Exporting to the UK from the EU: customs, origin and VAT

Key takeaways

The UK is outside the EU. Every shipment needs an export declaration in the EU country of departure and an import declaration in the UK, made in HMRC’s Customs Declaration Service.
You need an EU EORI number for the export. Whoever makes the UK import declaration needs an EORI number that starts with GB.
Zero UK duty only applies to goods with EU preferential origin, usually shown with a statement on origin on the invoice. Above 6,000 euros per consignment it must include your REX number.
Since 31 January 2025, goods moving from the EU to Great Britain must be covered by a safety and security declaration before they arrive.
You keep the zero VAT rate on the export only if you can prove the goods actually left the EU.

A Dutch manufacturer has shipped packaging machinery to a customer near Manchester for years. One month the customer receives a UK duty bill on a shipment that should have been duty free. The invoice carried no statement on origin, so HMRC charged the normal rate. The customer wants the money back from the supplier.

That argument almost always surfaces on the UK side, while the cause sits on the EU side. Exporting to the UK means two declarations in two countries, and the paperwork that decides the duty on the second one is yours to produce.

Below are the steps, who files which declaration and where shipments tend to go wrong.

What customs formalities apply when exporting to the UK?

Two declarations: an export declaration in the EU and an import declaration in the UK. On top of that, the shipment has to be announced to UK customs in advance.

The export declaration is filed with customs in the EU country the goods leave from, before departure. Without customs approval the goods may not be exported. Our guide to the export declaration walks through the steps.
The import declaration is made in the UK through the Customs Declaration Service of HMRC.
Both need an EORI number: an EU number for the export and one starting with GB for the UK import. If you do not have one yet, read how to go about applying for an EORI number in the Netherlands.

If the truck crosses through a port that uses the Goods Vehicle Movement Service, as most Channel ferry routes do, the driver also needs a goods movement reference. It bundles the declaration numbers of the load. Without it the truck cannot get through the port and the shipment is delayed.

Who makes the UK import declaration?

That depends on the Incoterm agreed with your customer. Under most terms the UK buyer handles the import. If you sell DDP, it is your responsibility, including UK VAT.

Filing the UK import declaration yourself requires a GB EORI number and a UK VAT number. A VAT registered UK importer can usually account for import VAT on its own VAT return through postponed VAT accounting, so it does not pay the VAT up front at the border.

Settle this before the first quote goes out. A DDP price without a UK VAT number is a promise you cannot keep. Our overview of Incoterms 2020 helps you pick the term that fits.

How do you avoid UK import duty under the rules of origin?

By showing that the goods have EU preferential origin. Under the Trade and Cooperation Agreement between the EU and the UK, such goods enter at zero duty. An EU product is not automatically duty free, though: it has to meet the origin rules of the agreement.

The UK importer can claim the preference in one of two ways.

With a statement on origin that you, the exporter, make out on the invoice or another commercial document. For consignments above 6,000 euros, your REX number must appear in the statement.
With importer’s knowledge: the importer holds the information that proves origin itself. That asks more of the importer, and therefore of you.

One statement on origin can cover multiple shipments of identical products to the same customer for up to twelve months. As the exporter you keep the statement and the evidence behind it, such as supplier declarations, for four years. If the statement is missing at import, HMRC allows the importer to claim the preference up to three years after import and get the duty repaid. The difference between EUR.1 and REX is explained in our article on the certificate of origin.

What is the UK safety and security declaration?

An advance notice of the shipment to UK customs, with details of the consignor, the consignee and the goods. Since 31 January 2025 it is required for all goods imported from the EU into Great Britain.

The carrier or haulier usually files it. They need your data to do so, and that data has to match the export declaration and the invoice. Agree who files the declaration and when you hand over the details. A truck that arrives without a valid declaration is likely to be held up at the border.

How do you keep the zero VAT rate on the export?

With proof that the goods left the EU. A supply to the UK is an export, which is zero rated for VAT, but only if you can show the goods exited. The exit confirmation linked to your export declaration is the strongest proof you can have.

This is where EXW causes trouble. If the UK buyer arranges the transport and the export, you often never receive that confirmation, and at an audit the tax authority can charge VAT on the sale after all. If you sell EXW, agree that the buyer sends you the proof of exit, or choose a term under which you file the export declaration yourself.

What applies to food, plants and animal products?

These goods face extra UK rules on top of the customs declarations, phased in through the Border Target Operating Model.

Agrifood products must be pre-notified in the UK system IPAFFS. The UK importer does this.
High risk plants and plant products need a phytosanitary certificate, which the EU exporter obtains.
Animal products often need a health certificate and can be checked on arrival.

Which rule applies depends on the risk category of the product. The rules are still changing, so check them per shipment on GOV.UK or with the plant and food authority in your own country. Northern Ireland follows different rules from England, Scotland and Wales.

If the goods first travel under customs supervision to a clearance point further inside the UK, a transit document can cover that leg. The UK is a party to the Common Transit Convention. Our article on T1, T2 and T2L documents explains how that works.

Frequently asked questions

Q: Will my UK customer pay import duty on my products?

Ans: Not if the goods have EU preferential origin and the origin is properly shown, for example with a statement on origin on the invoice. Then the rate is zero. If they do not meet the origin rules, HMRC charges the normal UK rate for that commodity code.

Q: Do I need a GB EORI number?

Ans: Only if you make the UK import declaration yourself, for example when you sell DDP. If your customer handles the import, they need the GB EORI number and your EU number is enough for the export declaration.

Q: When do I need a REX number?

Ans: When the total value of a consignment of EU originating goods exceeds 6,000 euros and you prove origin with a statement on origin. The REX number then goes into the statement on the invoice. Below that threshold the statement can be made without it.

Q: How long does customs clearance for the UK take?

Ans: With complete documents the export declaration in the Netherlands is done within hours. Delays usually happen on the UK side, because of a missing safety and security declaration, a vague description of the goods or extra checks on food and plants.

Q: Can I outsource the export declaration for the UK?

Ans: Yes. A customs broker files the export declaration, arranges a transit document where needed and lines up the data with the carrier and the UK side. You sign an authorisation once.

Shipping to the UK and want the EU side right first time? As an AEO certified customs broker we handle export declarations and transit documents, check the origin details on your invoice before the goods leave and work weekends and nights too. Have a look at our customs services or sign the authorisation and we take it from there.