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Since Brexit on 1 January 2021, Great Britain is a third country. Imports from the UK are subject to EU customs law – with the UK Global Tariff, CDS system, Postponed VAT Accounting and EU-UK TCA rules of origin. Everything important on one page.
Brexit fundamentally changed trade relations between the EU and UK.
Since 1.1.2021, all goods must be declared at customs when crossing the EU-UK border. There is no longer a duty-free zone. Customs declarations are required for exports (EU side: AES/ATLAS) and imports (UK side: CDS).
Northern Ireland remains de facto in the EU single market for goods under the Windsor Framework (2023), while belonging to the UK customs territory. For goods moving from GB to Northern Ireland, simplified "Green Lane" / "Red Lane" procedures apply, depending on whether goods stay in NI or go to the EU.
The EU-UK TCA (concluded 24 December 2020) provides for 0% duty rates for goods with proven EU or UK origin. Nevertheless, administrative costs arise (customs declarations, proof of origin). Without proof of origin, standard UK Global Tariff rates apply.
The British equivalent of EU TARIC – with some differences.
The UKGT is based on the global HS system (6 digits), extended to 10-digit UK Commodity Codes. Search: trade.gov.uk/tariffs-taxes. For imports into UK: 10-digit Commodity Code required; for exports from UK: 8-digit code.
Duty rates range from 0% to over 20% depending on product category. Examples: textiles 12%, shoes 4–10%, vehicles 6.5%, food often 0–4% (partly reduced vs EU). For goods with EU origin (TCA): 0% with proof. Anti-dumping duties possible (similar to EU).
The UKGT has some differences from EU TARIC: UK has lowered some rates (e.g. food, industrial inputs). UK has its own safeguard measures (e.g. on steel). EU free trade agreements (e.g. with Japan, Canada) no longer apply to UK – UK has negotiated its own FTAs.
If goods have UK origin and meet UK rules of origin, they benefit from 0% on export to the EU (TCA). Conversely, EU-origin goods benefit from 0% on import to the UK. Important: origin must be proven – either by statement on invoice or via REX/exporter declaration.
The new British IT system for all customs declarations – fully migrated.
CDS (Customs Declaration Service) is the central HMRC IT system for import and export customs declarations in Great Britain. It has fully replaced the older CHIEF system. CDS processes all trade types: standard import/export, simplified procedures, transit, bonded warehousing and special procedures.
Required for CDS: (1) UK EORI number (apply free at HMRC), (2) Government Gateway account (linked to company), (3) registration with HMRC/CDS. CDS software (third-party) or engaging a CDS-accredited customs broker. The migration from CHIEF to CDS was not automatic – companies had to actively switch.
Those without direct CDS access can engage a UK customs broker. The broker must be CDS-authorised and able to file declarations on behalf of the importer. The importer must explicitly authorise the agent in CDS. For occasional imports to the UK, this is the most efficient route.
No immediate VAT prepayment on import – a key advantage for UK importers.
Businesses with a UK VAT number can account for import VAT on their next VAT return as input tax and deduct it directly. No immediate cash payment at customs. VAT is "postponed" until the next quarterly/monthly return.
PVA is automatically available to all UK VAT-registered businesses. No separate application required. The customs code "G" for Postponed VAT Accounting must be used in the CDS declaration. Importers not UK VAT-registered (e.g. foreign companies without UK VAT) cannot use PVA.
For customs duties (not VAT), there is the Duty Deferment Account (DDA): importers pay customs duties monthly rather than per individual shipment. Prerequisite: HMRC approval and bank guarantee or cash guarantee. Combined with PVA, the entire duty payment flow can be optimised.
Three more important aspects for trade with Great Britain.
EU EORI (format: DE..., CH... etc.) valid only for EU customs declarations. UK EORI (format: GB + 12 digits) valid only for UK customs declarations. Those regularly importing to or exporting from UK should have both. UK EORI free from HMRC: gov.uk/eori.
TCA proof of origin: (1) Statement on invoice (up to £6,000): "The exporter of the products covered by this document declares that, except where otherwise clearly indicated, these products are of [EU/UK] preferential origin." (2) REX statement for over £6,000. Without proof: standard UKGT/EU duty rates.
Currently: shipments under £135 from non-UK countries – platforms collect VAT directly at purchase (Low Value Import Relief). Shipments over £135: full CDS declaration. Planned by March 2029: abolition of £135 threshold; then full customs declaration required for all shipments. Earlier than originally planned (2028).
Common questions about customs and trade with Great Britain after Brexit.
Yes. Since 1 January 2021, Great Britain (England, Scotland, Wales) is a third country outside the EU customs territory. Northern Ireland retains a special status in the EU single market for goods under the Windsor Framework. EU customs rules apply to imports from GB as for goods from China or the USA.
The UK Global Tariff is the British equivalent of EU TARIC. It defines duty rates for all goods imported into the UK. Rates are based on the HS nomenclature system (6 digits), extended to 10-digit Commodity Codes. Rates are sometimes lower than EU TARIC. Search: trade.gov.uk/tariffs-taxes.
CDS is the new HMRC IT system for import and export declarations, fully replacing the older CHIEF system. Importers and exporters file electronic customs declarations via CDS. Prerequisites: UK EORI number, Government Gateway account and CDS registration with HMRC.
PVA allows UK businesses with a UK VAT number to account for import VAT on their next VAT return rather than paying it immediately at import. This significantly improves cash flow as no immediate upfront payment to customs is required. PVA is available for all imports to GB.
No, EU exporters do not need a UK EORI number. However, they need an EU EORI number for the EU-side export declaration. The UK importer needs a UK EORI number for the CDS declaration. If EU companies import directly into the UK (e.g. as owner), they also need a UK EORI.
The EU-UK Trade and Cooperation Agreement (TCA) provides for 0% duty on goods with proven EU or UK origin. Origin must be proven by a statement on the invoice (up to £6,000) or via the REX system (above £6,000, REX registration required). Standard UKGT rates apply without proof of origin.
The UK plans to abolish the £135 import threshold for simplified VAT collection by March 2029. Currently, platforms can collect VAT directly at purchase for shipments under £135 (Low Value Import Relief). After abolition, full customs declarations and standard import VAT procedures will apply to all shipments.
Glossary terms
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