← Back to blog

Customs & Compliance

Brexit changed the rules of UK trade permanently — but the pace of change has been gradual, and some businesses are still catching up. If you're importing or exporting in 2026, it's worth taking stock of exactly where things stand, what obligations apply to you, and where the most common mistakes are still being made.

This guide focuses on the practical realities for UK SMEs rather than the politics. Here is what has changed and what it means for your business today.

Where UK-EU Trade Stands in 2026

The UK left the EU's single market and customs union at the end of 2020 — but the customs controls did not arrive symmetrically. UK exports to the EU faced full EU controls from day one, 1 January 2021. Great Britain staged its own import controls: through 2021, import declarations on EU goods could be deferred by up to 175 days, and full customs controls on EU-to-GB imports only began on 1 January 2022. Sanitary and phytosanitary checks and documentary controls were phased in later still, from 2024, under the Border Target Operating Model. If your experience of importing from the EU felt easier than your EU customers' experience of importing from you, that's why.

What this means for exporters to the EU: You need to submit an export declaration to HMRC, and your goods are subject to customs checks on entry into the EU. Your EU customer needs to clear the goods through import customs in their member state, paying whatever duty and VAT applies. You need export documents — particularly a compliant commercial invoice with a correct commodity code and country of origin.

What this means for importers from the EU: Goods from the EU are now imports into Great Britain, requiring a customs declaration and potentially attracting duty under the UK Global Tariff if they don't meet the rules of origin under the UK-EU Trade and Cooperation Agreement (TCA). The TCA provides zero tariffs on goods that genuinely originate in the UK or EU — but not on goods merely transshipped through either territory.

Northern Ireland remains in a distinct position under the Windsor Framework, maintaining alignment with the EU single market for goods. Businesses trading goods into or out of Northern Ireland should check the specific rules that apply, which differ from those for Great Britain.

Rules of Origin Under the TCA

The zero-tariff benefit under the TCA is not automatic. Goods must meet the relevant rules of origin — meaning they must substantially originate in either the UK or the EU, depending on the direction of trade. Goods made in China and simply passing through the UK warehouse are not of UK origin and do not qualify for TCA preference.

Proving origin requires a statement on origin — prescribed wording made out on the commercial invoice or any other commercial document that describes the goods, using your EORI number as the exporter reference. UK exporters do not need to register for anything: there is no registration requirement on the GB side, and the statement works at any consignment value. (The €6,000 threshold you may have seen quoted runs the other way — it's the value above which EU exporters shipping to the UK need to be Registered Exporters under the EU's REX scheme.) Getting this wrong means your EU customer pays duty they shouldn't have to — which tends to damage the commercial relationship and prompt disputes.

The UK Global Tariff and the FTA Network

Outside of the EU, the UK now operates its own tariff schedule — the UK Global Tariff (UKGT) — rather than the EU's Common External Tariff. The UKGT was designed to be broadly similar to the CET to minimise disruption, but there are differences, and it has been amended since 2021.

The UK has also built its own network of free trade agreements, many of which are continuity agreements rolled over from EU-era deals. More recently, the UK has negotiated new agreements — most notably joining CPTPP and completing deals with Australia and New Zealand. For businesses importing from these countries, it's worth checking whether the goods qualify for preferential rates under these agreements — the saving is the full UKGT rate, which on clothing, for example, is typically 12%.

EORI Numbers Are Now Essential

Every UK business importing or exporting goods needs an Economic Operator Registration and Identification (EORI) number. This is a unique identifier used on all customs declarations and is required to clear goods through UK customs. If you don't have one, your goods will be held at the border.

Applying for a GB EORI is free and straightforward via GOV.UK, and it's usually issued the same day. If you trade goods through Northern Ireland, you may also need an XI EORI.

VAT Changes for Imports

Postponed VAT Accounting (PVA) was introduced to prevent a cash flow hit for VAT-registered importers. Under PVA, import VAT is accounted for on your VAT return rather than paid at the point of import — a significant improvement for businesses with regular import activity. You need to opt in via your customs declaration, but the default for most VAT-registered businesses should be to use PVA routinely.

The £135 threshold for low-value imports also changed how VAT works for small consignments. Goods with a consignment value of £135 or less no longer have import VAT charged at the border — instead, the overseas seller is responsible for registering for UK VAT and charging it at the point of sale. Two important carve-outs: where an online marketplace facilitates the sale, the marketplace — not the seller — is liable for the VAT; and on B2B sales where the buyer provides a UK VAT number, the buyer accounts for the VAT themselves under the reverse charge.

July 2026: The EU Scrapped Duty-Free Parcels Under €150

If you sell B2C into the EU, the biggest change since Brexit itself landed on 1 July 2026: the EU abolished the €150 customs-duty exemption for parcels entering the EU. Until now, a £60 jumper posted to a customer in Lyon attracted no EU customs duty at all. That's over.

The transition rules matter. Low-value consignments (€150 or under) sold through IOSS or moving through the postal system pay a temporary flat duty of €3 per item until 1 July 2028. Consignments outside IOSS owe standard tariff duty at any value. The one clean way out: UK-origin goods claiming TCA preference with a statement on origin still enter duty-free. That single line of prescribed wording on the invoice — which many B2C sellers never bothered with, because their parcels slipped under €150 anyway — is now load-bearing. If your goods genuinely originate in the UK, put the statement on every consignment. If they don't — you import from China and resell — price the duty in.

Common Mistakes Businesses Still Make in 2026

Despite five years of operating under the new regime, certain errors persist. The most common include: incorrect or vague commodity codes on customs declarations; failing to claim TCA preference because origin documentation is missing from the shipment; not accounting for customs duty when pricing goods sold to EU customers under DDP Incoterms; using personal rather than business EORI numbers; and treating Northern Ireland the same as Great Britain for customs purposes.

The GOV.UK Trade Tariff tool and HMRC's guidance pages are the authoritative source for current requirements. For complex situations, a customs agent or freight forwarder will save you more than they cost.