Exporting to the UK After Brexit: A Guide for EU Suppliers Selling to UK Businesses

Exporting to the UK after Brexit means every shipment crosses a customs border: you make an export declaration in the EU, and your UK customer, or whoever acts as importer, makes an import declaration and pays any duty and import VAT. The paperwork is manageable once you know who does what. The two decisions that matter most are the Incoterm you quote and whether your goods can use preferential origin.

This article is general information, not legal, tax or customs advice.

What changed for EU suppliers exporting to the UK?

When exporting to the UK, remember that goods moving from the EU to Great Britain are imports on arrival. The UK government's step by step guide to getting UK customs clearance sets out the import side: the importer needs an EORI number starting with GB to import into England, Wales or Scotland, submits an import declaration (or hires a transporter or customs agent to do it), and HMRC then says how much duty and VAT to pay.

On your side, an export declaration is made in your own EU country using your EU EORI number. Our guide to the EORI number explains how that works.

GB EORI and XI EORI: which one do you need?

The UK has two kinds of EORI number. HMRC's guidance on who should register for an EORI number says businesses established in the UK register for a GB EORI, and those established in Northern Ireland for an XI EORI. Goods moving to or from Northern Ireland may need an XI number.

A business not established in the UK can only get a GB EORI for certain activities, such as some summary or transit declarations. If you do not qualify, you can appoint someone to handle customs for you. HMRC notes that this person needs their own EORI, and that having no EORI does not stop you trading if you use an indirect representative.

Border Target Operating Model and safety declarations

The Border Target Operating Model is the UK's framework for import controls. It brings safety and security controls on all imports, plus sanitary and phytosanitary checks on live animals, animal products, plants and plant products. According to the model, most EU and EFTA goods were categorised as low risk. Since 31 January 2025, a safety and security declaration has been needed for imports from the EU. The government's preparation guidance is aimed mainly at carriers and hauliers, so agree with your forwarder who files it.

UK import VAT: who pays and how?

The importer pays import VAT as well as any duty. For a VAT-registered UK customer, the simplest route is postponed VAT accounting. HMRC's page on accounting for import VAT on your VAT Return explains that businesses can use it for goods imported into Great Britain without any approval, but they must be registered for VAT in the UK.

Two details matter for anyone exporting to the UK:

• The import is reported on the importer's monthly postponed import VAT statement, so the customer declares and deducts the VAT in the same return.
• Since an update in June 2025, a freight forwarder or customs agent must have written permission from the importer before using postponed VAT accounting on a declaration.

If your customer will be the importer, ask them to give their forwarder that permission in advance. It avoids delays at the border and an upfront VAT payment.

DAP or DDP when exporting to the UK?

The Incoterm decides who acts as importer, and under DAP, you deliver to the agreed place and the buyer handles import clearance, duty and VAT. Under DDP, you take all of that on. Our guide to Incoterms 2020 covers the full split of costs and risks.

Why DDP needs more preparation

Quoting DDP means you become responsible for UK import formalities. HMRC's internal guidance on goods imported by or on behalf of non-UK traders notes that overseas persons making supplies in the UK may need to register for VAT and may appoint representatives to act for them. Before you offer DDP on exports to the UK, check whether you would need a UK VAT registration and who would act as your representative.

For many B2B shipments, DAP is the more practical starting point. A VAT-registered UK buyer can use postponed VAT accounting and keeps control of its own import declaration.

UKCA or CE marking for products you export to the UK

For many products you export to the UK, the CE marking still works in Great Britain. The government's guidance on using the UKCA marking says the UK continues to recognise CE marking alongside or instead of UKCA, under the Product Safety and Metrology (Amendment) Regulations 2024, and that businesses can choose which route to use.

There are exceptions with their own rules, notably construction products and medical devices. If you sell promotional electronics, display lighting or other regulated products, check the product marking table in the guidance before assuming CE is enough.

Preferential origin for exports to the UK

Under the EU-UK Trade and Cooperation Agreement, goods that meet the rules of origin can enter the UK with preferential tariff treatment. The European Commission's page on proof of origin explains that the exporter can make a statement on origin, which requires registration in REX for consignments above EUR 6,000. Under this agreement the UK importer can also claim the preference based on its own knowledge.

Either way, exporting to the UK at a preferential rate needs the correct commodity code and evidence that the product meets the rule for that code. Our guides to EUR.1 and preferential origin and to HS codes explain the steps.

A checklist before exporting to the UK

1. Agree the Incoterm, and say clearly who acts as importer.
2. Confirm the commodity code and whether the goods qualify for preferential origin.
3. Ask for the customer's GB or XI EORI and whether they use postponed VAT accounting.
4. Check product marking: CE, UKCA or a sector-specific rule.
5. Agree with your forwarder who files the safety and security declaration.

When UK businesses send requests on Flobid, the quote form starts with DAP as the default Incoterm, which keeps import formalities with the buyer unless you agree otherwise. If you supply promotional goods, you can see what buyers ask for in categories such as promotional merchandise.

Sources

1. Get UK customs clearance when importing goods into the UK: step by step, GOV.UK
2. Who should register for an EORI number, HM Revenue and Customs, GOV.UK
3. The Border Target Operating Model: August 2023, Cabinet Office, GOV.UK (2023)
4. Preparing for the new safety and security declaration requirements, HM Revenue and Customs, GOV.UK
5. Check when you can account for import VAT on your VAT Return, HM Revenue and Customs, GOV.UK
6. IMPS03320: Import entry procedures: goods imported by or on behalf of non-UK traders, HM Revenue and Customs, GOV.UK
7. Using the UKCA marking, GOV.UK
8. Proof of origin, European Commission, Taxation and Customs Union