How to Export to the UK After Brexit: A Guide for Non-UK Sellers

Great Britain or Northern Ireland: which rules apply

Since Brexit, Great Britain (England, Wales and Scotland) has had its own customs and product rules. Northern Ireland uses its own XI EORI numbers and applies the EU Cosmetics Regulation under the Windsor Framework. Decide where the goods will be sold before you quote, because the trader number and, for regulated goods such as cosmetics, the product rules differ.

You need a GB EORI to move goods between Great Britain and any other country, including the EU, and between Great Britain and Northern Ireland. An XI EORI is needed to move goods into Northern Ireland from Great Britain or from Northern Ireland to a non-EU country, or to make a declaration in Northern Ireland; you get the GB number first. A business that already has an EU EORI does not need an XI number, and an XI number can be used for EU declarations only by a business with a permanent establishment in Northern Ireland (see Triplicate's note on EORI numbers).

For cosmetics, Northern Ireland needs a Responsible Person established in Northern Ireland or the EU, a CPNP notification and EU-compliant labels, and EU bans and the longer allergen list apply there. Products lawfully on the Northern Ireland market can be sold in Great Britain as qualifying Northern Ireland goods; the Responsible Person only sends OPSS the same data through SCPN.

Who imports: GB EORI, indirect representation, DAP or DDP

The importer declares the goods, itself or through an agent, pays duty and import taxes and answers for the classification, value and origin declared. It needs a GB EORI: HMRC's import declaration guide asks for the importer's GB, EU or XI EORI on commercial imports unless a legal exemption applies. A business usually needs premises in the UK to get a GB EORI. A business not established in the UK can get one only for listed activities, such as transit or temporary admission declarations, applying for a customs decision, entry, exit or temporary storage declarations, or acting as a carrier.

HMRC says that if you are not established in the UK and import goods into Great Britain, you can only ask someone to act indirectly on your behalf. That person completes the import declaration and, if you cannot get an EORI, gets one instead. Who imports therefore follows from the Incoterm (see Triplicate's notes on the importer of record and on DDP vs DAP):

• FCA, FOB or DAP: the UK buyer normally imports with its own GB EORI and pays duty and import VAT.
• DDP: you take on import clearance, duty and taxes, so you need a UK-established agent acting indirectly for you, appointed in writing, and usually a UK VAT registration. The ICC notes that DAP suits a seller that does not want, or is not allowed, to handle import clearance.
• Checking a number: use HMRC's Check an EORI number service and save a dated result. A GB number is GB plus 12 digits and includes the VAT number of a VAT-registered business, but a number is valid only once it is registered in the EORI system.
• Applying for your own: HMRC issues a GB number immediately unless it needs to make checks, which can take up to 5 working days. A business not based in the UK does not need a UTR or SIC code.

Duty: commodity code, customs value and the UK Global Tariff

Duty depends on the commodity code, the customs value and the country of origin. The first 6 digits of the code are the Harmonized System; the UK uses 10 digits for imports and 8 for exports, so your own country's export code is not the importer's code. Check the rate for the full code in the UK Integrated Online Tariff, and for certainty before you ship, UK advance tariff rulings are valid for 3 years and published online. For cosmetics, for example, most goods in HS 3303 to 3305 are duty free under the UK Global Tariff and most of 3307 pays 6%.

Customs value is normally the transaction value (HMRC's Method 1): the price actually paid or payable, plus costs the buyer bears that the price leaves out, such as selling commissions, packing, assists and royalties paid as a condition of sale. HMRC uses the seller's invoice, or whatever document asks for payment, as evidence of that value, and adds delivery costs up to the place where the goods enter the UK. Costs after arrival can be left out only with evidence, such as the amount shown separately on the seller's invoice.

Method 1 normally cannot be used for goods supplied free of charge, such as samples, because nothing is paid, so HMRC values them by Methods 2 to 6; they still need a realistic value, not zero. If goods are cleared on a proforma invoice value and the final invoice differs, the declarant must request a post-clearance adjustment.

Import VAT, postponed VAT accounting and consumer parcels

Import VAT is due on top of duty, at 20% on cosmetics, for example. A UK VAT-registered importer can account for it on its VAT return through postponed VAT accounting; a non-UK business registered for UK VAT does this by instructing its agent in writing and being entered as consignee.

A business not established in the UK has no VAT registration threshold and must register once it makes taxable supplies of any value in the UK, so a DDP seller usually needs a UK VAT registration. Tax you cannot recover is an extra cost that your DDP price must cover; Triplicate's export price calculator helps you build the price for the rule you quote.

On consumer sales in consignments of £135 or less, no import VAT is charged: the seller or online marketplace charges UK VAT at the point of sale. The £135 customs duty relief is to be removed on a date the Treasury sets, by October 2028 at the latest.

Commercial invoice, origin declarations and preferences

The importer's agent builds the declaration from your commercial invoice. Give it in English, showing seller, buyer and their EORIs, the Incoterm with named place, a clear description such as "face cream, 50 ml jars", the commodity code, quantity, unit price and value, the currency as an ISO code and the country of origin of each line, with a packing list of cartons and weights made from the same data. Show freight, insurance and other charges as separate amounts, never issue a second, lower invoice for customs, and send the documents before arrival: HMRC aims to clear arrived air and road imports within 2 hours of receiving the documents it asked for (see Triplicate's note on commercial invoice requirements).

A lower duty rate needs preferential origin: the goods must meet the agreement's rules of origin and the importer needs proof in the form the agreement sets. A non-preferential certificate of origin only states where the goods were made and gives no duty reduction; it is needed only when the importing country, the contract or a letter of credit asks for one (see Triplicate's note on certificates of origin). Examples:

• UK–Korea FTA: an origin declaration on the invoice, made by an approved exporter if the consignment is worth over EUR 6,000. An upgraded agreement concluded in December 2025 was not yet in force when this note was checked.
• UK–India CETA: has applied since 15 July 2026; Indian goods can also use the DCTS until 15 July 2028.
• Developing Countries Trading Scheme (DCTS): any exporter in a beneficiary country can make an origin declaration on an invoice or other commercial document that describes the goods well enough to identify them.
• China: there is no UK–China trade agreement, so Chinese goods pay the UK Global Tariff rate.

Cosmetics, origin marks, wood packaging and records

Cosmetics sold in Great Britain need a Responsible Person (RP) established in the UK, with a real UK address, not a PO box or mail-forwarding service. For an imported product the UK importer is the RP, unless another UK-established person is appointed by written mandate, so a brand outside the UK cannot be its own RP. The RP holds the product information file in English with a signed safety report, kept 10 years after the last batch, and notifies each product to OPSS through the free SCPN service before sale; an EU CPNP notification does not cover Great Britain (see Triplicate's note on exporting cosmetics to the UK).

Since 2021 Great Britain has changed its ingredient lists by its own statutory instruments, on its own dates and often with sell-off periods the EU does not give. 4-MBC has been banned since 15 July 2026 (earlier stock may be sold until 14 January 2027), and TPO, used in gel nail products, and 15 other CMR substances since 15 August 2026 (earlier stock until 14 February 2027), both under SI 2026/23; 13 more CMR substances, including silver and ozone, are banned from 23 March 2027 (SI 2026/109). Screen the full formula, fragrance included, against the GB lists, not only the EU's.

• Cosmetic labels: nominal content, durability, precautions and function in English; ingredients by their common glossary names; the country of origin, such as Republic of Korea, not "Made in the EU"; and the UK RP's name and address. A label meeting the EU rule is accepted for the RP details until 31 December 2027; from 1 January 2028 it must name the UK RP.
• Origin marks: the UK has no general marking rule for non-food goods, but since 6 April 2025 misleading origin claims fall under the unfair commercial practices rules of the Digital Markets, Competition and Consumers Act 2024, and food law requires origin for meat, fish and seafood and wherever its absence could mislead. A mark never replaces a certificate of origin.
• Wood packaging: ISPM 15, the international standard, requires solid wood pallets, crates and dunnage to be debarked, treated by an approved method and stamped with the IPPC mark. Packaging made wholly of plastic, metal or processed wood such as plywood or OSB needs no treatment, but solid-wood skids or blocks on it do. State the packaging and its ISPM 15 status on the packing list, and confirm UK requirements with the importer's broker (see Triplicate's note on ISPM 15 wood packaging).
• Records: HMRC requires records of traded goods declared to it to be kept for 4 years, and VAT records for at least 6 years. Keep origin evidence as long as the agreement and national law require.