The customs territory of the EU is a single territory (comprising the EU MS’ territories). In general, for origin purposes the EU is considered as a whole, one unit, therefore any MS can be considered as the exporting country and in some cases this MS might differ from the one in which the exporter is established and keeps all evidence concerning the origin of the goods.
For certification of the preferential origin, the exporter (including the approved one) is the person able to determine and certify the origin (on the basis of the relevant documentation, including the supplier's declarations), to answer the subsequent verifications and to engage her/his responsibility on the correctness of her/his declarations concerning origin. The exporter, as a declarant or as an economic operator having goods declared on her/his behalf in view of the exportation is not necessarily the same person.
PEM rules of origin do not contain any definition of “exporter”. EU understanding of the term for the purpose of preferential origin can be illustrated by the definition in the EU Regulation 2015/2446 (Union Customs Code Delegated Act), Art. 37 (20) – person who is exporting the goods, whether or not she/he is the manufacturer and whether or not he himself carries out the export formalities.