EU Exit

Do you know the rules you need to follow for things like exports, imports, tariffs, data and hiring?

If you need support, see the below resources or call 01494 927130, email or click below to book a chat with one of our Business Advisers.

EU Importing & Exporting

This is a very compressive guide (131 pages) as to how the border works with the EU for both Importing & Exporting. An updated version is due to be published in June/July 23. This will outline the new NI (Windsor Agreement) protocols and will also outline some of the UK government deferred EU regulations which will start being implemented from October 23. Finally, it will also outline a new targeted UK importing model from 2025.

Border Operating Model - GOV.UK (  

Businesses moving goods between the UK and EU require an Economic Operator Registration Identification (EORI) number from both the UK AND EU following Brexit. EORI numbers are unique numbers businesses use to identify themselves to customs authorities report in customs declarations and similar import or export documentation.

Without a valid GB or EU EORI number, your goods will not clear through customs.

For Northern Ireland an ‘XI’ EORI is also used.

Get a UK EORI for GB goods movements

If you are importing or exporting into the UK, you will need a ‘GB’ prefixed EORI number. HMRC issued these in 2019 to all the businesses it believed would require one. GB EORI numbers are made up of:

  1. 'GB' prefix
  2. Your UK VAT number
  3. Usually '000' after that

If you have not already received one, contact HMRC. EU businesses may also now apply for one to cover the UK imports.

Apply for EU EORI for Imports and Exports

UK businesses now need an EU EORI number to import or export from the EU 27 member states. A single number for the whole of the EU may be obtained from any EU member state’s tax authority. Usually this may only be done with a non-resident VAT number application at the same time. Note, UK importers and exporters into the EU will need a customs intermediary and use their EORI number. This is because they are now non-resident within the EU Customs Union.

What is the Customs Declaration Service (CDS)?

The Customs Declaration Service (CDS) is HMRC’s new digital platform which supports businesses making import and export declarations when moving goods into and out of the United Kingdom.

How can I register for CDS?

You can subscribe to CDS to submit an import or export declaration via the government website here: You will also be able to create a new direct debit mandate for your Duty Deferment Account (as applicable) following your registration via the CDS Finance Dashboard. This CDS Finance Dashboard also contains important data and documents such as Duty Deferment/Postponed VAT Accounting statements (detailing any postponed import VAT), and C79 certificates (as applicable).

Who needs to use CDS?

All businesses submitting import customs declarations can do so via CDS. All export declarations should be submitted via CDS from 30 November 2023 to carry on exporting from 1 December 2023, when the old system Customs Handling of Import and Export Freight (CHIEF) is due to close.

Do all importers/exporters have to register for CDS?

Yes, all importers, exporters and declarants should register for CDS. All goods imported into the UK or exported out of the UK require a customs declaration.

Can I do my own customs declarations?

Yes, you can submit your own customs declarations directly to HMRC’s CDS system although you will require specialist software that can submit declarations to do this. To make things simpler, Deloitte has built CustomsClear which allows you to submit declarations directly to HMRC for just £15 per declaration and only answering those questions that are relevant to your declaration. Register here for CustomsClear:

How do I submit an import or export customs declaration via CDS?

There are three main options for submitting your customs declarations. These are:

  • submitting them yourself using software such as CustomsClear. This is usually the most cos-effective solution and means the process will be managed in-house, so you have complete oversight of the process and excludes the use of an intermediary.
  • a freight forwarder/haulier can usually create and submit declarations on your behalf when they move your goods.
  • a customs broker/agent is a third party that can create and submit declarations on your behalf.

The following links help outline the import and export declaration process:

See below for a more detailed explanation of each key document:

Export declaration

This needs to be submitted to, and approved by, the customs authorities before your goods leave the country. Your carrier should be able to take care of this using the information from your paperwork.

Commercial invoice

Must make sure you have a commercial invoices and that you fill it in correctly. This includes a clear goods description and the value of your goods.

This is a very important document – effectively the biography of the package

It must state:

Price, Value, Quantity, Description, Currency, Country of Origin, Declaration of Origin, Commodity Codes & EORI’s x 2 (GB & EU)

It is required to enable goods to clear Customs.


Used by the shipper and the importer, for UK and foreign customs.

Consignment note (Air waybill)

You’ll also need a consignment note. This outlines key details about your shipment such as the number of items, a goods description and weight.

Packing list

It’s worth including a packing list with your shipment as some countries require it. To be extra careful, you could also place one inside your package.

Remember, a packing list and a commercial invoice are two different documents. A commercial invoice includes the price while a packing list outlines the details of the goods like the weight and quantity.

Export license

An export license is a document issued by government bodies allowing registered companies or individuals to legally ship goods that are otherwise restricted. It’s important to check if you need one well in advance of shipping.

Certificate of origin

The certificate of origin is an official document that states where a product was produced, manufactured or processed. Remember to check in advance if you need one.


All your shipping documents need to be handed over to your carrier's driver when they come to collect your parcel or shipment. Once the driver returns to the carrier’s station, the paperwork will be checked to see if everything is in order. If the paperwork is incomplete, they’ll hold your shipment and you’ll be contacted. Ensure the information on each document is consistent. The details on your air waybill, commercial invoice and all other documents should be the same. If it’s not consistent, customs will ask for more information and your customer might have problems receiving your shipment.

Using international commercial terms ensures properly written contracts

If you are an exporter, you need to make sure shipping and delivery responsibilities are written down and clearly understood. Using international commercial terms (known as incoterms) in contracts can help you do this.

Incoterms are a set of internationally recognised 3-letter trade terms. They describe the practical arrangements for the delivery of goods from sellers to buyers and allocate the obligations, costs and risks between the 2 parties. They are produced by the International Chamber of Commerce (ICC) and updated periodically to reflect changing trade practices.

Elements of a contract

When you are negotiating a contract with a buyer, you'll need to discuss and agree:

  • where the goods will be delivered
  • who arranges transport
  • who handles and pays for insurance
  • who handles customs procedures
  • who pays any duties and taxes

Incoterms are used to ensure these responsibilities and handovers are clearly defined and agreed.

Commonly used incoterms (effective from 1/1/2020) – 11 in total

  1. Ex Works (EXW)
  2. Free Carrier (FCA)
  3. Free Alongside Ship (FAS)
  4. Free on Board (FOB)
  5. Cost and Freight (CFR)
  6. Cost, Insurance and Freight (CIF)
  7. Carrier and Insurance Paid to (CIP)
  8. Delivered at Place Unloaded (DPU)
  9. Delivered Duty Paid (DDP)

Visit the International Chamber of Commerce website for more information.


The Department of Business & Trade announced on 1/8/23 the indefinite CE mark recognition beyond the previous December 2024 deadline. It is expected that the extension will cut business costs and time required to place products on the market and hence benefit consumers.

The UK left the EU single market at 11PM on 31st December 2020. The United Kingdom Conformity Assessed or UKCA mark is being phased in from 1st January 2021 to replace the CE mark in Great Britain, although for most goods the CE mark will remain acceptable for a transition period ending on 31 December 2024. 

What does the UKCA mark mean?

The UK Conformity Assessed mark is a mandatory mark on a product to indicate that it conforms to GB legislation. The manufacturer or, if mandated, their authorised representative will be responsible for affixing the UKCA mark to the product, which is the same principle as CE marking but for the GB market.

Will the CE mark remain valid for products placed on the UK market?

For most products placed on the GB market, the CE mark will only remain valid until 31st December 2024. Some exceptions are Medical Devices and Construction Products and information has been published on the website for these.

What are the differences between UKCA and CE marking?

In technical terms, the differences between the requirements for CE marking and for UKCA marking are slight. Products which meet the technical requirements for one will mostly meet the requirements for the other for the foreseeable future. Most of the differences between the two systems are administrative in nature and reflect the fact that the UKCA mark only applies in Great Britain.

Other differences relate to the separation of UK conformity assessment bodies from the EU Notified Body system, described below.

What aspects are not changing?

For the moment, many facets are the same; the scope of products covered, technical requirements (essential requirements, standards) and conformity assessment procedures are all initially identical for the two different markets. If your product is sold in both the EU and the UK, the technical file to show that it meets these requirements will also be the same.

Will UKCA marking apply throughout the UK?

No, UKCA marking applies only in Great Britain (comprising England, Scotland and Wales), so it may be helpful to think of it more as a GBCA mark. CE marking continues in Northern Ireland, which remains aligned with the EU single market for goods. Products that are to be placed on the market in both GB and NI therefore need both UKCA and CE marking unless they are "Qualifying Northern Ireland Goods" in which case they can be sold in GB with a CE mark and do not need a UKCA mark.

How will UKCA marking impact Northern Ireland?

Products placed on the market in Northern Ireland must be CE marked, regardless of their origin. Products placed on the market in Great Britain must be UKCA marked, regardless of their origin with one exception: businesses in Northern Ireland will be in the unique position of being able to ship Qualifying Northern Ireland Goods certified to either the EU (CE mark) or UK (UKCA mark) rules into Great Britain.

Can I put both CE and UKCA marks on my products?

Yes, provided they fulfil the associated requirements. It is already common to see multiple conformity marks on internationally sold products. 

What is the specific UK legislation that needs to be followed?

To implement the new regime, the UK government has issued several Statutory Instruments to amend current legislation. The amendments are limited to:

  • replacing the CE mark with the UKCA mark, 
  • limiting applicability to products for the UK market, 
  • changing references to Notified Bodies to Approved Bodies, 
  • changing language references to English. 

What needs immediate action?

  • If you are based in (and selling into) the UK and your products are already properly CE marked then the only action you need to take before 2025 is to ensure that your UK name and address is on the product or its accompanying documentation.
  • If you are based outside the UK and you sell CE marked or UKCA marked products within the UK then in many cases you also need to identify a UK address (importer or Authorised Representative) on the product or its accompanying documentation.
  • If you relied on a Notified Body certificate from a UK based organisation before Brexit then you must get that certificate re-issued by an EU based Notified Body in order for your CE mark to remain valid. 
  • By the end of 2024, you will need to have updated the markings on products you sell within the UK to include the UKCA mark.
  • If your product requires EU Notified Body certification then you will also need a UK Approved Body certificate before you can legally UKCA mark it. 

From 1 January 2025, the address of the UK based manufacturer /importer / authorised representative must* be permanently marked on the product, and not just on the documentation or in the form of a sticky label on the product.

10 digit code which identifies the goods.

  • 1st 6 digits are common internationally
  • Last 4 digits can change between different countries

The commodity code should be clearly seen on the invoice.

The company shipping the goods needs to determine the Commodity Code.

Look up the Commodity Code listing on Gov.UK

If unclear what the code should be eg for manufactured item, then apply for Customs ruling. Will need to supply evidence eg invoices, marketing literature. Can argue and challenge and prove what you think it should be.

Ruling has to be made before goods can be shipped – allow weeks.

  • For the purposes of international trade, all goods are classified under the Harmonised System, an internationally standardised system of descriptions and numbers to identify goods. You need to know the classification of your goods to find the applicable rule of origin.
  • The Harmonised System forms the first 6 digits of the 10-digit classification (commodity) code when importing goods into the UK or the EU.
  • Goods are categorised into chapters (2 digits), headings (4 digits), and subheadings (6 digits)

Therefore the Harmonised system the commodity code and the rules of Origin are all linked. (see presentation within Rules of Origin below)

  • Rules of Origin determine the ‘economic nationality’ of a good. They are a standard part of free trade agreements (FTAs).
  • Rules of Origin in the UK-EU Trade and Cooperation Agreement ensure that only goods produced in the UK or EU benefit from the zero tariff agreement.
  • Different goods must comply with different rules. This presentation sets out the types of rules products may need to comply with as well as the documentation required to comply.

Please see the following presentation which outlines rules and process in more detail.

If you move goods in or out of Northern Ireland the Trader Support Service will guide you through any changes due to the implementation of the Windsor Framework. If you have not already prepared for these changes, you may not be able to move your goods.

The Trader Support Service can help your business adapt to the changes. The service is free to use and:

  • offers comprehensive education, training and advice about the changes to the way your goods move under the Windsor Framework
  • can complete customs and safety and security declarations on your behalf where these are required for movements between Great Britain (England, Scotland and Wales) and Northern Ireland so you do not have to access HMRC systems directly.

You can use the Trader Support Service if you:

  • are moving the goods yourself
  • act on behalf of someone if for example you are a haulier

If you’re not already prepared for these changes, you are encouraged to sign up now using the Trader Support Service website. (HMRC has chosen the Trader Support Service to provide this service.)

Sign Up for this service via the webpage link below.

for further detailed reference - see Border Operating Model pages 51 & 52)

Returned goods – Generally Businesses are able to claim Returned Goods Relief (RGR) from customs import duty for goods that are exported from the UK and re-imported within three years of export. VAT relief also applies, providing that any VAT due has previously been paid in the UK, and the importer/exporter is the same person. Businesses would normally apply for RGR in the same way as they do currently which means filling out a full Customs Declaration. In order to, identify the goods as returning, the RGR Procedure Code should be used. This declaration should also reference the export declaration, and where the export declaration is not available, HMRC will consider alternative evidence which proves the goods were previously within the UK.

This used for goods that are temporarily going out of the country and will be returned , for example for an exhibition or event, or tools of trade.

It’s effectively a passport for these goods and alleviates the need for VAT or duty to be paid.

Application for a Carnet is via the Chamber of Commerce.

Takes 24 hrs (or same day for increased fee) and is valid for 12 months.


  • Issue Fee payable for Carnet issue.
  • Preparation fee (shipper)
  • Bond fee (% value of goods for 12 months, insurance or a non-refundable tariff)

Average costs in region of £385 + VAT so not ideal for low value items.

Will need identification of every item eg serial number. Number the items and identify which ones from the Carnet are being shipped each time,

Planning required – can be used for many trips per annum so good to use extensively before it expires. If planned return is later than 12 months, need to check with country regulations and Chamber of Commerce if this is possible.

ATA Carnets are not mandatory in any instance, but they can be vital in saving time and money if you are temporarily taking goods out of the UK. They can be used to take the following goods overseas: 

  • Professional equipment
    This includes goods such as camera equipment, music/concert equipment, equipment for educational, scientific or cultural purposes, sporting equipment, and manufacturing equipment
  • Commercial or scientific samples
    This includes any goods that you might want to take to show overseas customers or potential customers
  • Goods that you need for display or use at international trade fairs or exhibitions

Perishable, consumable and disposable goods cannot be listed on ATA Carnets. This includes items such as food, water, pens, pencils, leaflets, flyers, etc. Saleable goods such as band merchandise are also not permitted on ATA Carnets.

For more information useful links are below

Commercial or scientific with no commercial value.

This is still not clear how to import and export.

ATA Carnet is NOT the route due to costs.

£135 VAT threshold should be application for imports into UK but not exports to EU

May be same process as normal goods but with zero value on the invoice (or a nominal value on the invoice for customs purposes eg £1).

The government has provided a 6-point checklist for haulage drivers transporting goods commercially if they are driving from the UK to any international destination.

Worldwide Importing & Exporting

The UK Global Tariff (UKGT) will replace the EU’s common external tariff, which applied until 31st December 2020. This follows a government consultation.

Use this online service to check the UK Global Tariff that will apply to goods you import from 1st January 2021. You can also check the difference between what you pay now and what you’ll pay as of 1st January 2021.

Please note: Any business looking to import and export to the EU will need to have an EORI (Economic Operators Registration and Identification) number. Find out more and get one here >

Read more about UK tariffs from 1st January 2021 >

Please refer to for more in depth details on the new trade agreements

  • Australia December 21
  • New Zealand Feb 22
  • Singapore Feb 22
  • CPTPP (Trans-Pacific) July 23

UK-India Free Trade Agreement Consultation

The UK and Indian governments have agreed a ‘2030 Roadmap’ which will provide a framework for UK-India relations across health, climate, trade, education, science and technology, and defence.

The Department for International Trade (DIT) has launched a 14-week public consultation, running until the end of August, to gather views from a broad range of participants regarding experiences of doing business with India.

DIT says that: “This public consultation provides stakeholders with the opportunity to express their views about a UK-India free trade agreement, which will help shape government policy positions and ensure a future trade deal benefits citizens and business in every region of the UK.”

You can submit your responses via the online questionnaire here. For any enquiries, email:

Importing & Exporting - Support /Programmes/Helplines

The Customs & International Trade Helpline with advisor support can be contacted on 0300 322 9434.

They'll help you with importing, exporting and customs reliefs. The helpline is open from 8am to 10pm Monday to Friday and from 8am to 4pm at weekends.

The General Export Facility (GEF) provides partial guarantees to banks to help UK exporters gain access to trade finance facilities.

Exporters will be able to apply for finance from the UK’s five largest banks backed by a UK Export Finance (UKEF) guarantee to free up working capital that can be used for everyday costs linked to exports and to scale up their business operations.

Learn more here >

When it comes to exporting goods overseas, what you need to do and the rules you need to abide by depend on whether you’re exporting:

to the EU

outside the EU

Learn more information about exporting good overseas.

Selling digital services in the EU

Follow the rules for tax if you sell digital services in the EU, for example, downloadable videos, music, ebooks or software.

The Department for International Trade have provided this useful list of actions for UK exporters to EU and rest of world.

UK Global Tariff - new import tariffs from 1st January 2021

Tariffs applied to UK imports have changed as of 1st January 2021.

The UK Global Tariff (UKGT) replaces the EU’s common external tariff, which applied until 31st December 2020.

Use this online service to check the UK Global Tariff that will apply to goods you import from 1st January 2021.

Importing - what are the rules you need to follow?

If your business imports goods from overseas, what you need to do and the rules you need to abide by depend on whether you’re importing

within the EU

outside the EU

Learn more information about importing goods from overseas.

Importing services from outside the UK

There are different rules if your business buys services from outside the UK.

An online tool launched by the Department for International Trade aims to make it easier for businesses to trade globally.

The tool enables businesses to report issues and problems which prevent them from trading globally, such as legal, regulatory or administrative requirements that slow down or prevent a business exporting or importing.

Once an issue or problem has been reported, trade experts will assess the problem and work with other governments around the world to resolve it.

Learn more about the tool and how to report trade barriers >

HMRC has an EU Exit Import and Export Trader Helpline for traders and hauliers importing from and/or exporting to the EU.

The helpline number is 0300 3301 331. Lines will be open from 8am to 6pm, Monday to Friday.

As of 1st January 2021, all businesses that move goods between Great Britain and countries in the EU, or under the Northern Ireland Protocol, must follow new customs and tax rules. HMRC can help you understand what the changes mean for your business.

Read this article where they share the answers to some of the most frequently asked questions and provide links to where you can find more information and support.

The Department for International Trade has a digital tool that helps UK businesses understand the rules, restrictions and tax and duty rates that may apply when they export goods internationally.

You’ll need to know what your product is made of to get the correct information about how to export it.

Access the tool here >

What is the Export Support Service (ESS)?

The Export Support Service is a new helpline and online service where all UK businesses can get answers to practical questions about exporting to Europe.

The service is a ‘one-stop shop’ and brings together UK government information, making it easier for exporters to access advice and support.  

British businesses exporting to Europe will now be able to access one-to-one advice via the new phone and online service.

From queries around rules of origin, to guidance on recognising professional qualifications and entering new markets, the Export Support Service will provide a single point of contact. It will help exporters navigate a range of complex information simply and quickly. 

The helpline and digital enquiry service launched on 1 October 2021.

Key details about the service

  • The Export Support Service is a new government helpline and online service where all UK businesses can get answers to practical questions about exporting to Europe.
  • It gives access to cross government information and support all in one place.
  • If you are a UK business you can use this free service, no matter the size of your business or which part of the UK you are based.
  • DIT will continue to work with businesses and business representative groups from all sectors, in all parts of the UK, to help make the service as useful as possible for businesses. 

You can access the Export Support Service at GOV.UK/ask-export-support-team or by calling 0300 303 8955 where you will be put in touch with a member of the dedicated export support team.

The service comes ahead of the upcoming launch of the government’s Export Strategy. The strategy will promote UK business’s ability to seize the opportunities to sell goods and services around the globe.

Here’s a guide with more details: Export Support Service for UK businesses.

No governmental grants for importing /exporting support to EU are available at this time for SME’s.

Horizon Europe Guarantee scheme is newly extended to end of Sept 23 to support UK R&D – see link below:

Horizon Europe funding - GOV.UK (


HMRC/ Financials

Essential guide to VAT and duty on imports and exports

Whether you are importing or exporting, there are important VAT and duty rules and procedures. You must ensure that you charge (or pay) the right amount of VAT. If you are importing, you may also need to pay import duty.

VAT and duty rules and procedures changed at the end of 2020.

Check your responsibilities for imports

  • You are normally responsible for clearing the goods through UK customs and paying any taxes.
  • Your supplier needs to provide the documentation you need to clear the goods through customs (and to make payment to the supplier).
  • You may have to pay import duty.
  • Your responsibilities depend on what you have agreed in the contract. To minimise the risk of disputes, your contract should use one of the internationally recognised Incoterms.

Check your responsibilities for exports

  • You are normally responsible for clearing goods outwards through UK customs.
  • Your customer is normally responsible for overseas customs clearance and taxes. You can find out more about how other countries handle import duties and taxes from the Department for International Trade.
  • You need to provide your customer with the documentation they need to clear goods into their country (and to pay you).
  • Your responsibilities depend on what you have agreed in the contract. To minimise the risk of disputes, your contract should use one of the internationally recognised Incoterms.

Decide whether to use an agent to handle your responsibilities

  • Freight forwarders can handle customs clearance as well as transport.
  • Exporting can be simpler if you choose to sell to a single agent or distributor in an overseas country. However, this may not suit your export strategy.

Make sure you can handle the bookkeeping

  • Many business accounting packages will offer the basic functionality you need for trading internationally. For example, dealing with VAT on imports and exports.
  • Check what other features you need. For example, you may want software that can handle multiple currencies, or the option to integrate with an international payments solution.

Check what UK VAT rate applies to the goods

  • Exports are usually zero-rated. You must keep proof that the goods have been exported.
  • There are exceptions where exports are not zero-rated. You can check the details with your trade association, local chamber of commerce or HMRC.

Check what paperwork you need

  • You or your representative (for example, a freight forwarder) must declare the export.
  • You need to provide your customer with the documents they need to import the goods into their country. Providing these documents can also be part of the process of getting paid.
  • As a minimum, you will need documents recording the exporter (yourself), the customer, the goods and their value, the export destination, how the goods will be transported and the route they will take.
  • Keep copies of documents giving details of all the sales you have made.

Take care of any responsibility you have for overseas customs clearance and taxes

  • Normally you will have agreed that your customer handles this. Take specialist advice, or use an expert agent, if you are responsible.

Since Brexit, exports to the EU are treated in much the same way as exports to any other country

  • Exports are generally zero-rated for VAT and have to be declared.
  • EU VAT is payable on the goods when they enter the EU.
  • From July 2021, UK businesses may be able to take advantage of the EU Import One-Stop Shop for sales to consumers worth under €150. You deal with the import VAT, making life easier for your customer.

There are special rules for Northern Ireland

  • The VAT treatment of exports from Northern Ireland to the EU is different. Exports from Northern Ireland to the EU do not have to be declared.
  • Exports from Northern Ireland to countries outside the EU are treated in the same way as exports from Great Britain.
  • Goods going from Great Britain to Northern Ireland have to be declared. Tariffs may be payable if the goods are ‘at risk’ of entering the EU (for example, by being sold on to customers in the Republic of Ireland).
  • Some of the arrangements are changing over 2023-2025 under the Windsor Framework agreed between the UK and the EU.

Check what import duty applies

  • Import duty is based on the type of goods you are importing, the country they originate from and their value.
  • There is no import duty for most imports from EU countries.
  • Any duty must be paid before the goods are released by customs, unless you have opened a deferment account with HMRC.
  • HMRC's Integrated Tariff sets out the classification of goods and the rates of duty in detail.
  • Your trade association or your import agent may be able to advise you.

Confirm what paperwork you require from the supplier for customs clearance

  • This normally includes an invoice and a copy of the transport documents.
  • You may need proof of the origin of the goods to claim reduced import duty for goods from certain countries.
  • A valuation document is also normally required for imports above a set value.

Make arrangements to handle customs clearance

  • Smaller importers often find it easier to have an agent handle customs clearance for them.

Make arrangements for VAT

  • VAT on imports is generally charged at the same rate as is used within the UK.
  • You can usually account for import VAT on your VAT return. This means you do not need to pay the VAT upfront and then recover it.
  • You must have an 'EORI' number and include your VAT registration number on any customs declaration.
  • If you are not registered for VAT, or the goods are not for business use, you have to pay import VAT and cannot reclaim it.

There are special rules for Northern Ireland

  • VAT is handled differently on goods imported into Northern Ireland from the EU.
  • In some cases, goods going from Northern Ireland to Great Britain may need to be declared.

Check whether any goods you are buying are subject to excise duty

  • Excise duty is charged on fuel, alcohol and tobacco products.
  • Excise duty is charged on imports from the EU as well as imports from countries outside the EU.
  • If goods are subject to excise duty, you pay this at the same time as you pay VAT and import duty.
  • VAT is charged on the value of the goods plus excise duty.

Consider using a customs warehouse if you expect to store imports for a long time

  • If you store goods in a customs warehouse, you will not need to pay import duty and VAT until you want to remove the goods from the warehouse.
  • Storage 'in bond' like this is often used for products subject to excise duty, such as wine and cigarettes.

Find out about possible tax relief if you are planning to re-export goods you import

  • You may be able to take advantage of special inward processing relief rules so that you do not have to pay import duty and VAT.
  • This relief can apply to imports that you process before re-exporting them.

If you import or export regularly, find out about alternative procedures

  • For example, businesses that import regularly and in large volumes can use processes such as Customs Freight Simplified Procedures.

Take expert advice on your own circumstances

  • HMRC can provide information on duty and VAT issues.
  • Other sources of information and advice can include international trade advisers at your trade association or your local chambers of commerce.

VAT OSS & IOSS rules and procedures - on the 1st of July 2021, new VAT ecommerce rules came into force, which means you or your accountant may need to register your business for the new VAT OSS (One Stop Shop) scheme or VAT IOSS (Import One Stop Shop).

These schemes only apply to businesses that are selling or plan to sell B2C goods or services cross-border. So, if you’re only selling B2B, these changes won’t affect you directly.

What is the VAT One Stop Shop (OSS)?

The OSS is an extension of the old Mini One Stop Shop (MOSS) scheme and it simplifies the VAT obligations for businesses selling goods and services to final consumers (B2C) in the EU.

Registration will enable suppliers to declare cross-border B2C supplies of services and intra-Community distance sales of goods in the EU. This means that businesses will only register for a VAT number in one country rather than in all the countries where the sales are made, making VAT declarations easier and quicker.

This also means that distance selling thresholds will no longer apply from 1 July 2021. (Distance sales occur when goods are dispatched to a private consumer in another EU Member State, and the supplier is responsible for the delivery of the goods).

VAT OSS will apply if:

  • You are were registered for VAT Mini One Stop Shop (MOSS).

If you’re still using the VAT MOSS Scheme, your registration will continue under the VAT OSS Scheme but you may need to update your information if you make other supplies covered by VAT OSS. Speak to your accountant if you need your information updated.

  • You carry out EU cross-border supply of services and/or goods on a Business to Consumer (B2C) basis to a Member State where your business is not established.

This is called Union Scheme registration and it means that you won't need to register for VAT in each country that sales are made.

  • You have no business establishment or fixed establishment in the EU and you carry out B2C supplies in the EU.

Suppliers eligible to register for this scheme, i.e. those that are not established in the EU, will be able choose to register in any Member State.

Services that apply to VAT OSS

VAT OSS applies to digital services and other exceptional services that don’t follow the general place of supply rules. In general, the place of supply rules for B2C supply of services is where the supplier is based.

Revenue has a list of services that are exceptions to that rule and these services can be included in the VAT OSS scheme. For instance, the transportation of passengers, services connected with immovable property, and the hosting of events are considered exceptions and can apply to the VAT OSS scheme.

VAT OSS Registration

There is Union scheme registration for suppliers established in Ireland or holding goods in Ireland and non-Union scheme registration for non-EU established suppliers of B2C services.

Both registrations are carried out on Revenue’s Online System (ROS) but different information may be required. For example, for non-Union scheme registration, you must confirm that you are not registered for the non-Union scheme in any other Member State and confirm that you have no establishment in the EU. During the Union scheme registration, your application will be prepopulated because Revenue already has your basic details but certain elements will need to be edited for the purposes of OSS registration.

VAT OSS Returns

When your business is registered, VAT OSS returns are due on a quarterly basis, and it is separate from a domestic VAT declaration.

What is the VAT Import One Stop Shop (IOSS)?

  • The Import One Stop Shop (IOSS) is the electronic portal that allows businesses to report on distance sales of goods imported from outside the EU, and it ensures compliance with VAT ecommerce obligations.

  • It is a simplified reporting model where you register in one location for the sales you make to EU consumers in the 27 EU member states.

  • Under this new scheme, VAT will be due on all goods imported into the EU with an intrinsic value not exceeding €150, i.e. the value of the goods alone, not including insurance, customs, etc. This means that the low-value consignment VAT relief threshold for goods under €22 is abolished.

  • If you register for this scheme, VAT can be charged at the point of sale to the customer and you can declare and pay this VAT via a monthly IOSS return.

  • The import is then treated as exempt from VAT if you quote a VAT IOSS number on the customs declarations. The tax authorities will compare the exempt imports linked to your VAT IOSS number with the IOSS returns that are submitted.

  • VAT IOSS doesn’t apply to excisable products, such as alcohol or tobacco, and also note that it is not mandatory to register for this scheme.

  • You are required to display the amount of VAT paid by the buyer in the EU, by the time the ordering process is finalised (at the latest). You will need to produce an invoice showing the price paid by the buyer in EUR, this will need to be provided alongside your IOSS number during the customs declaration process. This allows the import VAT to be exempt when the goods pass through customs. You then report the VAT you collected at point of sale in the new monthly IOSS returns.

VAT IOSS will apply if:

  • You sell goods B2C with a value not exceeding €150.

VAT will be due on all goods imported into the EU with an intrinsic value not exceeding €150, i.e. the value of the goods alone, not including insurance, customs, etc.

  • The goods are imported from outside the EU.

This scheme moves the taxing point to the point of sale not the point of importation so VAT will be charged at the point of sale to the customer, and you declare and pay this VAT via a monthly IOSS return.

VAT IOSS Registration

Similar to the VAT OSS Scheme, registration for VAT IOSS is done through HMRC’s Online System (ROS).

Non-EU established suppliers (except for Norway) register for IOSS through the appointment of an intermediary. An intermediary is responsible for the payment of the VAT and the VAT IOSS registration will be carried out in the Member State where the intermediary has established its business. Note that Accountant Online can not act as an intermediary but we can help EU-established companies to register and file IOSS returns.

VAT IOSS returns

VAT IOSS returns and payments are due by end of the month following the reporting month and they are separate from domestic VAT declarations.


Is VAT due on all imports after 1 July 2021?

Yes, as of 1 July 2021 the EU ended its low-value consignment relief threshold of €22, which means all products going into the EU will attract VAT for either the buyer or the seller.

What is the significance of the €150 threshold on consignment value?

VAT is now due on all goods shipped into the EU but once the value of goods are above €150 there could also be duties that would be applicable on top of the VAT. There are many things, like the origin of goods, that could affect whether duty is required to be paid. 

If I am selling on a marketplace, do I need my own IOSS number?

If you only make sales through marketplaces then you will not be required to have your own IOSS number because it is now the marketplace’s responsibility to report the transaction to the end consumer. You will make an exempt sale to the marketplace and they will report the VAT. 

Many marketplaces are following the IOSS approach, if they choose this approach they will provide you with their IOSS number and produce the invoices you need to provide to your carrier to ship the goods

Is it mandatory to register for IOSS when selling to the EU?

No, IOSS is a simplified process that allows you to ship to all 27 EU member states through one singular registration. You can still continue to ship through the old DAP and DDP models (see next question) but if you choose to use IOSS then all transactions must be reported under IOSS going forward, there is no pick and mix.

Are businesses required to charge VAT when goods are sold from non-EU locations directly to consumers?

The answer is it depends on the model you are planning to use. There are currently two popular models but with the introduction of IOSS there is now a third.

  • Delivery At Place - You are not required to charge VAT to the customer as this will be borne by the customer before they are allowed to receive the goods.

  • Delivery Duty Paid (DDP) - Businesses usually charge but it’s not mandated to show the customer the charges when following this model

  • Import One-Stop Shop (IOSS) - Businesses must charge and show the VAT amount they are charging to the customer

How do I ship goods that have a consignment value of above €150?

Unfortunately IOSS does not cover the shipment of these goods so you will be required to use one of the previous models like DAP or DDP. 

Can I reclaim the VAT on returned goods in the new IOSS returns?

Yes, each country has a slightly different method on how these need to be reported but you can report this much the same as a usual return of goods on your IOSS returns.

Any product posted or couriered/delivered to you from another country goes through customs to check it is not banned or restricted and you pay the right tax and ‘duty’ on it.

This includes anything new or used that you:

As a result before receiving your goods, you may have to pay :-

  • VAT
  • Customs Duty
  • Excise Duty (if applicable for example Tobacco or Alcohol)

Please see link below for detailed information

As of 1st January 2021, all businesses that move goods between Great Britain and countries in the EU, or under the Northern Ireland Protocol, must follow new customs and tax rules. HMRC can help you understand what the changes mean for your business.

Read this article where they share the answers to some of the most frequently asked questions and provide links to where you can find more information and support.

HMRC has an EU Exit Import and Export Trader Helpline for traders and hauliers importing from and/or exporting to the EU.

The helpline number is 0300 3301 331. Lines will be open from 8am to 6pm, Monday to Friday.


A series of new, on-demand videos have been created by the Department for Business, Energy and Industrial Strategy (BEIS) to help businesses familiarise themselves with the new rules and the actions they should take.

Learn more about a range of topics including importing and exporting, trade with Northern Ireland, tariffs, hiring overseas staff, IP, data and accounting.

Sign up for webinars and watch videos about trading with the EU.

The UK is no longer part of the EU merger system as of 1st January 2021. Businesses considering a merger that will affect both UK and EU markets will need to comply with UK and EU merger rules.

Read the government advice on how merger reviews and investigations into anti-competitive activity will change from 1st January 2021.

Cross border mergers

Cross border mergers involving UK companies must be completed and registered before 1st January 2021.

Read the government advice on cross border mergers >

If you are travelling to Europe for work, such as attending a conference or providing a service, new rules now apply.

guide has been produced containing information on:

  • entry requirements
  • luggage allowances
  • earnings and tax
  • qualifications
  • insurance

Read the guide here >

You will need to check the rules for each of the European Member States that you will visit.

Common travel area rights are unaffected. If you are a British or Irish citizen you can work and live in the UK or Ireland without needing additional permission.

Please see guidance below from IPO which outlines the new landscape.

To contact the ICO helpline (Information Commissioner’s Office)

See link below.

Overview – Data Protection and the EU

About this guidance

On 28 June 2021, the EU approved adequacy decisions for the EU GDPR and the Law Enforcement Directive (LED). This means data can continue to flow as it did before, in the majority of circumstances.

Both decisions are expected to last until 27 June 2025.

The General Data Protection Regulation has been kept in UK law as the UK GDPR.

This guidance is aimed at UK businesses who receive data from, or have offices in the EU and European Economic Area (EEA). It gives a basic overview of the changes to data protection since the UK left the EU and now has an approved adequacy decision.

We have also produced more detailed guidance on Data Protection and the EU

Further Reading

Data protection and the EU in detail

For organisations

Check what you need to do to comply with new rules regarding employment and immigration.

As of 1st January 2021, free movement has ended and the UK will introduce a points-based immigration system. The new system will treat EU1 and non-EU citizens equally and transform the way in which all migrants come to the UK to work. Anyone coming to the UK to work, excluding Irish citizens, will need to apply for permission in advance.

Under a points-based immigration system, anyone coming to the UK for work must meet a specific set of requirements for which they will score points. Visas are then awarded to those who gain enough points.

The points-based system will provide simple, effective and flexible arrangements for UK employers to recruit skilled workers from around the world through a number of different immigration routes.

This represents a significant change for employers recruiting from outside the UK labour market, who will need to adapt.

This guide provides an overview of the new system and sets out the steps employers can take to prepare >

Employers can sign up to receive email alerts for the latest news on the new immigration system.

Guidance is available for employers carrying out right to work checks on EU citizens and their family members in the UK.

You’ll need to check a job applicant’s right to work in the same way as you do now up until 30th June 2021.

A new immigration system will apply to people arriving in the UK from 1st January 2021 and EU citizens moving to the UK to work will need to get a visa in advance.

Find out more information and guidance here.

EU citizens applying for a skilled worker visa will need to show they have a job offer from an approved employer sponsor to be able to apply.

If you’re an employer planning to sponsor skilled migrants from 2021, and are not currently an approved sponsor, you should consider getting approved now.

Learn more about becoming an approved sponsor.

European Union, European Economic Area (EEA) or Swiss citizens and their family members who are living in the UK before 1st January 2021 need to apply to the EU Settlement Scheme to continue living in the UK after 30th June 2021.

The government has produced a toolkit containing information with which employers can support EU citizen employees and their families with regards to the EU Settlement Scheme. The information can help employers to support EU citizen employees to apply to stay in the UK.

The toolkit includes:

an introduction to the EU Settlement Scheme for employers

details of eligiblity, the application process and deadline

template letters to EU staff



leaflets and posters

social media graphics and videos

translated materials

View the toolkit here.

The government has also produced a toolkit for community groups to support EU citizens and their families, which can be accessed here >