Why Italian Customs Really Blocks Incoming Goods in 2026 — A Fiscal Representative's Firsthand Guide
Set aside counterfeits and undervalued declarations, and most goods stopped at the Italian border are stopped by paperwork: a missing EORI, an absent conformity mark, or a VAT number closed ex officio that the importer still believes is active.
I have worked as a fiscal representative in Italy for years, and one question I get constantly from foreign sellers is why their goods were stopped at customs. Set aside counterfeit goods and deliberate undervaluation — that is clear fraud, and customs is built to catch it. Most of the holds I actually see have nothing to do with fraud at all.
They come down to administrative gaps: a missing registration, a document that is not where it should be, or a VAT number the importer did not even know had already been closed. Here is what I actually see trigger a hold, and along the way, a regulatory shakeout from the past two years that is still catching non-EU sellers off guard in 2026.
Rarely Fraud, Almost Always Paperwork
Beyond counterfeit merchandise and undervaluation on the customs declaration — both treated as fraud, and both handled accordingly — the most common reason goods are held at the Italian border, in my experience, is administrative.
A Missing or Invalid EORI Number
The first requirement is a valid EORI number: the identifier every non-EU business needs before its first customs declaration in the EU, issued by one of the 27 national customs authorities. If a shipment arrives without one declared in advance, it is held until that is sorted out.
Missing Product-Conformity Marks
The second is product conformity. Goods that do not carry the required marks — the CE mark, for instance, by which the manufacturer declares that a product meets the EU requirements allowing it to circulate freely, or WEEE markings for electronics — are not released into free circulation, regardless of whether the VAT and EORI side of the paperwork is otherwise in order.
Confusing the Customs Agent’s Role with the Fiscal Representative’s
The third is importer documentation, and this is where I see the two professional roles involved get confused constantly. The customs agent is the licensed professional who clears goods through customs and takes responsibility for the import declaration itself. As a fiscal representative I have a separate, VAT-focused role: I am responsible for the tax side of the transaction, not for customs clearance.
I have personally had customs officials ask me directly whether I had signed certain clearance documents. The answer is no, because that is not the function I perform. Confusing the two roles — or having a customs agent operate without the credentials the role requires — creates exactly the kind of documentation gap that gets a shipment held.
The 2024–2025 Reform Most Sellers Never Heard About
Here is where it becomes more consequential for anyone using a fiscal representative to import into Italy. The rules have been in force since 2025, but this is the part I think most sellers still do not fully understand, even now in 2026.
Decreto Legislativo 13/2024 introduced two separate guarantee requirements aimed at cleaning up the fiscal representation market. They are distinct obligations, each set by its own ministerial decree in December 2024 and made operational by its own Agenzia delle Entrate measure in April 2025 — and taking one for the other is the first mistake to avoid.
The Guarantee the Representative Itself Must Post
A guarantee I, as the representative, have to post myself, scaled to how many businesses I represent: from €30,000 for a handful of clients up to €2,000,000 for a representative handling more than 1,000. A firm representing a single client posts no guarantee at all, only a declaration that it meets the eligibility requirements. The brackets and the minimum term of 48 months come from the Ministry of Economy and Finance’s decree of 9 December 2024; the procedure, from Provvedimento n. 186368 of 17 April 2025.
Representatives already operating on that date had 60 days — until 16 June 2025 — to file the declaration and, where required, the guarantee. Miss it and the Agenzia delle Entrate notifies the representative that the procedure to close the VAT numbers of every business it represents has begun: 60 further days, and then those numbers are closed ex officio.
The practical effect: a fiscal representative with a large book of foreign clients now needs a seven-figure guarantee on file with the tax authority simply to keep operating — and if it does not, it is the clients’ VAT numbers that close, not the representative’s own registration. I represent several thousand foreign businesses, and we posted the top-tier €2,000,000 guarantee to keep operating under the new rules.
The Guarantee the Represented Business Must Post for VIES
A separate guarantee, this time for the represented business itself — a minimum of €50,000 for at least 36 months — is required for a non-EU or non-EEA company to obtain or keep VIES inclusion when it operates through a fiscal representative. Its criteria come from the ministerial decree of 4 December 2024, its operational rules from Provvedimento n. 178713 of 14 April 2025. It applies on top of, and separately from, the guarantee I have to post as the representative — how it works across the EU is the subject of our guide to VIES for non-EU companies.
The Wave of VAT Deregistrations That Followed
From what I have seen directly, a meaningful wave of VAT number closures followed, as representatives who had not gone through the qualification process had their clients deregistered — by my own estimate, in the tens of thousands, concentrated in the reform’s rollout window. The businesses caught in that wave had generally done nothing wrong themselves: they simply did not know their representative had failed to qualify. What reopening now involves, step by step, is set out in our guide to Italian VAT and VIES registration.
Why This Still Shows Up as a Customs Hold Today
A closed VAT number does not announce itself. A business can go on believing that its Italian VAT and EORI are both active — invoicing normally, shipping normally — right up until a shipment reaches an Italian port and customs finds no valid VAT number behind the EORI on file.
At that point the goods are held, and reopening a VAT number closed ex officio is not a same-day fix in my experience: absent a representation mandate dated before the closure, a narrow exception that applied to very few of the cases I have handled, it has to be reopened from scratch — and, where the business needs VIES, with the €50,000 guarantee requirement now attached.
One clarification I make constantly: VIES inclusion is not automatically required. It matters only if the business needs to invoice other VAT-registered EU businesses without charging VAT under the intra-community regime. A non-EU seller that imports into Italy, sells to Italian consumers and pays Italian VAT normally has no VIES obligation at all. I still see sellers assume VIES is mandatory for any EORI and VAT setup. It is not, and the two should not be conflated when diagnosing a hold.
What I Would Check, in 2026
- Confirm that your fiscal representative completed the 2025 qualification process, and ask for proof of the guarantee it posted with the Agenzia delle Entrate — not just a VAT registration certificate. Since 25 February 2026 you no longer have to take anyone’s word for it: the Agenzia delle Entrate publishes a verification service for fiscal representatives that anyone can query by tax code.
- Check your own VAT number’s status directly with the Agenzia delle Entrate, rather than assuming it is active because nothing has changed on your end.
- If you sell only to consumers, or already pay Italian VAT directly, do not assume you need VIES — confirm whether your actual sales model requires it before treating it as a blocker.
- Keep customs-agent and fiscal-representative documentation clearly separated: a hold citing missing authorisation is usually a gap on the customs-clearance side, not the VAT side.
Working with a Qualified Representative
I work as a fiscal representative at Servix International, qualified under Italy’s 2024–2025 rules and representing several thousand non-EU businesses in Italy. If a shipment of yours is already held, or you simply want to know whether your Italian setup would survive the check, we review VAT, EORI and VIES status before the goods leave — which is the only point at which fixing it is inexpensive.
Sources: Decreto Legislativo 13/2024 (Normattiva) · Ministerial decree of 4 December 2024 — VIES guarantee (Gazzetta Ufficiale) · Ministerial decree of 9 December 2024 — fiscal representative’s guarantee (Gazzetta Ufficiale) · Agenzia delle Entrate, Provvedimento n. 178713 of 14 April 2025 · Agenzia delle Entrate, Provvedimento n. 186368 of 17 April 2025 · Agenzia delle Entrate, fiscal representative verification service · European Commission, EORI number · European Commission, CE marking.
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