Essential?

Without a properly drawn-up customs representation mandate, a representative cannot legally submit customs declarations on behalf of a third party. This document proves to customs authorities that the representative is duly authorized, and it legally protects both the principal and the representative by clarifying their respective roles and level of liability.

What Does It Include?

A customs representation mandate must specify:

• The identity of the parties (principal and representative);
• The nature of the transactions concerned (import, export, transit, special procedures, etc.);
• The type of representation: direct or indirect
• The obligations and responsibilities of each party;
• The validity period of the mandate (single operation or fixed term);
• The conditions for revocation;
• And, of course, it must be signed by both parties.

The RDE’s Responsibilities

The RDE acts as an intermediary between the customs authority and their client. Thanks to them, customs formalities (registering and declaring goods on import or export) are carried out properly and in line with best practice.

Their responsibilities include:

• Verifying the validity of the client’s documents and ensuring they meet the requirements of the relevant authorities. If the documents are not compliant, the import or export of the goods cannot proceed.
• Submitting additional supporting documents when required.
• Ensuring the correct application of duties and taxes, based on the nature of the goods, the country of origin, and the country of destination.
• Carrying out a physical inspection of imported or exported goods when needed.
• Advising their partner on the choice of customs procedure and calculating, in real time, the economic performance of these procedures, as well as the return on investment.
• Providing advisory and informational support (goods classification, customs tariffs, duty reductions, etc.). It is thanks to their expertise that clients can carry out their import and export operations.
• Organizing the transport of goods and developing the related logistics strategies.

In addition, the RDE is involved in several other key areas:

• Preparing and submitting customs declarations, including those for import, export, and transit.
• Managing, maintaining, and updating approvals, authorizations, and certifications, with active monitoring to ensure all qualifications remain in order and meet current regulatory requirements. Approvals are treated as the foundation of operational capacity, followed by authorizations for specific operations and certifications for compliance with particular standards.
• Representing clients before customs authorities, including handling disputes or responding to requests for additional information.
• The RDE also provides ongoing support and advice to clients, particularly on matters related to optimizing customs clearance procedures and ensuring compliance with European and international regulations.

Registering as an RDE

Several criteria must be met, including: no record of serious or repeated infringements, no criminal record, a proper system for keeping customs and commercial records, and demonstrating the professional competence required to act as a Registered Customs Representative.

Liability and Penalties

The RDE plays an essential role in import-export transactions, but this comes with significant legal liability. In the event of non-compliance or irregularities in customs declarations, the consequences can be severe for both the RDE and their clients. Potential measures include financial penalties, legal sanctions, or the revocation of RDE and AEO status.

Import or Export Customs Clearance

To carry out import and export operations, holding Customs Agent status is mandatory.

RDE with AEO Status

AEO (Authorized Economic Operator) status provides additional advantages, such as the ability to operate in other EU Member States and benefit from centralized EU customs clearance.