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Selling to the UK as an overseas seller: VAT, UKCA, EPR and the GB EORI

The short answer

The UK is outside the EU, so EU rules do not govern a sale to Great Britain and UK rules replace them. A business based outside the UK registers with HMRC for UK VAT whatever its turnover, with narrow exceptions. In Great Britain products fall under the General Product Safety Regulations 2005 and, where a product regulation asks for a mark, UKCA or CE. Customs needs a GB EORI number, yours or your UK customs agent's. Northern Ireland applies EU product rules and uses an XI EORI number; an EU number replaces it, but HMRC's Customs Declaration Service takes a GB number instead for now.

Last checked
Country
United Kingdom

National rules in United Kingdom

RuleLocal nameBodyApplies to you when
UK VAT registrationNon-established taxable personHMRCYou are based outside the UK and make taxable sales of goods or services to UK customers. You register whatever your turnover. You may not need to when every UK sale is zero-rated, a consumer sale through a marketplace, or a sale to a VAT-registered business in Great Britain that accounts for the VAT under the reverse charge, or, if you are based in an EU country, a sale of goods to a non-business customer in Northern Ireland (VAT Notice 700/1, paragraph 9.3). If every UK sale is exempt from VAT, you cannot register.
UK VAT representativeVAT representativeHMRCAppointing one is voluntary and needs HMRC's agreement. HMRC can direct you to appoint one only if your home country has no VAT mutual-assistance arrangement with the UK.
UK VAT on goods of £135 or lessVAT at the point of saleHMRC; the marketplace, where you sell through oneYou send consignments valued at £135 or less from outside the UK to customers in Great Britain. You charge UK VAT at the point of sale, or the marketplace does if you sell through one; a UK VAT-registered business customer that gives you its VAT number accounts for the VAT itself. Above £135 the normal import VAT and customs rules apply.
GB EORI numberGB EORI; XI EORI for Northern IrelandHMRCYou move goods between Great Britain and another country, the EU included, and make customs declarations or use customs systems. With no premises in the UK, you apply for your own number only for the declarations HMRC lists, such as transit, temporary admission, entry or exit summary and temporary storage declarations, or a customs decision. Otherwise the agent you appoint, who must be established in Great Britain or Northern Ireland, gets the EORI number instead of you. A business based outside the UK needs no UTR, SIC code or National Insurance number to apply. For Northern Ireland you apply for an XI number after the GB one, or, if you hold an EU EORI number, you need no XI number, though declarations into Northern Ireland in HMRC's Customs Declaration Service use your GB number for now; the declarant must be based in Northern Ireland or the EU.
UK packaging EPRPackaging extended producer responsibility (pEPR)The Environment Agency (England), SEPA (Scotland), Natural Resources Wales or the Northern Ireland Environment Agency (NIEA, part of DAERA), by the nation of your UK registered office, head office or principal place of business; with none of these, the agency you choose once in writing (SI 2024/1332 reg. 5)You are established in the UK (a UK warehouse, branch, or postal or returns address counts), supplied more than 25 tonnes of packaging in the UK two calendar years before the obligation year and have worldwide turnover of more than £1 million. A UK-established online marketplace is the producer for packaging on goods that sellers established outside the UK supply through it to UK buyers. The regulations name no representative for a business outside the UK.
UK Deposit Return SchemeDeposit Return Scheme (DRS)Defra; the deposit management organisationFrom 1 October 2027 in England and Northern Ireland, for drinks in single-use PET, steel or aluminium containers of 150 ml to 3 litres. The scheme producer is a manufacturer, importer or filler established in the UK (for Northern Ireland, also in the Republic of Ireland). Selling from outside the UK, that is the first UK-established business that offers your drink for sale: it registers with the deposit management organisation, charges the deposit, labels and reports. A product line registered as a low volume line (at most 5,000 containers a year, or 6,250 in the first scheme year) pays no producer fee and carries no deposit or scheme label, but is still registered and reported.
UK WEEEWEEE producer responsibilityEnvironment Agency, Natural Resources Wales, NIEA, SEPAYou sell electrical or electronic equipment to UK customers. Selling direct to UK end users from outside the UK, you appoint an authorised representative based in the UK or join an approved compliance scheme before you place it on the market. Selling through a UK importer or retailer, the first UK business in the chain registers instead. Selling to UK households through an online marketplace, the marketplace is the producer for those sales; you still mark the equipment and give treatment information (SI 2013/3113 regs 2D(3), 24A).
UK waste batteriesWaste battery producer responsibilityEnvironment Agency, Natural Resources Wales, NIEA, SEPA; OPSS for vehicle and industrial batteriesYou have a UK business presence and are the first in the selling chain, an importer included, to make batteries available on the UK market. Products with batteries inside count. Above 1 tonne of portable batteries a year you join a battery compliance scheme by 15 October before the compliance year.
UKCA markingUKCA mark; CE accepted in Great BritainLocal authority Trading Standards; OPSSYour product falls under a UK product regulation that asks for a conformity mark. Great Britain takes UKCA, or CE where the UK recognises it. Northern Ireland takes CE, or CE and UKNI.
UK product safetyGeneral Product Safety Regulations 2005Local authority Trading Standards; OPSSYou supply consumer products in Great Britain. The producer duties sit with a manufacturer established in the UK, else its UK representative, else the UK importer. Instructions for electrical equipment and toy warnings must be in English. Northern Ireland follows Regulation (EU) 2023/988.
UK Responsible Person (cosmetics)UK Responsible PersonOPSSYou sell cosmetic products to consumers in Great Britain. The Responsible Person needs a UK address and notifies OPSS before the product is on sale. In Northern Ireland the Responsible Person must be established in Northern Ireland or the EU.
UK GDPR representativeUK GDPR Article 27 representativeInformation Commission (until 30 September 2026 the Information Commissioner, ICO; ico.org.uk still uses the ICO name)You are not established in the UK and offer goods or services to people in the UK, or monitor their behaviour there. You designate a representative in the UK in writing, unless the processing is occasional, includes no large-scale sensitive or criminal-offence data and is unlikely to risk people's rights.

What does not apply in United Kingdom

  • The EU One Stop Shop and Import One Stop Shop, for sales to customers in Great Britain. There UK VAT is charged at the point of sale on consignments of £135 or less, by you or by the marketplace, and a seller registers with HMRC. For consignments of £135 or less sold to consumers in Northern Ireland, IOSS is available through an intermediary.
  • The EU responsible person under the GPSR, in Great Britain. There the duties sit with the producer as the General Product Safety Regulations 2005 define it: the manufacturer if established in the UK, else its representative or the importer established in the UK. An EU address does not fill that role. In Northern Ireland GPSR Article 16 applies: the responsible operator may be established in Northern Ireland or the EU.
  • An EU EORI number in Great Britain: there you need a GB number. In Northern Ireland an EU EORI number makes an XI number unnecessary, but HMRC's Customs Declaration Service does not accept it for declarations into Northern Ireland for now; a GB number is used instead.
  • A fiscal representative for UK VAT as a general duty. HMRC can direct one only where your home country has no VAT mutual-assistance arrangement with the UK.
  • A packaging authorised representative. The packaging EPR regulations (SI 2024/1332) put duties on producers established in the UK, and the word "representative" appears in them only in connection with packaging recovery notes.
  • A mandatory recycling or sorting mark on packaging. The packaging EPR regulations contain no labelling duty; the three uses of the word "label" in them describe packaging components and who produces them. Drinks containers in the Deposit Return Scheme must carry scheme labelling from 1 October 2027, except registered low volume lines.
  • Textiles EPR. No UK regulations on textile producer responsibility are in force: the newest of the 121 statutory instruments with "textile" in the title on legislation.gov.uk is a 2018 fibre-labelling instrument.

Northern Ireland follows EU rules for goods; Great Britain does not

England, Scotland and Wales apply UK rules. Northern Ireland applies the EU rules for manufactured products under the Windsor Framework, so a seller who ships there meets some EU requirements as well as UK ones (DBT guide for Northern Ireland).

Great Britain Northern Ireland
General product safety General Product Safety Regulations 2005 Regulation (EU) 2023/988Regulation (EU) 2023/988, General Product Safety RegulationThe whole regulationClick opens the law on the EU Publications Office., since 13 December 2024
Conformity mark UKCA, or CE where the UK recognises it CE, or CE and UKNI
Cosmetics Responsible Person A UK address, no PO box Established in Northern Ireland or the EU
EORI number GB EORI An XI EORI, applied for after the GB one; with an EU EORI number no XI is needed, but CDS declarations take your GB number for now; the declarant must be based in Northern Ireland or the EU
VAT on consignments of £135 or less from outside the UK UK VAT at the point of sale Import VAT, which the seller accounts for on its UK VAT return or through IOSS, not at the border
Deposit Return Scheme, from 1 October 2027 England (Scotland and Wales: their own legislation) Covered
Battery product rules Batteries and Accumulators (Placing on the Market) Regulations 2008 Regulation (EU) 2023/1542Regulation (EU) 2023/1542, Batteries RegulationThe whole regulationClick opens the law on the EU Publications Office., since 18 February 2024; SI 2026/1053 revokes the 2008 Regulations for Northern Ireland from 17 October 2026

Sources: OPSS product safety advice, UKCA or CE in Great Britain, cosmetics in Great Britain, GB and XI EORI numbers, VAT on overseas goods, the 2025 Deposit Scheme Regulations, the Deposit Return Scheme guidance, EU Batteries Regulation in Northern Ireland, EORI numbers for Northern Ireland.

Each UK rule has an EU counterpart guide

What happens if you do nothing

  • VAT. A late registration means paying VAT on every sale since the date you should have registered, and possibly a penalty (GOV.UK). HMRC can also direct you to appoint a VAT representative where your home country has no VAT mutual-assistance arrangement with the UK, ask for a security, or tell the marketplace, which may remove you (VAT Notice 700/1, paragraphs 10.3 and 12.3).
  • Product safety. Placing an unsafe product on the market is an offence, with up to 12 months in prison or a fine of up to £20,000 on indictment; in England and Wales a magistrates court can fine without limit (reg. 20; see UK product safety).
  • WEEE. Not registering as a small producer or joining a scheme is an offence that can bring enforcement action (Environment Agency).
  • Batteries. Failing the regulations can lead to prosecution and a fine, which in England and Wales is unlimited (Environment Agency; SI 2009/890, reg. 90 with LASPO 2012, s. 85; see UK batteries).
  • UK GDPR representative. A fine of up to £8,700,000 or 2% of worldwide turnover, whichever is higher (UK GDPR Art. 83(4)(a); see UK GDPR representative).

A website that sells to the UK shows business details

Regulation 6 of the Electronic Commerce (EC Directive) Regulations 2002 lists what an online service provider makes easily, directly and permanently accessible: its name, geographic address, contact details including an e-mail address, its trade-register entry and number, where it is in a public register, and its VAT number, where its activity is subject to VAT. A company registered in the UK must also show its registered name, the part of the UK where it is registered, its registered number and its registered office address on its websites (SI 2015/17, regs. 24 and 25).

The facts for United Kingdom, with their sources

FactValueSourceChecked
Registration authorityVAT: HM Revenue and Customs (HMRC), through its online VAT registration service. A business based outside the UK is registered at its principal place of business, which must be outside the UK.HMRC, VAT Notice 700/1, Who should register for VAT, paragraphs 9.3 and 9.4
Registration authorityWEEE: the regulator is set by where the producer has its registered office or, without one, its principal place of business: the Environment Agency (England), Natural Resources Wales, the Northern Ireland Environment Agency or SEPA (Scotland). A producer based outside the UK registers with the Environment Agency.Waste Electrical and Electronic Equipment Regulations 2013 (SI 2013/3113), regulation 2, "appropriate authority", as revised on legislation.gov.uk
RegisterWEEE: the WEEE online service for producers placing under 5 tonnes a year on the UK market; larger producers join an approved producer compliance scheme.Environment Agency, Electrical and electronic equipment (EEE): producer responsibilities
RegisterBatteries: the National Packaging Waste Database (NPWD) for producers placing 1 tonne or less of portable batteries a year, and for vehicle and industrial batteries; a battery compliance scheme for portable producers above 1 tonne.Environment Agency, Waste batteries: producer responsibility
Small-volume thresholdVAT: a business based outside the UK that supplies goods or services to the UK registers whatever its taxable turnover. It may not need to when every UK sale is zero-rated, a consumer sale through an online marketplace, or a sale to a VAT-registered business in Great Britain that accounts for the VAT under the reverse charge, or, for a business based in an EU country, a sale of goods to a non-business customer in Northern Ireland (VAT Notice 700/1, paragraph 9.3). The £90,000 turnover threshold is the general test for other businesses.GOV.UK, Register for VAT, When to register for VAT
Small-volume thresholdPackaging EPR: you are obligated if you are established in the UK, supplied more than 25 tonnes of packaging in the UK two calendar years before the obligation year and have worldwide turnover of more than £1 million. A UK warehouse, branch, or postal or returns address makes a business established in the UK.Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332), regulation 24, Threshold criteria: large and small producers
Filing deadline and frequencyVAT: a business based outside the UK must register if it makes taxable sales in the UK or expects to in the next 30 days, and must tell HMRC within 30 days of becoming liable.HMRC, VAT Notice 700/1, Who should register for VAT, paragraph 9.3
Filing deadline and frequencyWEEE: a small producer registers by 31 January every year, or within 28 days of first placing EEE on the UK market. A producer placing 5 tonnes or more joins a compliance scheme by 15 November every year, or within 28 days of first placing EEE on the market after that date.Environment Agency, Electrical and electronic equipment (EEE): producer responsibilities
PenaltyPlacing an unsafe product on the market (General Product Safety Regulations 2005, reg. 5), or breaching distributor duty reg. 8(1)(a): on conviction on indictment up to 12 months in prison or a fine up to £20,000, or both; on summary conviction up to 3 months or the statutory maximum fine, or both (in England and Wales a summary fine of this size is unlimited). Breaches of regs. 7(1), 7(3), 8(1)(b) and 9(1): up to 3 months or a level 5 fine, or both; contravening a safety notice carries the reg. 5 penalties (reg. 20(4)).General Product Safety Regulations 2005 (SI 2005/1803), regulation 20, Offences
Enforcement bodyGreat Britain: local authority Trading Standards, with the Office for Product Safety and Standards (OPSS) for cases that are national, novel or contentious. Northern Ireland: local authority Environmental Health, with OPSS.OPSS, Product safety advice for businesses
Local representativeVAT: none by default. HMRC may direct a business to appoint a UK-established VAT representative only where its home country has no VAT mutual-assistance arrangement with the UK; otherwise appointing one is voluntary and needs HMRC's agreement.Value Added Tax Act 1994, section 48, VAT representatives
Local representativeWEEE: a business not established in the UK that supplies EEE directly to UK end users must appoint an authorised representative based in the UK, or join a UK-approved compliance scheme, before it places EEE on the UK market. Sales to UK households through an online marketplace are registered by the marketplace (reg. 2D(3)).Environment Agency, Electrical and electronic equipment (EEE): producer responsibilities, Non UK based producers
Local representativeCosmetics: every product has a Responsible Person with a UK address in Great Britain; a PO box or mail-forwarding address does not count. In Northern Ireland the Responsible Person must be established in Northern Ireland or the EU.OPSS, Making cosmetic products available to consumers in Great Britain
Local representativeUK GDPR: where Article 3(2) applies (offering goods or services to people in the UK, or monitoring their behaviour there), a business not established in the UK designates a representative in the UK in writing, unless the processing is occasional, has no large-scale sensitive or criminal-offence data and is unlikely to risk people's rights (Art. 27(1), (2)(a)).UK GDPR (Regulation (EU) 2016/679 as it forms part of UK law), Article 27, as revised on legislation.gov.uk
How the fee is setDeposit Return Scheme: the producer fee is based on the number of drinks containers you place on the market. The deposit management organisation sets the deposit amount.Defra, Deposit Return Scheme: drinks producer and retailer responsibilities
National ruleDeposit Return Scheme for drinks containers: the Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 come into force on 1 October 2027. The provisions for registering scheme producers are already in force.Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 (SI 2025/67), regulation 1
National ruleConformity marks: Great Britain recognises the CE mark alongside or in place of the UKCA mark under the Product Safety and Metrology etc. (Amendment) Regulations 2024. Which mark a product needs depends on its product regulation, and not every product needs a conformity mark.DBT, Placing UKCA or CE marked products on the market in Great Britain
National ruleGeneral Product Safety Regulations 2005, reg. 2 (Great Britain): the producer is the manufacturer if it is established in the UK; if not, its representative established in the UK; if it has none, the person established in the UK that places the product from outside the UK on the market.General Product Safety Regulations 2005 (SI 2005/1803), regulation 2, Interpretation
National ruleNorthern Ireland: Regulation (EU) 2023/988 on general product safety has applied since 13 December 2024.OPSS, Product safety advice for businesses, Understanding the law on product safety
National ruleVAT on goods in consignments of £135 or less sent from outside the UK and sold directly to customers: in Great Britain the seller charges UK VAT at the point of sale, unless the customer is a UK VAT-registered business that gives its VAT number; in Northern Ireland, for goods from outside the UK and EU, the seller accounts for the VAT on its UK VAT return instead of at the border, or registers for IOSS, through an intermediary unless it is established in the EU, Northern Ireland or Norway. Above £135 the normal import VAT and customs rules apply.HMRC, VAT and overseas goods sold directly to customers in the UK
Marketplace can file for youAn online marketplace is liable for the VAT on consignments of £135 or less sold to customers in Great Britain, and on goods located in the UK that an overseas seller sells through it. The overseas seller stays liable for import VAT and customs duty when it first imports the goods.HMRC, VAT and overseas goods sold to customers in the UK using online marketplaces

Sources

  1. Official source, opened 5 October 2026HMRC, Get an EORI number
  2. Official source, opened 5 October 2026HMRC, Apply for an EORI number (GB and XI)
  3. Official source, opened 5 October 2026Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332), full text
  4. Official source, opened 5 October 2026DBT, Placing CE, or CE and UKNI marked products on the market in Northern Ireland
  5. Official source, opened 5 October 2026Electrical Equipment (Safety) Regulations 2016 (SI 2016/1101), regulation 9
  6. Official source, opened 5 October 2026Toys (Safety) Regulations 2011 (SI 2011/1881), regulation 20
  7. Official source, opened 5 October 2026legislation.gov.uk, UK Statutory Instruments with "textile" in the title, by year
  8. Official source, opened 5 October 2026Electronic Commerce (EC Directive) Regulations 2002 (SI 2002/2013), regulation 6
  9. Official source, opened 5 October 2026Company, Limited Liability Partnership and Business (Names and Trading Disclosures) Regulations 2015 (SI 2015/17), regulation 24
  10. Official source, opened 5 October 2026Company, Limited Liability Partnership and Business (Names and Trading Disclosures) Regulations 2015 (SI 2015/17), regulation 25
  11. Official source, opened 5 October 2026UK GDPR (Regulation (EU) 2016/679 as it forms part of UK law), Article 3, Territorial scope
  12. Official source, opened 5 October 2026Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 (SI 2025/67), full text
  13. Official source, opened 5 October 2026Defra, Deposit Return Scheme: drinks producer and retailer responsibilities
  14. Official source, opened 5 October 2026HMRC, EORI numbers if you move goods to or from Northern Ireland
  15. Official source, opened 5 October 2026HMRC, Economic Operators Registration and Identification (EORI) (customs technical handbook), Place of registration
  16. Official source, opened 5 October 2026HMRC, Appoint someone to deal with customs on your behalf
  17. Official source, opened 5 October 2026DBT, EU Batteries Regulation in Northern Ireland
  18. Official source, opened 5 October 2026Data (Use and Access) Act 2025 (Commencement No. 9 and Transitional and Saving Provisions) Regulations 2026 (SI 2026/1015)
  19. Official source, opened 5 October 2026Data (Use and Access) Act 2025 (Consequential Amendments and Transitional Provision) Regulations 2026 (SI 2026/386)
  20. Official source, opened 5 October 2026Defra and Environment Agency, Extended producer responsibility for packaging, guidance collection
  21. Official source, opened 5 October 2026HMRC, Check if you can register for the VAT Import One Stop Shop scheme (Northern Ireland; an intermediary for businesses established outside the EU, Northern Ireland and Norway)
  22. Official source, opened 5 October 2026Waste Batteries and Accumulators Regulations 2009 (SI 2009/890), regulation 90, Penalties
  23. Official source, opened 5 October 2026Legal Aid, Sentencing and Punishment of Offenders Act 2012, section 85, Removal of limit on certain fines on conviction by magistrates court
  24. Official source, opened 5 October 2026UK GDPR (Regulation (EU) 2016/679 as it forms part of UK law), Article 83, General conditions for imposing administrative fines
  25. Official source, opened 5 October 2026HMRC, VAT Notice 700/1, Who should register for VAT, paragraphs 10.3 and 12.3
  26. Official source, opened 5 October 2026Waste Electrical and Electronic Equipment Regulations 2013 (SI 2013/3113), regulation 2, "appropriate authority", as revised on legislation.gov.uk
  27. Official source, opened 5 October 2026Environment Agency, Electrical and electronic equipment (EEE): producer responsibilities
  28. Official source, opened 5 October 2026Environment Agency, Waste batteries: producer responsibility
  29. Official source, opened 5 October 2026GOV.UK, Register for VAT, When to register for VAT
  30. Official source, opened 5 October 2026Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332), regulation 24, Threshold criteria: large and small producers
  31. Official source, opened 5 October 2026General Product Safety Regulations 2005 (SI 2005/1803), regulation 20, Offences
  32. Official source, opened 5 October 2026OPSS, Product safety advice for businesses
  33. Official source, opened 5 October 2026Value Added Tax Act 1994, section 48, VAT representatives
  34. Official source, opened 5 October 2026OPSS, Making cosmetic products available to consumers in Great Britain
  35. Official source, opened 5 October 2026UK GDPR (Regulation (EU) 2016/679 as it forms part of UK law), Article 27, as revised on legislation.gov.uk
  36. Official source, opened 5 October 2026Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 (SI 2025/67), regulation 1
  37. Official source, opened 5 October 2026DBT, Placing UKCA or CE marked products on the market in Great Britain
  38. Official source, opened 5 October 2026General Product Safety Regulations 2005 (SI 2005/1803), regulation 2, Interpretation
  39. Official source, opened 5 October 2026HMRC, VAT and overseas goods sold directly to customers in the UK
  40. Official source, opened 5 October 2026HMRC, VAT and overseas goods sold to customers in the UK using online marketplaces