This free guide from our Portishead team explains post-Brexit customs rules for UK businesses trading with the EU. Whether you are exporting to the EU after Brexit or importing from Europe, this guide covers the declarations, documentation and compliance requirements that apply on every UK-EU movement. No jargon. No sign-up required.
What Changed After Brexit?
Since 1 January 2021, the UK has operated outside the EU customs union and single market. This means every UK to EU and EU to UK freight movement requires formal customs declarations in both directions, regardless of cargo value, frequency or the trading relationship between buyer and seller.
Before Brexit, goods moved freely between the UK and the EU with no customs declarations, no border checks and no duty considerations. Post-Brexit customs rules require a UK export declaration when goods leave the UK and an EU import declaration when goods arrive in the EU, and the reverse for goods moving from the EU into the UK.
Brexit transition date: 1 January 2021.
Applies to: All UK-EU commercial freight movements, in both directions.
De minimis threshold: None for commercial shipments.
Governing system: HMRC’s Customs Declaration Service (CDS).
Brexit Customs Rules for UK Exporters.
If you are exporting to the EU after Brexit, the following customs rules apply to your shipment.
- A CDS export declaration must be filed before your goods leave the UK.
- Your goods require a commodity code under the UK Trade Tariff.
- An EU import declaration is required on arrival, filed by you, your customer or an EU-based customs agent.
- Rules of origin must be assessed if you want to claim preferential tariff treatment under the UK-EU Trade and Cooperation Agreement.
- A valid UK EORI number is required before any export declaration can be submitted.
Exporters who do not arrange these declarations in advance risk their goods being held at the UK border or refused entry into the EU.
Brexit Customs Rules for UK Importers.
If you are importing goods from the EU into the UK, the following customs rules apply to your shipment.
- A CDS import declaration must be filed before your goods are released into the UK.
- Import duty and VAT liability is calculated based on the commodity code and the rules of origin position.
- Goods meeting UK-EU Trade and Cooperation Agreement rules of origin may qualify for a zero tariff rate.
- Postponed VAT accounting can be used by UK VAT-registered businesses to defer import VAT to their VAT return.
- A valid UK EORI number is required before any import declaration can be submitted.
Our Portishead team coordinates import declarations for every EU shipment we manage, calculating duty liability before your goods arrive so there are no surprises at the UK border.
Export Declarations and T1 Transit Documents.
Every UK to EU road freight movement requires specific documentation prepared before the vehicle departs.
CDS Export Declaration
A CDS export declaration is required for every commercial shipment leaving the UK for the EU. This declares the nature, value, quantity and commodity code of your goods, and must be submitted before the goods cross the UK border.
T1 Transit Document
A T1 transit document allows goods to move through EU countries under customs control without paying import duty at each border crossed, with duty assessed only at the final EU destination. T1 documents are commonly used for UK-EU road freight movements transiting through multiple EU countries.
Rules of Origin and Preference Certificates
Where your goods qualify for zero tariff treatment under the UK-EU Trade and Cooperation Agreement, a statement on origin or supplier’s declaration is required to support the preference claim. Our Portishead team assesses rules of origin eligibility and prepares the required documentation before your goods move.
Brexit Customs Rules by Freight Mode.
Post-Brexit customs documentation requirements apply consistently across every freight mode, though the practical process varies.
Road Freight
UK-EU road freight requires export and import declarations filed before the vehicle departs and arrives. T1 transit documents are commonly used for movements through multiple EU countries. Our Portishead team prepares all documentation before the truck leaves the depot, avoiding delays at the Channel crossing.
Sea Freight
UK-EU sea freight requires the same CDS export and import declarations as road freight, filed before vessel departure and on arrival. Sea freight movements to and from the EU are less common given the proximity of the UK and EU by road, but the same customs rules apply in full.
Air Freight
UK-EU air freight requires export and import declarations filed before departure and on arrival, in the same way as road and sea freight. Time-critical EU air freight movements still require full customs documentation, prepared by our Portishead team before the flight departs.
Rules of Origin and the UK-EU Trade Agreement.
The UK-EU Trade and Cooperation Agreement allows goods that meet specific rules of origin requirements to move between the UK and the EU at a zero tariff rate. Rules of origin determine whether a product is genuinely of UK or EU origin, based on where it was manufactured, processed or substantially transformed.
Goods that do not meet the applicable rules of origin requirements are subject to the standard UK Global Tariff or EU Common External Tariff rate for their commodity code, even when moving between the UK and the EU.
Assessing rules of origin correctly is one of the most complex parts of post-Brexit customs compliance. Our Portishead team assesses rules of origin eligibility for every UK-EU shipment we manage and prepares the required statement on origin or supplier’s declaration to support a preference claim.
Frequently Asked Questions
Common questions from UK businesses about post-Brexit customs and UK-EU trade.
Do I need customs documentation for every shipment to the EU, no matter how small?
Yes. There is no de minimis threshold for commercial shipments moving between the UK and the EU. Every commercial movement requires a customs declaration in both directions, regardless of cargo value or shipping frequency.
What is the difference between UK EU customs before and after Brexit?
Before Brexit, goods moved freely between the UK and the EU with no customs declarations. Since 1 January 2021, every UK-EU commercial movement requires a CDS export declaration and an import declaration at the destination, in both directions.
Do I need an EORI number for post-Brexit customs declarations?
Yes. A valid UK EORI number is required before any UK export or import declaration can be submitted through HMRC’s Customs Declaration Service. EORI registration is free and managed by HMRC.
Can I avoid paying duty on goods moving between the UK and the EU?
Goods that meet the rules of origin requirements under the UK-EU Trade and Cooperation Agreement can move at a zero tariff rate. Goods that do not meet these requirements are subject to standard tariff rates, even within the UK-EU trading relationship.
Do I need a customs broker to handle post-Brexit customs for my business?
You need someone to file your customs declarations, whether that is an in-house customs team, a separate customs broker, or a freight forwarder who coordinates customs alongside your shipment. Our Portishead team coordinates customs documentation via our dedicated Felixstowe partners as part of every UK-EU movement we arrange.
What happens if I do not file the correct post-Brexit customs documentation?
Your goods can be held at the UK or EU border until the correct documentation is provided. This can result in demurrage, storage charges or delivery delays. Incorrect declarations can also result in HMRC post-clearance audits and additional duty demands.
