Brexit fundamentally changed the way goods move between the UK and the European Union. For businesses importing or exporting across the UK-EU border, understanding the new requirements is essential.
What Changed on 1 January 2021
Before Brexit, goods moved freely between the UK and EU with no customs formalities. Now:
- All goods require customs declarations on both entry and exit
- Rules of Origin determine whether preferential zero-tariff rates apply
- VAT on imports is now handled via the UK import VAT system
- Sanitary and phytosanitary (SPS) checks apply to animal and plant products
The UK-EU Trade and Cooperation Agreement (TCA)
The TCA means goods that qualify as UK or EU origin can be traded tariff-free. However, you must prove origin using:
- A supplier declaration or EUR.1 movement certificate
- Exporter’s statement of origin on the commercial invoice
If you can’t prove origin, standard MFN tariffs apply.
Rules of Origin: The Key Challenge
For goods to qualify as UK origin, they must be substantially manufactured in the UK. Goods imported from China and re-exported to the EU do NOT qualify — full EU tariffs apply.
EORI Numbers Are Essential
Both UK and EU EORI numbers are required for businesses trading across the border. UK EORI numbers start with ‘GB’; EU EORI numbers vary by member state.
Commodity Codes Have Changed
The UK now uses its own Global Trade Tariff rather than the EU Combined Nomenclature. While similar, there are differences — always verify UK-specific codes.
Postponed VAT Accounting
UK VAT-registered businesses can use Postponed VAT Accounting (PVA) to defer import VAT to their VAT return rather than paying at the border — a significant cash flow benefit.
How ASA Logistics Helps UK-EU Traders
Our customs team manages UK and EU declarations, ensures accurate Rules of Origin documentation, and handles all post-Brexit compliance requirements for importers and exporters.
Contact us to simplify your UK-EU trade.
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