What changed for UK exporters

Since 1 January 2021, the UK is outside the EU Single Market and Customs Union. All goods exports from Great Britain to the EU now require customs declarations, and you must prove UK origin to benefit from the TCA's zero-tariff access.

This journey covers the key changes and how to benefit from the UK-EU Trade and Cooperation Agreement.

1. Get your GB EORI number

EORI for EU exports

Post-Brexit, you need a GB EORI (Economic Operators Registration and Identification) number to make customs declarations for EU exports. This is free and takes about a week to receive.

When required: Export/import between GB and any country (including EU)
Format (VAT-registered): GB + VAT number + 000 (e.g., GB123456789000)
Processing time: Immediate for most applications (unless HMRC requires checks)
Cost: Free
Consequences without: Delays at customs, increased costs, goods may be stored until obtained

Get an EORI number (opens in a new tab)

2. Make customs declarations for EU exports

How to declare goods for EU export, including the documents you need and common errors to avoid

Customs declarations are now mandatory

Pre-Brexit, goods moved freely to the EU with no customs paperwork. Now all exports require full customs declarations through the Customs Declaration Service (CDS). Many exporters use freight forwarders or customs agents.

When required: All exports to non-EU countries and most exports to EU
EORI number: GB EORI number required
Declaration system: Must use Customs Declaration Service (CDS)
Permission to Progress: Receive P2P message once customs clear the goods

Post-Brexit, export declarations are now required for goods moved from Great Britain to the EU. Your freight forwarder usually handles the technical submission, but you're legally responsible for the accuracy of information you provide.

Make an export declaration (opens in a new tab)

3. Prove UK origin for zero-tariff access

How to determine if your goods qualify as UK-originating under the TCA, and how to provide origin proof

Origin requirements for tariff-free trade

The TCA offers tariff-free trade, but only for goods that 'originate' in the UK. Origin means either wholly produced here, or meeting specific processing requirements. Simply re-exporting goods that came from elsewhere does not qualify.

UK trade agreements: 71+ partners covering 75+ countries including EU
Proof of origin: Statement on origin on invoice or EUR1 Movement Certificate
Key principle: Qualifying level of processing in UK required, not just shipping from UK
Important: Different FTAs have different rules - meeting one doesn't automatically qualify for others

Free Trade Agreements allow zero or reduced tariffs, but only if you prove goods 'originate' in the UK. This means wholly obtained here OR sufficient processing occurred here.

Statement on origin

For UK-EU TCA, you complete a statement on your invoice or commercial document. This allows your customer to claim preferential tariff when importing.

Competitive advantage

If your EU customer pays 10% tariff because you didn't provide origin proof, they'll buy from competitors who comply correctly. Origin compliance is essential for competitiveness.

UK-EU rules of origin (opens in a new tab)

4. Understand VAT treatment for EU exports

Zero-rating rules, evidence requirements, and VAT treatment of services to EU customers

VAT zero-rating for exports

Exports to the EU are zero-rated for UK VAT, but you must keep evidence of export. Your EU customer will pay import VAT in their country at their local rate. B2B services follow different rules based on where the customer is established.

VAT rate on exports: 0% when conditions met (goods consumed outside UK)
Evidence deadline: Must obtain within 3 months of time of sale
Record retention: Minimum 6 years for all export evidence and documents
Failure consequence: Supplier liable for VAT due if conditions not met

Three core requirements for zero-rating

1. Goods must be physically exported from UK
2. Evidence obtained within 3 months of sale
3. Evidence retained and all conditions met

Acceptable evidence

Official: C88 Form (SAD Copy 3) with customs endorsement, or CDS export declaration with departure message.

Commercial: CMR Consignment Note (fully completed by consignor, carrier, consignee), or commercial documents linking transaction to exported goods.

Official and commercial evidence have equal weight for VAT purposes.

VAT Notice 703 - Exports (opens in a new tab)

5. Check EU labelling and product marking requirements

EU labelling requirements, CE vs UKCA marking, and what needs to change on your packaging for EU export

CE marking for EU markets

Post-Brexit, CE marking remains valid for EU markets, but UKCA marking is now required for the GB market. Products placed on both markets may need dual marking. Labelling requirements differ - EU rules on country of origin, language, and product information apply to your EU-bound goods.

Great Britain (England, Scotland, Wales): UKCA marking required (CE marking accepted during transitional period)
Northern Ireland: CE marking required under Windsor Framework (UKCA alone NOT valid)
CE mark deadline — old Directives (MDD/AIMDD/IVDD): 30 June 2028
CE mark deadline — EU MDR/IVDR certified: 30 June 2030
Dual marking: Products can carry both UKCA and CE marks simultaneously
Indefinite CE recognition consultation: MHRA consulting on removing 2028/2030 deadlines entirely (16 February to 10 April 2026)
UKNI marking (Northern Ireland): Required alongside CE mark when UK Approved Body has been used for NI market conformity assessment

Using the UKCA marking (opens in a new tab)

6. Prepare your export documentation

EU exports now require commercial invoices with origin statements, customs declarations, and potentially certificates of conformity. Some products (food, live animals, plants) need additional health certificates or phytosanitary documentation.

Essential for all exports

1. Customs Declaration: Via Customs Declaration Service, submitted by deadlines (30 min to 2 hours before departure)

2. Commercial Invoice: All required elements - parties, EORI numbers, goods description, HS codes, value, Incoterms, signatures

3. Packing List: Detailed contents, package marks, weights, dimensions

4. Bill of Lading (sea) or Air Waybill (air): Transport document and contract of carriage

Frequently required

Certificate of Origin: Check destination requirements - apply via Chamber of Commerce

EORI Number: GB EORI for England/Wales/Scotland exports

Product/situation-specific

Export License: Controlled goods, military, dual-use items

Health/Phyto Certificates: Animal products, plants

Dangerous Goods Declaration: Hazardous materials

EUR1 Movement Certificate: Preferential trade under FTAs

Insurance Certificate: If required by payment terms

Export documentation guide (opens in a new tab)

7. Understand Northern Ireland arrangements

Under the Windsor Framework, Northern Ireland remains aligned with EU customs rules for goods. Moving goods from GB to NI requires customs declarations and potentially duties if goods are 'at risk' of onward movement to the EU.

GB EORI number: Required for businesses moving goods from GB
XI EORI number: Required for businesses established in NI or trading with EU via NI
Internal Market Movement Information (IMMI): Simplified declaration for UK Internal Market lane goods
Trader Goods Profile: Set up commodity codes and supplier details to simplify declarations
NIRMS: Northern Ireland Retail Movement Scheme for agri-food products
NIRMS checks: Reduced to 5% from 1 July 2025

Get an EORI number (opens in a new tab)

Export to the EU after Brexit

What changed for UK exporters

1. Get your GB EORI number

2. Make customs declarations for EU exports

3. Prove UK origin for zero-tariff access

4. Understand VAT treatment for EU exports

5. Check EU labelling and product marking requirements

Related journeys

Start exporting from the UK

Start importing goods to the UK

Manage your export compliance

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