Brexit Export Guide Update 2026: What You Need to Know
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We are now 6 years on from the dreaded word “Brexit”. Since 31st December 2020, the UK has operated under the EU-UK Trade Cooperation Agreement, which has done vast amounts of damage to UK SME’s. Trading with the EU means getting to grips with EORI numbers, customs declarations, Rules of Origin, and VAT rules that didn’t exist a few years ago.
Whilst the dust has started to settle on this, the annual EU-UK summit is beginning to repair the damage and take painfully slow, incremental steps back into the market.
Onwards and Up has taken all the information from our old Brexit Academy and provided one full blog post with the latest updates that is here to help you navigate some of the export process, keeping exports moving and simplifying some of the technical jargon along the way. Suitable for any business, big or small. Stay tuned towards the end for key tips for fashion and creative businesses.
What Brexit Means for Business
Zero tariffs have been agreed, so customs duties don’t need to be paid, subject to evidence of Rules of Origin being provided
Customs declarations are required for all shipments between the UK and the EU, supported by a commercial or pro-forma invoice.
Register for an EORI number to move goods between the UK and EU. It is a unique ID code to track and register customs information in the EU.
Northern Ireland remains a special case. It’s still part of the UK’s customs territory, but many EU rules continue to apply, including EU VAT and free movement of goods.
The Windsor Framework and the UK-EU Reset
The Northern Ireland arrangement is now known as the Windsor Framework, which replaced the original Northern Ireland Protocol in 2023. More recently, following the UK-EU “reset” summit in May 2025, both sides agreed to work towards a new Sanitary and Phytosanitary (SPS) agreement. If finalised, this would remove most certificates and routine checks on animal and plant products moving between Great Britain and the EU, and, in turn, ease some of the Windsor Framework checks between Great Britain and Northern Ireland. Talks were still ongoing as of mid-2026, so it’s a space worth watching. Read more from the House of Commons Library.
What You Need To Export Your Goods
- Get an EORI
- Commercial invoice
- Incoterms® 2020
- Deferment account
- Additional documentation and checks for certain goods
- Customs declarations
- Country of origin
- Customs value
- Customs procedure codes
- Commodity code
- Weight
Zero Tariffs on Shipment To The EU
Only products that originate from the UK or have had considerable processing in the UK qualify for zero tariffs under the EU-UK TCA. Therefore, customs duties are not required. Companies will still be required to pay or account for import VAT.
To qualify for zero tariffs, you’ll need to submit a customs declaration with proof of origin document or statement.
You’ll need to check that your products comply with the agreed Rules of Origin.
Get company EORI Number for Great Briatin and Northern Ireland
An Economic Operators Registration and Identification (EORI) number is required to ship goods from the UK beginning 1 January 2021. If you haven’t already, you must register for an EORI number.
- If you’re located in Great Britain, you should receive an EORI number that starts with GB.
- If you’re moving goods to Northern Ireland or from Northern Ireland to any non-EU country (including GB), you need an additional EORI that starts with XI.
- Goods moving between Northern Ireland and Great Britain are treated as domestic shipments, despite requiring customs information.
How to Complete a Proforma or Commercial Invoice
It’s essential that you provide a completed commercial or proforma invoice for all dutiable shipments going to the EU. Here are the details you’ll need to include:
- Exporter’s (your business) EORI number
- Consignee’s EORI number; having this will ensure the prompt clearance of your shipments and is vital for business-to-business shipments
- Consignee’s telephone number and email address
- Harmonisation HS codes for all of the goods to be shipped
- Country of origin
- Goods description on both the waybill and the commercial invoice, listed by line, starting with the most valuable
- Value: it’s important that the goods are valued correctly
CDS Has Replaced CHIEF
Since this page was first written, HMRC has completed the move of all UK customs declarations onto the Customs Declaration Service (CDS), which has now fully replaced the older CHIEF system. CHIEF has been switched off for imports and exports; if your business, or your freight forwarder, is still set up for it, this needs sorting before you can move goods at all.
A few practical points if you’re getting to grips with CDS:
- Registration is free and available to any business with an active GB EORI number, via your Government Gateway account
- CDS uses a more detailed, data-led declaration model than CHIEF, particularly around origin and preference data, so accuracy on your Rules of Origin evidence and commodity codes matters more than ever
- Most businesses use a customs agent, freight forwarder, or specialist software rather than filing manually, as declarations can get complex
- HMRC issues periodic CDS updates and tariff changes, so it’s worth checking GOV.UK’s CDS guidance or your customs agent’s updates now and again
Looking further ahead, HMRC is also developing the UK Single Trade Window, a planned “one-stop shop” that will eventually connect HMRC, Border Force, Defra and other border agencies into a single digital platform, so you’re not submitting the same information to several systems. It’s being rolled out in phases and won’t change how you complete declarations today, but it’s worth keeping half an eye on. More on the Single Trade Window.
Proof of Origin
A proof of origin statement must be included on your Commercial or Pro-Forma Invoice to show that the goods originate from the UK or the EU (as long as the Rules of Origin are met).
For UK to EU shipments:
Proof of Origin can be produced by any exporter who has a GB EORI number. Your GB EORI number must be included within the origin statement regardless of the value of the shipment.
For EU to UK shipments:
The origin statement can be produced by any exporter where the value of the consignment is 6,000 EUR (currently £5,700) or less. Anything above this amount the EU exporter must have a Registered Exporter (REX) number and include it in the statement.
Legally you must use the following statement on your Commercial or Pro-forma invoice:
The exporter of the products covered by this document [Exporter Reference No. (REX or GB EORI number)] declares that, except where otherwise clearly indicated, these products are of ……. preferential origin.
(Place and date)
(Name of the exporter)
Tariff, Harmonisation, HS Codes
A harmonised code is a customs tariff code and an important part of the customs declarations. This code identifies the type of goods that are being imported/exported and is the basis for calculations of duties – such as customs duty and import duty. It also defines whether goods are subject to import or export controls. HS Codes that are inaccurate can lead to delays, fees, and inaccurate charges.
Beware that while HS Codes are recognised internationally, more specific categories differ by country. You should use an HS Code search that targets the UK.
Use the following resources to look up your appropriate codes:
• HS Code Lookup by GOV.UK
• TARIC, the integrated Tariff of the European Union
Changes to UK VAT up to £135
UK VAT on goods valued up to £135 will be collected at the point of sale, and not the point of import. This means that overseas businesses selling goods to the UK valued between £0-135, will be required to charge and collect any VAT due at the time of sale.
Overseas businesses must be registered for UK VAT and pay VAT using a UK VAT return.
Changes to UK VAT more than £135
Postponed VAT Accounting (PVA), has been introduced for imports valued at more than £135.
PVA will allow registered UK
businesses to declare and recover import VAT on the same VAT Return, instead of having to pay it upfront and recover it later.
This Threshold Is Changing
In the Autumn Budget 2025, the government announced it will remove the £135 low-value import (LVI) customs duty relief entirely, meaning parcels that are currently exempt could start attracting customs duty on top of VAT. The change is expected to land by March 2029 at the latest, likely with transitional arrangements along the way, worth keeping tabs on via GOV.UK’s import VAT and duty guidance if you regularly ship low-value parcels to or from the EU.
How To Pay Duties and VAT
- Duty payment payable when import declaration submitted (full frontier or supplementary declaration)
- Duty deferment account (DDA) allows deferment of duty and VAT
- Payment must be made on the 15th of the month following submission
- Most companies can apply for a guarantee waiver
Postponed VAT Accounting
- Importer confirms via customs declaration if they will pay import VAT at import or postpone the VAT
- VAT will be declared and recovered on the same VAT return, rather than having to pay it upfront and recover it later
- The goods are released without payment of import VAT
- Improves cash flow for business
What are the Rules of Origin?
The Rules of Origin determine the “economic nationality” of where the goods were made. It ensures that only goods produced in the UK or EU benefit from the zero-tariff agreement.
3 Steps to Comply with Rules of Origin
Classify Your Goods
- Classify good goods using the Harmonised System
- the first 6 digits of the 10-digit classification (commodity) code when importing goods into the UK or the EU.
- Find you products HS codes.
Meeting the Rules of Origin Requirements
- Understand your supply chain and where the materials come from
- Do they originate in the UK/EU/outside the EU?
- EU origin materials and processing can be counted as part of the process, but overall there has to be significant transformation/processing of the goods in the UK to meet the RoO requirements.
- If goods contain non-EU originating material you need to refer to product-specific rules
Products Are ‘Wholly Obtained’
When goods naturally occur in a country. For example, live animals are reared; plants grown and harvested or natural minerals are extracted in a particular country.
Wholly obtained also covers goods produced from scrap and waste derived from manufacturing or processing operations, or from consumption.
Products Have Undergone A ‘Substantial Transformation’ in A Particular Country
When goods are considered to have been “substantially transformed”, having undergone specified manufacturing or processing.
There are a number of technical ways in which countries demonstrate this, including when the manufacturing process. This results in the product
- Changing tariff classification or
- Calculating the percentage change in value-added
Proving Your Goods Qualify
- You must have evidence to prove your goods meet the rules of origin.
- You may also require a supplier declaration from your supplier as evidence of origin.
- Self-declare that your goods meet the RoO by making out a statement on origin and sending this to your customer with your export. The customer can use this as the basis of their claim for zero tariffs.
Importing goods into GB and then (re-)exporting them to the EU
To be eligible for zero tariff export to the EU, goods still need to comply with Rules of Origin. There must be some production in the UK. This applies to EU origin goods as well as to goods from the rest of world.
Understanding Incoterms®
Reducing Export Risk
Never has there been a time when Incoterms have played a significant role in how goods are sold and transported. Brexit has made these fashionable again and an essential part of the export process to ensure businesses understand the risk and liabilities involved to select the best shipping methods.
Each Incoterms rule specifies:
- The obligations of each party (e.g. who is responsible for services such as transport; import and export clearance etc)
- The point in the journey where risk transfers from the seller to the buyer
All Incoterms are based on the principle that the risk of loss or damage is transferred from the seller to the buyer when the seller has fulfilled the delivery obligation according to the applicable term. It is important to note that this point can be different to the point at which the seller is responsible for paying the carriage to.
Why Agreeing Incoterms® Is Important
Obligation
A clear understanding as to who is responsible for what part of the process.
- Who organises transport and insurance
- Who obtains shipping documents and export/import licenses
Risk
Where and when the seller delivers the goods
- Where risk transfers from seller to buyer
Cost
Which party is responsible for costs such as transport, packaging, loading and unloading
Buyers Responsibilities
Transfer of Risk
Sellers Responsibilities
What Do The Incoterms Mean?
Ex Works EXW
Ex Works (EXW) is the Incoterms® 2020 rule used to describe the delivery of goods by the seller at their place of business, normally in their factory, offices or warehouse. The seller does not need to then load items onto a truck or ship, and the remainder of the shipment is the responsibility of the buyer (e.g. overseas shipment and customs duty). EXW is therefore more favourable to the seller as they do not need to worry about the freight once it has left their premises
Free Carrier FCA
The FCA (Free Carrier) rule requires the seller to deliver the goods to the buyer or its carrier either at the seller’s premises loaded onto the collecting vehicle or delivered to another premises (typically a forwarder’s warehouse, airport or container terminal) not unloaded from the seller’s vehicle. The seller must carry out any export formalities and the buyer carries out any import formalities.
Carriage Paid To CPT
The CPT (Carriage Paid To) rule requires the seller to deliver the goods to its carrier but does not indicate whether that is either at the seller’s premises, loaded onto the collecting vehicle or delivered to another premises not unloaded from the seller’s vehicle. The seller must carry out any export formalities, and the buyer carries out any import formalities. It is the seller’s responsibility to contract for carriage, and of course the cost of that will be built into the selling price.
Carriage and Insurance Paid To CIP
The CIP rule is similar to CPT with one very important difference. This rule requires the seller to take out maximum insurance cover under Institute Cargo Clauses (A) or (Air) or similar, for the buyer’s risk. The seller must give the buyer any insurance document the buyer will need in case it must claim under that insurance.
Delivered at Place DAP
DAP requires the seller to deliver to a place named by a buyer, typically the buyer’s premises. The buyer is responsible for unloading the means of transport. The seller has to carry out any export formalities and the buyer has to carry out any import formalities. Like with CPT and CIP the seller contracts for carriage and risk transfers only upon delivery which now is at the buyer’s premises. The seller has no obligation to the buyer to insure for its risk.
Delivered at Place Unloaded DPU
This is a new rule for 2020. While it is often stated as simply being a change of name from the previous DAT (Delivered At Terminal), it is in fact just that little bit more. DAT itself was introduced in 2010 as an expansion of DEQ (Delivered Ex Quay) to cover any mode of transport. The implication of DAT was that the seller delivered the goods, unloaded, into a terminal, whether that be an open area of land such as a container yard or a covered warehouse such as at an airport.
Duty Delivered Paid DDP
DDP functions much like DAP with one most important exception. It is the seller’s obligation to import clear the goods in the buyer’s country and pay any duties and VAT. This rule should be used with great care as the seller might need to be a registered entity both for import and VAT in the buyer’s country, a fairly unlikely scenario. If the seller finds itself unable to be the importer or to be able to recover any VAT paid then the parties should instead contract on DAP terms.
Free Alongside Ship FAS
The FAS (Free Alongside Ship) rule goes back to the days of sailing ships, and requires the seller to place the goods alongside the vessel nominated by the buyer.
Free On Board FOB
FOB (Free on Board) is the most commonly used trade term, but in practice it is used without reference to any version of the Incoterms® rules. In such cases, it is then up to the seller and buyer to agree in their contract on what they mean when they use these 3 letters.
For more details on Incoterms® check out the International Chamber of Commerce
Doing Business In Europe Post Brexit
Things To Know
As part of the agreement to leave the European Union on 31st December 2020, freedom of movement for citizens of the UK within Europe is no more. New rules now apply to how we work and travel on the continent.
When Is A Visa or Work Permit Required?
You will need a visa or work permit if you are:
- taking part in activities or providing services that are not covered by a country’s visa-waiver rules
- staying for more than 90 days in a 180-day period for any reason
- carrying our contracts to provide a service to a client in another country in which your employer has no presence.
When a Visa or Work Permit Is Not Required
If you are travelling for less than 90 days in a 180-day period, you will not need a visa if you are:
• going to a business meeting, attending a conference, attending cultural or sports events or exchanges
• travelling for journalistic or media purposes
Whatever you are doing, we advise you to check the rules on the website of the relevant Member State to find out if you need to apply.
New Border Checks — EES and ETIAS
Two further changes affect UK travellers on top of the visa rules above.
The Entry/Exit System (EES) replaces manual passport stamping for UK and other non-EU travellers with a digital record. On first entry to the Schengen area, you’ll be registered with a facial image and, in most cases, fingerprints, and the system then logs the date and place of every entry and exit automatically, tracking your 90/180-day allowance electronically. EES began a phased rollout on 12 October 2025 and became fully operational at all participating external borders on 10 April 2026. First-time crossings may take a little longer while biometric data is captured. Because the 90/180-day limit is now tracked automatically, overstaying is far easier for border authorities to detect, so it is worth building in some extra time at the border, especially in peak season, while the system beds in.
ETIAS (the European Travel Information and Authorisation System) is a separate requirement; a pre-travel authorisation similar to the US ESTA or the UK’s own ETA. Once live, most visa-exempt travellers, including UK passport holders, will need to apply online before travelling, pay a small fee, and receive an approval linked electronically to their passport. It’s expected to start operating in late 2026 with a grace period before it becomes mandatory, though the date has shifted before, so it’s worth checking closer to any planned trip.
If you send staff to Europe regularly for trade fairs, client meetings or site visits, it’s worth building both systems into your travel planning now. EU Entry/Exit System | ETIAS information portal
Temporary Movement of Goods to Europe
If you’re taking goods to another country temporarily for business reasons and you think you’ll be over the duty-free limit of £390. Applying for an ATA Carnet can help you to avoid paying duty. An ATA Carnet can cover the following things:
- samples to show at trade fairs or sales meetings
- publicity materials
- recorded film and audio
- equipment you need for work, like laptops, cameras or sound equipment
- goods for educational, scientific or cultural purposes
- personal effects and sports goods.
What is an ATA Carnet?
An ATA carnet is often referred to as a passport for goods. It is an international document used to transport non-perishable goods for import and export tax-free and duty-free that are listed on the carnet for up to one year to over 100+ countries and territories around the world.
ATA Carnet costs around £300 + VAT and can be obtained from your local Chamber of Commerce, export documents department.
Keep Up to Date
Brexit rules haven’t stood still since 2021, and they’re not standing still now: the UK-EU reset talks, the phased rollout of EES/ETIAS, and the planned removal of the £135 low-value import relief all mean this is a page worth checking back on rather than treating as settled.