To stay compliant and avoid costly mistakes, follow our Brexit import export checklist

• Register for Brexit VAT in the EU if selling across borders.
• Understand the impact of the Northern Ireland Protocol VAT on your trade.
• File accurate Brexit customs declarations and maintain all required customs paperwork.
• Apply the correct Brexit rules of origin to minimise tariffs.
• Review your e-commerce compliance with Brexit VAT OSS/IOSS systems.
• Prepare for ongoing Brexit VAT changes 2025 and strengthening UK border controls Brexit.

These steps will help reduce post-Brexit trade barriers, streamline your Brexit customs checklist for businesses, and limit the Brexit supply chain impact.

VAT and Customs After Brexit

The UK is no longer a member of the EU’s Customs Union or VAT regime. This change has introduced significant challenges around Brexit VAT rules, customs after Brexit, and ongoing post-Brexit VAT compliance. Any business selling or moving goods between the EU and the UK must now deal with Brexit customs declarations, import duty Brexit, and new Brexit VAT registration EU obligations.

For many companies, the added complexity has increased costs, created delays in the Brexit customs clearance process, and raised concerns about the wider Brexit supply chain impact. To stay compliant and ensure goods are not held up at borders, businesses should follow a clear Brexit import export checklist.

Checklist of Basic Steps for VAT and Customs After Brexit

1. Understand Brexit VAT Rules
   • Review how UK EU trade VAT applies to your goods and services.
   • Stay updated on Brexit VAT changes 2025, which may affect your pricing and reporting.
2. Register for Post-Brexit VAT
   • Complete Brexit VAT registration EU if selling into the European market.
   • Familiarise yourself with Brexit VAT refund rules for reclaiming input VAT.
3. Prepare Customs Declarations and Paperwork
   • File accurate Brexit customs declarations for every shipment.
   • Maintain all required Brexit customs paperwork to avoid delays.
4. Account for Import Duties and Rules of Origin
   • Assess import duty Brexit costs in advance.
   • Apply the correct Brexit rules of origin to qualify for reduced tariffs.
5. Follow the Northern Ireland Protocol VAT Requirements
   • If trading with Northern Ireland, comply with specific Northern Ireland Protocol VAT obligations.
6. Plan for E-commerce VAT Compliance
   • Online sellers must follow the rules for Brexit VAT on e-commerce.
   • Register under the Brexit VAT OSS/IOSS system where applicable.
7. Adapt to UK Border Controls and Trade Barriers
   • Prepare for checks under UK border controls Brexit.
   • Anticipate post-Brexit trade barriers that may affect supply chains.

Why This Checklist Matters

By following this Brexit customs checklist for businesses, you can reduce the risk of shipments being delayed, keep taxes to a minimum, and avoid unnecessary attention from tax authorities. Staying ahead of compliance obligations helps ensure your trade operations remain smooth despite the challenges of Brexit customs clearance and changing VAT rules.

Issues with Customs After Brexit

One of the biggest challenges businesses face since Brexit is dealing with customs after Brexit. The removal of the UK from the EU’s Customs Union has created multiple hurdles for importers and exporters, adding both time and cost to cross-border trade.

Some of the most common issues with Brexit customs clearance include:

• Complex Brexit customs declarations – Each shipment now requires detailed paperwork, increasing administrative work and the risk of errors.
• Brexit customs paperwork delays – Missing or incorrect documents can result in goods being held at the border.
• Import duty Brexit charges – Businesses must pay additional duties if products don’t meet Brexit rules of origin requirements.
• Post-Brexit trade barriers – UK border checks and EU regulatory compliance can slow down supply chains.
• Northern Ireland Protocol VAT challenges – Moving goods to and from Northern Ireland adds another layer of complexity for VAT and customs.

These Brexit VAT rules and customs requirements have reshaped how businesses plan logistics. Companies must adapt their supply chains to reduce the Brexit supply chain impact, stay compliant with UK border controls Brexit, and manage extra costs tied to Brexit VAT changes 2025.

Who Will Be the Official Importer?

Since the UK left the EU Customs Union and VAT regime, one of the most critical decisions businesses must make is determining who will act as the official importer. This responsibility affects how Brexit customs declarations, import duty Brexit, and post-Brexit VAT compliance are managed.

Companies trading across borders must clearly decide whether:

• The business itself will handle customs duties, taxes, and VAT.
• The customer will be responsible for customs after Brexit, including Brexit VAT rules and import charges.

Who Handles Customs Declarations and Taxes?

Every shipment between the UK and EU requires a Brexit customs declaration. Along with this comes the obligation to pay customs duties, Brexit VAT registration EU, and sometimes additional fees under the Brexit rules of origin.

While it may seem easier to pass these responsibilities to the customer, this often leads to problems:

• Customers face unexpected Brexit customs paperwork.
• Goods may be delayed in the Brexit customs clearance process.
• Unexpected import duty Brexit costs can damage trust.
• Poor experiences discourage repeat purchases, especially in Brexit VAT on e-commerce transactions.

For long-term growth, businesses should consider taking control of customs paperwork, VAT registration, and UK EU trade VAT compliance. This ensures a smoother process, fewer post-Brexit trade barriers, and a better customer experience.

How Are You Going to Handle Customs Declarations?

Every shipment between the UK and the EU now requires a Brexit customs declaration. This is one of the most important steps in ensuring smooth trade after Brexit. If not handled correctly, your goods risk being delayed in the Brexit customs clearance process, leading to extra costs, penalties, or customer dissatisfaction.

For most businesses, the best approach is to work with a freight forwarder or customs clearance agent. These professionals will:

• Prepare and file the correct Brexit customs paperwork.
• Ensure that import duty Brexit and VAT charges are calculated properly.
• Verify compliance with Brexit rules of origin to minimise tariffs.
• Help you stay on top of post-Brexit VAT compliance requirements.

Although the UK initially postponed certain customs after Brexit declarations until January 2022, these rules are now fully in force. Businesses trading between the UK and EU must be proactive about their Brexit import export checklist and ensure all documentation is complete before shipping.

By managing UK border controls Brexit obligations early, you reduce the risk of facing post-Brexit trade barriers and keep your supply chain moving.

Do You Have Both a UK and an EU EORI Number?

To trade smoothly between the UK and the EU after Brexit, businesses must ensure they hold the correct Economic Operator Registration and Identification (EORI) numbers. Since the UK left the EU Customs Union, companies now need:

• A GB EORI number to move goods into or out of the United Kingdom.
• An EU EORI number to move goods into or out of any EU member state.

Without both identifiers, businesses cannot complete Brexit customs declarations or comply with UK border controls Brexit requirements.

Why Both GB and EU EORI Numbers Are Required

1. Customs Declarations
   • Every shipment now requires formal Brexit customs paperwork.
   • A valid EORI number must be included to clear goods through the Brexit customs clearance process.
2. Customs Correspondence and Rulings
   • Both UK and EU authorities require an EORI number for issuing rulings, tax queries, and post-Brexit VAT compliance checks.
3. Hiring a Customs Representative
   • Importers and exporters from the UK into the EU often need to appoint a local customs representative.
   • These representatives use their own EU EORI number to complete filings for non-resident businesses.
   • Similarly, non-resident importers face restrictions in the UK (such as simplified declarations) and may require a local representative to manage Brexit VAT rules and filings.

What Is the Code for the Commodity?

When moving goods between the UK and the EU, every product must be classified with the correct commodity code. This standard identifier is essential for completing Brexit customs declarations and calculating import duty Brexit charges.

• EU requirements: Products must be listed with an 8-digit commodity code.
• UK requirements: Products must be listed with a 6-digit commodity code.

The commodity code determines:

1. Customs Duties and Tariffs
   • Incorrect codes can result in overpaying or underpaying tariffs, leading to compliance issues.
   • Correct classification helps reduce costs through applicable trade agreements and Brexit rules of origin.
2. VAT Obligations
   • Codes are used by tax authorities to apply the correct Brexit VAT rules and ensure proper post-Brexit VAT compliance.
   • They affect whether goods qualify for reduced or zero VAT rates.
3. Customs Paperwork and Clearance
   • The code must appear on all Brexit customs paperwork.
   • It speeds up the Brexit customs clearance process and avoids delays at UK border controls Brexit checkpoints.

Why Commodity Codes Matter for Brexit Trade

Since the UK is no longer part of the EU Customs Union, incorrect or missing commodity codes create serious problems. Shipments may be delayed, refused at the border, or face unexpected post-Brexit trade barriers. Using the right code ensures your goods comply with Brexit VAT registration EU requirements and smoothens the entire Brexit import export checklist process.

Tariffs: Know Your Rules of Origin

The EU–UK Trade and Cooperation Agreement allows for tariff-free and quota-free trade between the UK and the EU. However, this benefit only applies if businesses comply with the strict Brexit rules of origin.

These rules are designed to prevent tariff evasion, such as routing goods through third countries to claim preferential treatment. To qualify for zero tariffs:

• Goods must originate in either the UK or the EU, as defined under the agreement.
• Businesses must maintain detailed Brexit customs paperwork, including supplier declarations and product certificates.
• Correct commodity codes must be used in all Brexit customs declarations to prove compliance.

Why Rules of Origin Matter

Failure to meet Brexit rules of origin requirements means your goods may lose tariff-free status and become subject to import duty Brexit. This not only increases costs but can also disrupt supply chains and add to post-Brexit trade barriers.

By ensuring your goods are correctly classified and supported with proper documentation, you can:

• Avoid unexpected customs duties.
• Speed up the Brexit customs clearance process.
• Strengthen compliance with UK EU trade VAT and post-Brexit VAT compliance rules.

Make an Application for a Duty Deferment Account

For businesses importing goods into the UK, applying for a Duty Deferment Account (DDA) can make managing import duty Brexit and post-Brexit VAT compliance much easier.

The UK’s HMRC allows traders to use a DDA to delay payment of customs duties and import VAT by up to one month. This helps businesses improve cash flow and avoid paying charges immediately at the point of entry.

Key Features of a Duty Deferment Account

• One-Month Deferment: Importers can defer the payment of both import duty and customs VAT for a month.
• No Guarantee Required: Since 2021, most businesses no longer need to provide a financial guarantee to open a DDA.
• UK-Based Businesses Only: The scheme is available exclusively to companies registered and operating in the United Kingdom.

Why a Duty Deferment Account Matters Post-Brexit

With the UK outside the EU’s VAT and Customs Union, businesses face additional Brexit VAT rules, Brexit customs declarations, and border charges. A DDA provides several benefits:

• Simplifies the Brexit customs clearance process.
• Reduces administrative burden by consolidating payments.
• Helps manage the Brexit supply chain impact by improving liquidity.
• Ensures compliance with UK border controls Brexit and VAT reporting obligations.

Issues with VAT

One of the most significant post-Brexit changes for traders is import VAT accounting. The UK introduced postponed VAT accounting (PVA) on 1 January 2021, giving businesses the ability to defer VAT payments instead of paying immediately at the border.

How Postponed VAT Accounting Works

• Import VAT is not paid upfront when goods arrive in the UK.
• Instead, it is deferred and reported on your next VAT return.
• This applies to both UK-based and non-UK businesses importing into the UK.

Benefits of Postponed VAT Accounting

• Cash flow relief – businesses don’t have to pay VAT immediately.
• Simplified VAT reporting – import VAT can be reclaimed in the same return.
• Alignment with EU imports – many EU member states have similar systems.

Country-Specific VAT Issues

While PVA works smoothly in the UK, not all EU countries allow the same flexibility. Businesses must check the VAT rules of the EU country they are trading with:

• Countries with PVA schemes: Many EU states allow postponed accounting, meaning VAT is declared on the VAT return instead of upfront.
• Exceptions (e.g., Germany): Germany requires import VAT to be paid at customs, without an automatic deferral.

B2C Goods and Additional VAT Registrations

If your business sells business-to-consumer (B2C) goods across UK-EU borders, you may face new VAT obligations. The previous distance selling thresholds (which allowed limited cross-border sales without extra VAT registrations) no longer apply in the same way after Brexit.

When Extra VAT Registrations Are Required

• UK sellers to EU consumers
  • If you hold stock in an EU country and sell directly to consumers, you must register for VAT in that country.
  • Selling from UK stock to EU customers usually requires registration in each EU member state where goods are delivered, unless you use the EU One Stop Shop (OSS) scheme.
• EU sellers to UK consumers
  • If EU businesses ship goods to UK consumers and hold stock in the UK, they must register for UK VAT.
  • For sales under £135, the seller (or marketplace) must collect and remit UK VAT at the point of sale.

Why This Matters

• Compliance risk – Failing to register can result in penalties and delays at customs.
• Cash flow impact – VAT may need to be paid in multiple jurisdictions.
• Administrative burden – More VAT filings, reporting, and local compliance requirements.

Extra VAT Registrations for B2C Digital Services

If you supply digital services (telecommunications, broadcasting, or electronic services) to consumers (B2C) across the UK-EU border, Brexit has changed how you handle VAT compliance.

1. Sales from the EU to UK Consumers

• If you previously used the EU Mini One-Stop-Shop (MOSS) to declare UK sales, this is no longer valid.
• You must now register separately for UK VAT and file UK VAT returns for your UK consumer sales.

2. Sales from the UK to EU Consumers

• UK businesses can no longer use the EU MOSS system.
• Instead, you must register for the Non-Union MOSS scheme in an EU member state of your choice to report VAT on all your EU consumer sales.

Why This Matters

• No more single filing – Businesses need at least two VAT registrations (UK + EU MOSS).
• Higher admin costs – More reporting, compliance, and possibly local representation requirements.
• Cash flow impact – Different deadlines for VAT payments between the UK and the EU.

Returns: VAT and Duties Management

For e-commerce sellers, handling returns after Brexit has become more complex. Goods sent back by EU or UK customers may be hit with VAT and customs duties twice — once on the original import and again when re-entering the country.

How to Manage This:

Customer Experience: Making use of RGR ensures smoother returns, reduced costs, and better customer satisfaction by avoiding unnecessary charges.

Returned Goods Relief (RGR): This scheme allows businesses to reclaim or avoid paying VAT and duties on goods that are re-imported within a set period, provided the items have not been altered.

Proper Documentation: To qualify for RGR, you must show clear evidence that the goods being returned are the same items originally exported (e.g., invoices, export declarations, transport documents).

Do You Require the Services of a Fiscal Representative?

After Brexit, UK businesses are treated as non-EU entities. This means that in many EU countries, a Fiscal Representative is mandatory when you register for VAT.

• A Fiscal Representative is a locally established tax agent who acts on your behalf with the tax authorities.
• They are jointly and severally liable for your VAT obligations — which is why most will require a bank guarantee or security deposit.
• Currently, up to 19 of the EU’s 27 member states require UK businesses to appoint a Fiscal Representative for VAT compliance.
• Countries such as Ireland, the Netherlands, and some Nordic states may allow direct registration without one, but many others (like Italy, France, Spain, and Poland) require it.

Why This Matters

• Without a Fiscal Representative where required, your VAT registration will not be approved.
• Appointing one adds cost (fees + guarantee), but ensures you remain fully compliant and avoid penalties.

UK VAT Reforms for eCommerce (Post-Brexit)

On January 1, 2021, HMRC introduced major VAT reforms for eCommerce, alongside the Brexit VAT changes. These reforms directly impact how businesses selling to UK consumers must handle VAT.

Key Rules to Know:

• £135 Import VAT Rule
  • For consignments valued at £135 or less, UK VAT must be charged at the point of sale, not at the border.
  • Sellers (or the marketplace, if applicable) are responsible for collecting and remitting the VAT.
• Marketplaces as “Deemed Suppliers”
  • Online marketplaces such as Amazon, eBay, and Etsy are now legally responsible for charging and reporting VAT on sales made through their platforms.
  • This applies when goods are sold by overseas sellers to UK consumers or when UK VAT rules require marketplace intervention.
• Imports Above £135
  • Goods valued over £135 remain subject to normal import VAT and customs duties at the border.
  • Businesses may use postponed accounting to defer import VAT until their next VAT return.

Why It Matters:

Sellers need to ensure their systems (or marketplaces) apply the correct VAT treatment based on the consignment value.

Failure to follow the new VAT rules could lead to blocked listings, fines, or HMRC investigations.

Customs Clearance & VAT Registrations for Marketplace Sellers

When selling B2C goods via major online marketplaces (such as Amazon, eBay, or Etsy), compliance is strictly enforced.

Key Requirements:

• Customs Clearance First: Goods must be properly cleared through customs, with the correct commodity codes, duties, and VAT accounted for.
• Marketplace Restrictions: If sellers fail to meet customs and VAT requirements, marketplaces will block their ability to ship to or sell within the UK and EU.
• Additional VAT Registrations:
  • Selling into the EU from UK stock: You may need EU VAT registrations in the destination country.
  • Selling into the UK from EU stock: You’ll need a UK VAT registration.
• Marketplace Liability Rules: In many cases, marketplaces are held liable for VAT collection on cross-border sales. However, the responsibility to register, declare, and provide valid VAT numbers still lies with the seller.

Why It Matters

Failure to comply leads to blocked listings, delayed shipments, or financial penalties. Ensuring proper clearance and VAT registrations keeps your goods moving smoothly and avoids account suspensions.

B2B: VAT Triangulation Rules No Longer Apply to the UK

Since Brexit, the UK is no longer part of the EU VAT area. This means that the EU’s VAT triangulation simplification rules can no longer be applied to transactions involving the UK.

What This Means for Businesses

• No More UK Triangulation
  • You cannot use the UK as part of an EU triangulation chain to avoid multiple VAT registrations.
  • For example, if goods are shipped from France → UK → Germany, the simplification rules will not apply.
• Supply Chain Replanning Needed
  • Businesses that relied on UK entities in three-party transactions may now need to register for VAT in multiple EU countries.
  • Review your supply chain structures to determine where additional VAT obligations could arise.
• Still Possible for EU-only Triangulation
  • As a UK business, you can still use an EU VAT number to participate in triangulation within the EU, provided the UK is not part of that chain.

Why It Matters

Ignoring these changes may result in:

• Supply chain delays due to incorrect invoicing or VAT treatment.
• Multiple unexpected VAT registrations.
• Higher compliance costs.

B2B: UK Consignment Stock VAT Rules Are Ending

The UK is no longer part of the EU VAT area, and this directly affects how consignment stock arrangements are handled.

What’s Changing

• End of Simplification
  • Previously, EU businesses could hold stock in the UK under Consignment Stock rules without requiring a UK VAT registration.
  • After Brexit, this simplification no longer applies.
• Now Treated as Imports
  • Any goods moved into the UK to be stored at a customer’s warehouse must now be treated as imports at the point of entry.
  • UK import VAT and customs duties will apply.
• UK VAT Registration Required
  • Non-UK businesses holding stock in the UK must now register for UK VAT.
  • This ensures VAT is correctly accounted for when the goods are sold to UK customers.

Why This Matters

• Compliance Risk – Failure to register for UK VAT could result in penalties and delayed shipments.
• Extra Costs – Import VAT, customs duties, and compliance obligations increase overall costs.
• Supply Chain Adjustments – Businesses need to update contracts, invoicing, and warehouse arrangements.

VAT Issues in Northern Ireland

Northern Ireland has a unique VAT position following Brexit, which often confuses businesses trading across the UK and EU.

Key Points to Know

Mistakes can lead to double taxation or non-compliance penalties.

Dual VAT Status

Northern Ireland remains aligned with EU VAT rules for goods, meaning transactions with the EU are treated as intra-community supplies.

For services, Northern Ireland follows UK VAT rules.

Impact on Businesses

If you trade in both goods and services, you may need to apply different VAT rules depending on the transaction.

Businesses must ensure invoices and VAT filings correctly reflect whether the transaction falls under UK or EU law.

Special Northern Ireland VAT Number

Businesses in Northern Ireland are issued a ‘XI’ prefix VAT number for EU transactions.

This number must be used when trading goods with EU countries.

Compliance Complexity

Businesses dealing with the EU, the rest of the UK, and Northern Ireland may face three different VAT treatments.

First Step: Understand Your UK VAT Compliance Requirements

The first step in determining your VAT compliance obligations is to research UK VAT legislation and how it applies to your business activities. Post-Brexit changes have made VAT compliance more complex, especially for companies trading across borders.

At TAS Consulting, we provide tailored VAT solutions to match your specific business model—whether you’re:

• Selling goods into the UK or EU,
• Providing services across borders, or
• Managing multiple VAT registrations.

Our experts ensure you stay compliant while focusing on growing your business.

Services Subject to VAT

Practical Implication
Service providers must ensure correct invoicing, VAT reporting, and compliance with local EU rules, which may differ from UK regulations.

No Immediate Change Post-Brexit
Following Brexit, there were no instant changes to how VAT is applied to services. The UK continues to apply its existing “use and enjoyment” rules.

B2C Services Adjustments
However, certain UK-to-EU B2C services and EU-to-UK B2C services have been modified. Businesses offering digital, financial, or professional services should review how these changes affect their VAT obligations.

B2B Services
For most B2B transactions, the reverse charge mechanism continues to apply, but businesses must carefully determine the customer’s VAT status and location.

Book an Appointment

Need professional help with Brexit VAT registration EU, Brexit VAT refund rules, or managing the Brexit VAT on e-commerce requirements?

Book an appointment today with our VAT and customs specialists to ensure your business remains compliant and competitive in the post-Brexit environment.