FCA, in almost every case. Under EXW the seller does nothing beyond making the goods available at their premises, which leaves export clearance and often loading with a buyer who has no legal standing to file an export declaration in the seller’s country.
Why it works this way
EXW is the only Incoterms rule that places export formalities on the buyer. In practice that rarely works across a border: the export declaration is normally filed by an established exporter in the country of departure, so an EXW sale ends with the seller doing the clearance anyway, informally and without the obligation being written anywhere.
FCA fixes exactly that. The seller clears the goods for export and delivers them either at their own premises loaded onto the buyer’s collecting vehicle, or at another named place ready for unloading. Risk passes at delivery, and both parties know who was supposed to load.
What follows in practice
If you use FCA at the seller’s premises, the seller loads. If you use FCA at a named terminal, they do not. Name the place precisely, because the loading obligation and the risk transfer point both move with it.
For frozen goods, add the temperature clause separately. No Incoterms rule specifies a set point, pre-cooling or logger placement. FCA against CPT against DAP sets out where each rule leaves cold chain responsibility and what to write in the contract to close the gap.