Export from UK to EU: customs, EORI, VAT and origin rules for a UK seller

A sale from Great Britain to the EU crosses two borders. UK customs clears the goods out. EU customs clears them in. Each side has its own number, its own declaration and its own tax, and the UK-EU trade agreement gives zero tariff to goods that originate in the UK.

The UK export declaration is made in the Customs Declaration Service

HMRC’s step-by-step guide covers goods moving permanently from England, Wales or Scotland to a country outside the UK. You can hire someone to deal with customs and transport the goods, or do it yourself. Moving goods through the post has its own route, and the guide sends it to Royal Mail’s guidance (GOV.UK, Export goods from the UK).

• The service. The online service for an export declaration needs a subscription to the Customs Declaration Service, and sign-in details linked to your EORI number. It asks for the EORI numbers of everyone involved, the commodity code, the value, weight and packaging, where the goods go and the invoice and packing-list references (GOV.UK, Make and manage an export declaration online). The commodity code is among the details it asks for.
• The deadline. You or your representative must submit the declaration and get clearance before the goods leave. The time depends on the last mode of transport:
  • By road or inland waters, at least one hour before departure.
  • By air, at least 30 minutes before departure from a UK airport.
  • By sea, a container going to Greenland, the Faroe Islands, Iceland or a port on the Baltic, North, Black or Mediterranean Sea needs the declaration at least 2 hours before leaving port. Any other container needs it at least 24 hours before it is loaded onto the vessel leaving the UK. Cargo not in a container needs it at least 2 hours before the goods leave the port.
  • By rail, at least one hour before arrival at the customs office of exit when the journey from the last station where the train was formed takes less than 2 hours. In all other cases, at least 2 hours before the goods leave the UK (GOV.UK, Making a full export declaration).
• Roll on roll off ports and the Channel Tunnel. HMRC calls for a combined safety and security and customs declaration, made before the goods reach the departure port, and for the vehicle registration number in it (GOV.UK, Sending goods to the EU through roll on roll off ports or the Channel Tunnel).
• Post and parcels. An export declaration can be made by conduct. For goods of GBP 1,000 or less, it is made by submitting them to a universal service provider or an authorised foreign designated operator, so posting the goods is the declaration (SI 2019/108, reg. 23(1) and (2)). Regulation 20 excludes some goods from this, among them goods under an export restriction, goods with an application for repayment or remission of import duty not yet decided, and goods under a tariff suspension (SI 2019/108, reg. 20). Above GBP 1,000, or when the parcel goes by courier, a declaration is made in the Customs Declaration Service. For a parcel sent with Parcelforce Worldwide, HMRC’s VAT notice describes a customs declaration for every parcel, on a paper dispatch pack or online, and a receipt that serves as proof of posting (GOV.UK, VAT Notice 703, paragraph 7.6).

The UK VAT side is part of the same job. An export of goods to a destination outside the UK is zero-rated if you export within the time limit and hold evidence of the supply and of the export. For a direct export both limits are 3 months from the time of supply. If you miss either, the supply is not zero-rated and you account for UK VAT at the UK rate (GOV.UK, VAT Notice 703, paragraphs 3.3 and 3.5).

A GB EORI number does not work at EU customs

HMRC’s EORI guidance says what a business needs to make a declaration in the EU: either an EORI number from an EU country, or an EORI number beginning with XI and a permanent business establishment in Northern Ireland (GOV.UK, Check which EORI number you need). A GB number comes from HMRC, for movements to and from Great Britain, and is on neither list. So a UK business that works on both sides can hold three kinds of number.

The rows come from HMRC’s EORI guidance and from the Delegated Regulation (GOV.UK, Get an EORI number; Delegated Reg. Art. 5(1)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 5, paragraph 1Click opens the article on EUR-Lex., 5(6)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 5, paragraph 6Click opens the article on EUR-Lex.). To lodge an EU customs declaration itself, your business needs an EU number, or an XI number with a permanent business establishment in Northern Ireland. The Commission’s EORI guidance gives the plain case: an exporter outside the EU whose goods are consigned to an EU consignee “is not required to apply for an EORI number”; lodging one of the listed declarations in the EU would require one. Whoever declares the goods in the EU uses their own number. How to apply for an EU number is on apply for an EORI number; which country issues it is on EORI number.

The EU import declaration is lodged by a declarant established in the EU

The declarant is the person who lodges the declaration in their own name, or in whose name it is lodged (UCC Art. 5(15)Regulation (EU) No 952/2013, Union Customs CodeArticle 5, paragraph 15Click opens the article on EUR-Lex.). The declarant must be established in the EU. Three declarants are excused: those who lodge for transit or temporary admission; those who lodge occasionally, where customs considers that justified; and those established in a country next to the EU who present the goods at the EU border customs office next to that country, where that country grants the same to EU businesses (UCC Art. 170(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 2Click opens the article on EUR-Lex., Art. 170(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 3Click opens the article on EUR-Lex.).

A UK business that sells into the EU regularly therefore uses one of two routes.

• The customer imports. An EU business buying from you imports the goods in its own name. It or its representative is the declarant, and the duty is its own.
• A representative declares for you. A customs representative established in the EU acts for you. Acting in its own name, it is the declarant (indirect representation). Acting in your name (direct representation) makes you the declarant, and the establishment rule then applies to you, so a regular seller uses the indirect form (UCC Art. 18(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 1Click opens the article on EUR-Lex., Art. 18(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 2Click opens the article on EUR-Lex., UCC Art. 170(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 2Click opens the article on EUR-Lex.).

The declarant owes the import duty. Under indirect representation, the person on whose behalf the declaration is made owes it too (UCC Art. 77(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 77, paragraph 3Click opens the article on EUR-Lex.). That is why a carrier that declares for you in its own name wants your details, and why the duty can reach you. For low-value consumer parcels the Commission says the declarant is in most cases a postal operator, express carrier or customs agent (Commission, Explanatory Notes, section 4.3.5). The order of declarants for parcels of EUR 150 or less is on EORI number, and the two roles behind the word “importer” are on importer of record.

Zero duty under the trade agreement needs UK origin and a statement on origin

The Trade and Cooperation Agreement (TCA) prohibits customs duties on goods originating in the other side, “except as otherwise provided” (TCA Art. 21). Not every good sold from the UK originates there. A good originates in the UK if it is wholly obtained there, produced there exclusively from UK materials, or produced there with non-originating materials and meets the product rule in Annex 3 (TCA Art. 39(1)). Goods that do not meet the rules can still be sold, but pay the standard EU tariff, “also known as Most Favoured Nation”, which for exports to the EU is the Common External Tariff (GOV.UK, rules of origin). Goods made elsewhere and only repacked, labelled, sorted or simply assembled in the UK do not become UK-made: those operations do not confer origin (TCA Art. 43(1)). The rule set is on certificate of origin.

The claim belongs to the EU importer, and it rests on one of two bases: a statement on origin made out by the exporter, or the importer’s own knowledge that the product originates (TCA Art. 54). You are the exporter, so the statement is yours to make.

• What it is. Prescribed text, in one of the language versions of Annex 7, written on the invoice or on any other document that describes the goods well enough to identify them. The importing country cannot require a translation (TCA Art. 56(2), Annex 7).
• Who answers for it. You do. The exporter is responsible for its correctness and must make it out on information showing the product originates, including the origin of the materials (TCA Art. 56(1)).
• How long it lasts. 12 months from the date it is made out, or a longer period the importing side sets, up to 24 months. HMRC gives 12 months for exports to the EU. One statement can cover a single shipment, or multiple shipments of identical products within up to 12 months (TCA Art. 56(3), Art. 56(4); GOV.UK, proving originating status).
• What you keep. A copy and the records behind it, for at least four years (TCA Art. 59(2)).
• Your reference number. For a UK exporter it is the number assigned under UK law, which HMRC says is the EORI number. Where none has been assigned, the field may be left blank (TCA Annex 7, note 2; GOV.UK, proving originating status).

The agreement has a waiver for small consignments, but on the EU side it does not reach a seller’s parcels: it covers small packages from private persons to private persons, and excludes a product imported by way of trade (TCA Art. 60). A parcel you sell needs the statement.

Import VAT, IOSS and the EUR 3 duty decide what your customer pays

Import VAT is payable by whoever the EU country of import designates (VAT Directive Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.). Each country decides, and the Commission records that in general practice the customer or consignee is the person liable, so a parcel sent without IOSS reaches your customer with the VAT to pay (Commission, Explanatory Notes, chapter 5, scenario 4a). If you ship duty paid and the country makes you liable, your sale can move into the EU and bring a VAT number there; that is on DDP shipping to Europe.

IOSS covers distance sales of goods imported in consignments of EUR 150 or less, except excise goods (VAT Directive Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex.). A business in Great Britain is outside the EU, so it uses an intermediary established in the EU (Art. 369m(1)(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 1, point (b)Click opens the article on EUR-Lex.). HMRC says the same: businesses in Northern Ireland or Norway can register directly, and businesses in Great Britain must ask an intermediary to do it (GOV.UK, IOSS). The VAT is due on the sale, when payment is accepted (Art. 369nDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369nClick opens the article on EUR-Lex.), and the import is exempt once the IOSS number reaches customs (Art. 143(1)(ca)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 143, paragraph 1, point (ca)Click opens the article on EUR-Lex.). The registration is on IOSS. The EUR 150 is the intrinsic value: the price of the goods without transport and insurance shown separately on the invoice (Delegated Reg. Art. 1(48)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 48Click opens the article on EUR-Lex.).

The EUR 3 duty. From 1 July 2026 until 1 July 2028, a customs duty of EUR 3 per item applies to a consignment of EUR 150 or less where the import is VAT-exempt under IOSS, or the goods are in a postal consignment as the Delegated Regulation defines it (Council Regulation (EU) 2026/382, Art. 2; Delegated Reg. Art. 1(24)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 24Click opens the article on EUR-Lex.). That definition covers goods “sold in distance sales of imported goods”, so the duty is aimed at sales to consumers. A sale to a VAT-registered business is not one, and pays the normal tariff. Who owes the duty, and what changes in 2028, is on EU de minimis. For a UK seller, origin changes the outcome on one route for goods sold to a consumer:

An item is the goods in the parcel that share one tariff classification, description and, where declared, origin (Delegated Reg. Art. 1(61)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 61Click opens the article on EUR-Lex.). The declarant pays the duty: the IOSS holder, a user of the special arrangements, their indirect representatives, or the importer’s indirect representative. The Commission says it is not a tax on consumers, and the consumer pays only in very residual cases (Commission, guidance on the temporary flat fee).

Northern Ireland follows EU customs and VAT rules for goods

Northern Ireland is part of the UK, but under the Protocol on Ireland/Northern Ireland the Union Customs Code applies to and in Northern Ireland, and so do the EU VAT rules on goods (Withdrawal Agreement, Protocol Art. 5(3) and Art. 8). The EU-UK Joint Committee adopted the Windsor Framework arrangements for the Protocol on 24 March 2023 (European Commission, Windsor Framework). The result for a seller in Northern Ireland:

• No customs declaration to the EU. HMRC states that declarations are not needed for any goods moving directly from Northern Ireland to the EU. Goods sent from Northern Ireland to a country outside the UK and the EU do follow the export steps above (GOV.UK, Trading and moving goods in and out of Northern Ireland; GOV.UK, Export goods from the UK).
• VAT is not collected at the frontier. Northern Ireland aligns with EU VAT rules for movements of goods. VAT on goods traded with the EU is not collected at the frontier, and how it is accounted for depends largely on whether the recipient is registered for VAT in the country of arrival (GOV.UK, VAT on movements of goods between Northern Ireland and the EU, sections 1.4 and 2.4). You add the XI prefix before your UK VAT number on documents sent to EU customers and suppliers, and tell HMRC you trade under the Windsor Framework. For sales to consumers in the EU, HMRC points to the OSS Union scheme, which is on OSS VAT.
• The XI number. You may need an EORI number starting XI to move goods between Northern Ireland and non-EU countries, including Great Britain, or to declare in Northern Ireland. You do not need one if you already hold an EU EORI number, or if you only move goods between Northern Ireland and an EU country (GOV.UK, Get an EORI number). The Commission’s EORI guidance lists a number assigned by UK customs in respect of Northern Ireland next to one assigned by another EU country. To make a declaration in the EU, HMRC accepts an XI number if the business has a permanent business establishment in Northern Ireland (GOV.UK, Check which EORI number you need).
• Product law. The GPSR superseded the 2005 UK Regulations in Northern Ireland on 13 December 2024 (GOV.UK, General product safety regulations: Northern Ireland). What that means for you is on does GPSR apply to you.

A sale from Great Britain to Northern Ireland is a different regime again, under the UK internal market rules. IOSS shows the edge: goods sold from Great Britain to consumers in Northern Ireland stay out of the IOSS return, and their VAT goes on the UK VAT return (GOV.UK, IOSS).

Product law follows the goods into the EU

Customs clearance does not settle whether the product may be sold. A product covered by the General Product Safety Regulation (GPSR) cannot be placed on the EU market unless an economic operator established in the EU is responsible for the tasks the Regulation sets. Its name and contact details go on the product, its packaging, the parcel or an accompanying document (GPSR Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex., Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.). A business in Great Britain is not established in the EU. Who can take that role, and what it costs, is on the EU Responsible Person. Products with EU harmonised rules carry the CE marking: see CE marking. Whether GPSR reaches your goods at all is on does GPSR apply to you.

What happens if you do nothing

• No GB EORI number. The export declaration asks for the EORI numbers of everyone involved, and HMRC warns of delays at customs and increased costs, for example goods stored until you have one (GOV.UK, Make and manage an export declaration online; GOV.UK, Get an EORI number).
• No export declaration or proof of export. The goods are not cleared to leave, and a sale without the evidence is not zero-rated, so you account for UK VAT on it (GOV.UK, Making a full export declaration; GOV.UK, VAT Notice 703, paragraph 3.5).
• No statement on origin. The EU importer’s claim then has to rest on its own knowledge that the goods originate, and without a claim the standard duty applies. If customs verifies a claim and you cannot show the goods originate, your EU customer pays the full duty (GOV.UK, proving originating status; TCA Art. 63(1)). A claim missed at import can still be made up to three years later, and the excess duty is repaid (TCA Art. 55(2)).
• Nobody in the EU to declare. Goods presented to EU customs are in temporary storage from that moment (UCC Art. 144Regulation (EU) No 952/2013, Union Customs CodeArticle 144Click opens the article on EUR-Lex.). Within 90 days they must be placed under a customs procedure or sent back out (UCC Art. 149Regulation (EU) No 952/2013, Union Customs CodeArticle 149Click opens the article on EUR-Lex.). Each EU country sets the penalties for breaking the customs rules, and they must be effective, proportionate and dissuasive (UCC Art. 42(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 42, paragraph 1Click opens the article on EUR-Lex.).

What you can skip

What the law leaves open

• Whether a business in Great Britain can use the neighbouring-country exception to declare at EU customs itself. UCC Art. 170(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 3Click opens the article on EUR-Lex., point (c), needs a person established in a country next to the EU, goods presented at the EU border customs office next to that country, and the same treatment for EU businesses in return. No official text applies it to a business in Great Britain. HMRC lists what a business needs to declare in the EU: an EORI number from an EU country, or an XI number with a permanent business establishment in Northern Ireland. It adds: “If you cannot get an EORI number that can be used in the EU, you will need to appoint someone to deal with customs on your behalf” (GOV.UK, Check which EORI number you need). Plan on an EU representative or an EU importing customer.