A customs representation mandate (often called a customs power of attorney) is the written authorization a company gives a customs representative to carry out customs formalities on its behalf. It sets the type of representation, direct or indirect, and the scope of operations entrusted. In France, the mandate is established by written evidence, which may be provided electronically (French Customs Code, Article R221-13).
Direct or indirect representation
The Union Customs Code (UCC), Articles 18, 19 and 77, the EU regulation governing customs clearance, provides for two types of representation. French Customs summarizes them in its registered customs representative guidance:
- in direct representation, the representative acts in the client’s name and on its behalf;
- in indirect representation, the representative acts in its own name, but on the client’s behalf.
| Direct representation | Indirect representation | |
|---|---|---|
| In whose name? | The client’s | The representative’s |
| On whose behalf? | The client’s | The client’s |
| Debtor for a debt arising from the declaration | The client, as declarant | The representative, as declarant, and the client |
| Representative’s exposure | More limited | Broader |
The representative must state that it is acting on behalf of someone else and specify the type of representation. If it fails to do so, or acts without being empowered, it is deemed to act in its own name and on its own behalf. Customs may also ask for evidence of the empowerment (UCC, Article 19).
Who can act as a customs representative?
Any person may appoint a customs representative established in France or in another Member State. Since 1 January 2018, operators acting under direct or indirect representation in France must be registered as a registered customs representative (RDE), a role still commonly called a “customs broker” (French Customs guidance).
Since 1 May 2026, the French registration rules sit in the regulatory part of the French Customs Code (Articles R221-13 to R221-28):
- applications go to the interregional customs directorate;
- applicants must meet certain UCC criteria (Article 39, points a and d) and have appropriate record-keeping and administrative organization;
- registration is granted for an indefinite period.
A freight forwarder may be a registered representative, but not automatically: check the status of the entity actually filing your declarations. Our article on the differences between freight forwarders, transport organizers and customs brokers explains these roles.
What should the mandate contain?
The rules require written evidence, not a single mandatory form. French Customs provides full and simplified power-of-attorney templates, which define in particular the delegated powers and the geographic scope (power-of-attorney procedure, in French). Your representative will often propose its own template.
Before signing, check that the document answers these questions:
- Who? Identity of the principal and the representative, company identifiers (SIREN, EORI number).
- Which type? Direct or indirect representation, clearly stated.
- Which operations? Import, export, special procedures, flows or customs offices covered.
- Until when? Duration, renewal and termination conditions.
- Who signs? A person authorized to bind the company.
- Who supplies what? Who provides and validates classification, origin and value information.
This list is a review checklist, not a legal template.
Liability and customs debt
On import (release for free circulation or temporary admission), the customs debt arises when the declaration is accepted, and the declarant is the debtor. Under indirect representation, the person on whose behalf the declaration is made is also a debtor (UCC, Article 77). If the declaration is based on false data that leads to duties not being collected in full, the person who supplied the data, and who knew or should reasonably have known it was false, is also a debtor.
In practice, the type of representation never relieves the client from supplying accurate data: description, HS code, origin, value and supporting documents.
Duration, validity and termination
The mandate lasts as long as the parties decide. Under French civil law, a mandate ends in particular through revocation, renunciation by the agent, or the death, guardianship or insolvency of either party (French Civil Code, Article 2003).
Do not confuse two durations: the representative’s registration is indefinite, whereas the mandate your company grants can be limited in time or to specific operations.
How to grant the mandate in practice
Agree on the type of representation with your provider, use its template or the French Customs one, have an authorized person sign it, then keep a copy your teams can access. Update the mandate when the entity, flows or provider change.
Store the mandate and your exchanges with the representative in the shipment files: the representative finds the documents it needs, and your team keeps a record of what was provided.
Frequently asked questions
Is a customs representation mandate mandatory?
A representative can only act for you if it is empowered to do so. In France, the mandate is established by written evidence, possibly electronic, and customs can ask to see it. Without empowerment, the representative is deemed to act on its own behalf.
What is the difference between direct and indirect customs representation?
Under direct representation, the representative acts in your name and you are the declarant. Under indirect representation, it acts in its own name on your behalf: it is the declarant and both of you are debtors for the debt arising from the declaration.
What is a registered customs representative (RDE)?
It is an operator registered with French Customs to carry out formalities on behalf of others. Registration has been compulsory since 2018 and is granted for an indefinite period.
How long is a customs power of attorney valid?
There is no single duration: it depends on what the mandate states. It ends in particular through revocation or renunciation. Review it whenever your provider or legal entity changes.
Do I need an EORI number to grant a mandate?
French Customs states that economic operators carrying out customs formalities need an EORI number, the EU customs identifier for businesses. For a French company, it consists of FR followed by its SIRET or SIREN number.