Exporter of Record when a shipment leaves the EU



My question is related to Exporter of Record. If we as a business are not part of the supply chain, can we be listed as the exporter of record on a shipment leaving the EU?

In particular, these are dual use goods and would be exported under my companies OIEL (still obtaining relevant EUU’s and conducting other checks). We would essentially be offering an export “service” to assist one of our customers.

I believe the main issue we have is in relation to the ECO Part 5 – where it states we must be owner of the goods or have relevant rights of disposal. Is there a way around this?

Surely there must be businesses out there enabling companies who want to export by taking the risks on their behalf?

Thanks in advance for any help.

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Export Action Plan