When the Vessel Is the Cargo: How CSG Handled a Nine-Figure FSRU Import

When supply chain disruption reaches a certain scale, the solutions it demands can be just as complicated as the problem itself. This is the story of one such project, with an approach that carries over for any business facing a high-value, exceptional import into the EU.

Excelerate Energy needed to bring a high-value floating LNG terminal into the EU. The vessel was a permanent infrastructure asset, not cargo in transit. That distinction changed everything about how the import had to be handled, with multiple stakeholders involved.

In this article, we explain what CSG did, why each decision was made, and what the approach means for any business that faces a complex, high-value import into the EU.

Contents:

• When macro disruption creates exceptional logistics
• What the Excelsior project involved
• The customs problem nobody had encountered before
• Why the Netherlands — and what fiscal representation means in practice
• The T2L, the six parties, and the same-minute declaration
• What this means for businesses facing high-value exceptional imports
• How Customs Support Group can help

When Macro Disruption Creates Exceptional Logistics

Europe’s response to the energy supply crisis following the Russia-Ukraine conflict forced a set of infrastructure decisions that would previously have taken years. One of the most significant was the rapid deployment of floating LNG import terminals at key German ports.

These terminals – known as FSRUs, or floating storage and regasification units – allowed LNG to be received, processed, and fed into the domestic gas network. They gave Germany a way to replace supply that was no longer available through conventional routes.

The German government moved quickly. Deutsche Energy Terminal GmbH (DET) was tasked with commissioning the programme under a federal mandate. Excelerate Energy – a US-based leader in floating LNG infrastructure – was contracted to supply one of those terminals: the FSRU Excelsior.

None of this was standard freight. And the customs operation required to put it in place was unlike anything in a standard broker’s portfolio.

What the Excelsior Project Involved

An FSRU functions as a permanently moored offshore terminal. LNG carrier ships transfer their cargo to the vessel. The FSRU then converts the LNG into gas and delivers it at pipeline pressure through subsea infrastructure to the onshore grid.

The Excelsior is a 277-metre vessel with a regasification capacity of approximately 4.5 billion cubic metres per year. It had previously completed ten years of service in Israel and a seasonal charter in Argentina. It was Belgian-flagged but built in South Korea — a detail that mattered for determining customs origin.

Excelerate Energy held the vessel. DET, acting under the federal mandate, was the charterer. CSG’s role was to manage the customs clearance that would bring the Excelsior into the EU and position it for its final deployment in Wilhelmshaven, Germany.

This was not CSG’s first FSRU import. The Excelsior was the fourth such vessel the team had handled. Earlier engagements came via a referral from one of the global Big Four professional services firms – a route that reflects the level of complexity these operations involve. By the time Excelerate reached CSG directly, the team had both the framework and the track record.

The Customs Problem Nobody Had Encountered Before

In international trade, a basic rule applies to vessels at borders: you import what is inside the ship, not the ship itself. A container vessel arriving at Rotterdam is not imported; its contents are. The ship is a means of transport, not a declarable good.

The Excelsior broke that rule. Because it was being imported as a permanent infrastructure asset – not as a vessel in transit – the ship itself became the cargo. The declarable good was a 277-metre ocean vessel. The customs value was nine-figure. The goods classification sat within Chapter 89 of the Harmonised System, which covers ships and floating structures.

There was a further complication that arose out of the import strategy. The Excelsior was itself the importer of record – not Excelerate Energy as the owning company. That meant the vessel needed its own EORI number and its own German VAT registration. The vessel, not its owner, held the legal identity for the import.

A German legal firm was brought in to apply for those registrations on the vessel’s behalf. This was not a standard step. It required a clear understanding of what the import actually was, and the ability to structure the legal and customs work around that understanding.

This is the kind of complexity that separates exceptional import work from standard customs operations. You cannot follow an established procedure when no procedure exists. You have to build one – correctly, quickly, and with the full weight of a nine-figure project depending on it.

Why the Netherlands — and What Fiscal Representation Means in Practice

The Excelsior’s final destination was Wilhelmshaven in Germany. The obvious approach would have been to import the vessel directly into Germany. CSG recommended that the import clearance be Netherlands instead.

The reason was VAT. In Germany, import VAT is payable at the point of entry. On a high-value asset, that creates an immediate and significant cash flow obligation – even if the VAT is ultimately reclaimable. The reclaim process takes time. At the scale involved here, the cost of paying that liability upfront and waiting for its return has serious commercial impact.

The Netherlands offers a solution: fiscal representation. Under this mechanism, import VAT is not paid at the border. Instead, it is transferred to a local VAT number and handled through the VAT return cycle. The cash flow problem does not arise.

To use this mechanism, the vessel had to be physically present within Rotterdam’s 12-mile customs zone. CSG made the declaration from there. The fiscal representation structure handled the VAT position. The vessel was then free to proceed to Wilhelmshaven.

Fiscal representation is not a workaround. It is a legitimate EU trade mechanism, underpinned by Article 18 of the Union Customs Code and, in the Netherlands specifically, operated under an Article 23 permit issued by the Dutch tax authority. But you have to know it exists, know when to use it, and be able to execute it correctly. For businesses importing high-value goods into the EU without an established EU presence, it is one of the most useful tools available — and one of the least well understood.

The T2L, the Six Parties, and the Same-Minute Declaration

Clearing the vessel in the Netherlands was not the end of the customs work. Because the Excelsior would travel from Rotterdam through international waters to Wilhelmshaven, CSG also needed to issue a T2L document.

A T2L is the document that proves goods already in free circulation in the EU retain that status when they move between Member States via a non-EU route – including temporary transit in international waters. Without it, the vessel could have been treated as a new import on arrival in Germany. CSG issued the T2L following the Netherlands clearance, closing that exposure before the vessel left port.

The coordination structure for this project involved at least six parties:

• Excelerate Energy, as the vessel owner
• The Rotterdam shipping agent, responsible for managing the vessel’s physical presence and safety reporting
• Dutch legal counsel
• German legal counsel, handling the EORI and VAT registration
• A German shipping agent, overseeing port readiness at Wilhelmshaven
• CSG, managing the customs declaration.

Further complexity arose around a potential to have LNG cargo already on board the vessel. If present, that cargo would have required a separate import declaration – involving additional major industry stakeholders who were already engaged at project level.

In the event, no cargo was present. But the contingency had to be identified, planned for, and resolved before the vessel arrived.

Speed mattered commercially. An FSRU at anchor in the Netherlands’ 12-mile zone incurs port-related holding costs that can run to tens of thousands of euros per day. That figure does not include the ongoing operational costs of the vessel itself – crew, maintenance, and fuel – which continue regardless of where the ship is sitting.

Every unnecessary hour at anchor carries a real price. The goal was to minimise that time, which meant having the import declaration ready the moment the vessel arrived.

CSG filed the declaration in the same minute as the vessel’s arrival within the customs zone. The Excelsior cleared and proceeded to Wilhelmshaven without delay.

From first engagement to cleared vessel, the project ran for approximately 14 months. The main delay was port infrastructure readiness at Wilhelmshaven – not the customs process. CSG’s preparation was complete well before the vessel arrived.

What This Means for Businesses Facing High-Value Exceptional Imports

Most businesses will not be importing an FSRU. But the principles behind this project apply to a much wider range of situations – any time a high-value or non-standard import creates problems that a standard broker cannot solve.

The first principle is jurisdictional structuring. Where you import into the EU is a commercial decision, not just a logistical one. Routing via the Netherlands under fiscal representation can eliminate a VAT cash flow problem that direct import into Germany would create. That option is only available if you know it exists.

The second principle is importer of record structuring. When the importing entity has no established EU presence, setting up the correct legal identity is a prerequisite for everything else. Getting this wrong creates exposure across the whole declaration. Getting it right requires legal and customs expertise working together from the start.

The third principle is multi-party coordination under time pressure. Complex imports involve multiple parties – lawyers, agents, advisers, and customs brokers – who all need to be aligned around a single declaration timeline.

When financial penalties apply to delay, the broker who coordinates the whole process protects the project. The one who only manages their own part does not.

For businesses managing DDP obligations into Germany, importing capital equipment, or restructuring supply chains under external pressure, these are not abstract points. They determine whether a high-value project lands cleanly or accumulates avoidable cost.

How Customs Support Group Can Help

The Excelsior project is one example of the complex import operations that CSG has managed. It is also a clear demonstration of what separates a specialist customs advisory partner from a standard broker.

Customs Support Group provides practical expertise across:

• Fiscal representation and VAT deferment for high-value EU imports, including structuring via the Netherlands for businesses without an established EU presence
• Exceptional and non-standard import clearance, including asset imports, capital equipment, and goods without conventional cargo manifests
• Importer of record structuring, including EORI and VAT registration for entities without an existing EU customs identity
• T2L and customs status documentation for goods moving between EU Member States via international waters
• Multi-party project coordination across legal, shipping, port, and customs workstreams under commercial time pressure
• DDP incoterm advisory for sellers managing delivery obligations into EU markets, including Germany

If your business is facing an import challenge that falls outside the standard playbook, speak to our team.