Key Takeaways
- EU goods are no longer treated as domestic trade — every commercial shipment entering the UK from the EU now requires a customs declaration, an EORI number, and correct commodity code classification
- The EU-UK Trade and Cooperation Agreement (TCA) provides 0% preferential duty on qualifying goods, but only if rules of origin are met and a valid statement on origin is held — many importers still pay duty they do not owe
- Safety and security declarations became mandatory for EU imports in 2025, adding a pre-arrival filing requirement that did not exist under the original post-Brexit staged approach
- Correct documentation — commercial invoices, statements on origin, packing lists, and customs entries — is the single biggest factor in avoiding delays, duty overpayment, and HMRC penalties
- Working with a competent customs broker and understanding your supply chain’s origin profile can save thousands of pounds per year in avoidable costs
What changed after Brexit
Before 1 January 2021, goods moved between the EU and UK as a single customs territory. No customs declarations, no tariff classification, no rules of origin, no border checks. A lorry loaded in Rotterdam arrived in Leicester with roughly the same formality as one coming from Birmingham.
That ended on 1 January 2021.
The UK left the EU’s Single Market and Customs Union, which means every commercial movement of goods from the EU into the UK is now an international import. In practical terms, the changes fall into four categories:
Customs declarations are mandatory. Every consignment requires a full customs declaration submitted to HMRC via the Customs Declaration Service (CDS). There is no simplified route for EU goods — they are treated identically to goods from the rest of the world. For a full walkthrough of the declaration process, see our customs clearance guide.
Tariffs apply unless a preference is claimed. Without the TCA preference, EU goods are subject to the UK Global Tariff at MFN (Most Favoured Nation) rates. For some product categories — textiles at 12%, vehicles at 6.5%, footwear up to 17% — these rates are significant. The TCA allows 0% duty, but it must be actively claimed with supporting documentation. See our import duty guide for full details on how UK duty rates work.
VAT treatment changed. Import VAT at 20% applies on EU goods at the point of entry, just as it does for goods from any other country. Postponed VAT Accounting (PVA) is available and widely used — it allows importers to account for import VAT on their VAT return rather than paying it at the border, which is a significant cash flow benefit.
Regulatory checks now apply. Product safety, sanitary and phytosanitary (SPS) controls, and conformity assessments that were previously handled through EU-wide mutual recognition now require separate UK compliance. The Border Target Operating Model (BTOM), fully implemented from 2024, introduced risk-based checks on animal and plant products arriving from the EU.
The net effect is that importing from France, Germany, or the Netherlands now involves the same customs and regulatory infrastructure as importing from China or the United States. The TCA softens the tariff impact, but the administrative burden is permanent.
Customs declarations for EU imports
Every EU-to-UK import requires a customs declaration submitted through CDS. Here is what that involves.
Who submits the declaration. Most importers use a customs broker or freight forwarder to submit declarations on their behalf. You can submit declarations yourself if you have CDS access, but the complexity of tariff classification and procedure codes means professional support is advisable for all but the most straightforward shipments.
What you need before the declaration can be filed:
- A valid EORI number — you cannot import commercially without one
- The correct commodity code for each product line
- The customs value of the goods (typically the transaction value, adjusted for freight and insurance costs depending on the Incoterms used)
- A commercial invoice from the supplier
- Details of the country of origin (not the country of dispatch — these can differ)
- Any preferential origin documentation if claiming TCA duty relief
Customs Procedure Codes (CPCs). The procedure code tells HMRC how the goods should be treated. For a standard EU import entering free circulation, the procedure code is 4000 (or 40 00 000 in the full CDS format). Other codes apply for goods entering a customs warehouse, inward processing relief, or temporary admission.
Duty deferment. If you import regularly, a duty deferment account lets you defer payment of customs duty and import VAT to a monthly consolidated payment, rather than paying per consignment. This is standard practice for businesses with any meaningful import volume.
The EU-UK TCA and preferential duty rates
The Trade and Cooperation Agreement, which took effect on 1 January 2021, is the free trade agreement between the UK and EU. Its headline feature is 0% tariff, 0% quota on goods that meet the agreement’s rules of origin.
This is a genuinely valuable agreement. Without it, UK importers would pay MFN duty on every EU shipment — and for many product categories, those rates are not trivial. The table below illustrates the difference:
| Product Category | MFN Rate (no preference) | TCA Preferential Rate |
|---|---|---|
| Clothing and textiles | 6.5–12% | 0% |
| Vehicles and parts | 6.5–22% | 0% |
| Footwear | 3.5–17% | 0% |
| Food and drink | 0–50%+ | 0% |
| Machinery | 0–6.5% | 0% |
| Electronics | 0–4.7% | 0% |
| Chemicals | 0–6.5% | 0% |
However, the 0% rate is not automatic. You must claim the preference on the customs declaration, and you must hold a valid statement on origin from the exporter to support that claim. If you do not claim it, you pay the MFN rate — and HMRC will not refund duty simply because you could have claimed a preference but failed to do so.
Industry estimates suggest that around 48% of eligible EU imports into the UK do not claim the TCA preference. That represents billions of pounds in duty paid unnecessarily across UK businesses each year. The most common reasons are a lack of awareness, poor communication with EU suppliers, and the administrative burden of obtaining origin documentation.
Rules of origin: how to qualify
Rules of origin determine whether goods genuinely “originate” in the EU (or UK) for the purposes of the TCA. They exist to prevent third-country goods from being routed through the EU to avoid higher tariffs — a practice known as trade deflection.
The TCA uses three main types of origin rule:
Wholly obtained. The goods are entirely produced or sourced within the EU. This covers agricultural products, minerals, and goods manufactured entirely from EU materials. Straightforward in principle, though the supply chain documentation required can be demanding.
Sufficient processing (change of tariff classification). If goods are manufactured using non-EU materials, the finished product must undergo a specified change in tariff heading. For example, if raw materials classified under one HS chapter are processed into a finished product under a different chapter, that transformation may satisfy the origin rule. The specific rule varies by product and is set out in the TCA’s product-specific annexes.
Value-added thresholds. Some product-specific rules require that a minimum percentage of the product’s value originates in the EU or UK. For example, certain vehicle components must have a specified percentage of originating content by value. These thresholds were phased in over the first few years of the agreement, with the final, stricter thresholds now fully in force.
Bilateral cumulation. The TCA allows UK content to count towards EU origin, and vice versa. This is significant for supply chains that involve processing in both the UK and EU. If a product is partially manufactured in the UK, exported to the EU for further processing, and then re-imported, the UK-origin content can contribute to meeting the EU origin threshold — and the combined content can qualify the finished product for 0% duty.
The statement on origin. To claim the TCA preference, the importer must hold a statement on origin from the EU exporter. This is a prescribed text (set out in the TCA annexes) that the exporter includes on the commercial invoice or another commercial document. It must include the exporter’s reference number (for EU exporters, their REX number if the consignment exceeds EUR 6,000 in value). The importer does not submit the statement on origin with the customs declaration, but must hold it on file and produce it if HMRC requests it during an audit.
If you cannot obtain a statement on origin from your supplier, you cannot claim the preference. Full stop. This is the most common practical barrier to claiming TCA duty relief, and it requires proactive engagement with your EU suppliers.
Safety and security declarations (2025 changes)
Safety and security declarations — formally known as Entry Summary Declarations (ENS) — were originally waived for EU imports as part of the UK government’s staged approach to border controls. That waiver ended in 2025.
Since then, all EU imports require a pre-arrival safety and security declaration filed with HMRC before the goods reach the UK border. The key points:
- Filing deadline. For goods arriving by road (the most common mode for EU imports), the ENS must be filed at least two hours before arrival at the UK port. For maritime freight, the deadline is longer.
- Who files. Typically the carrier or freight forwarder, though the obligation can fall on the importer depending on contractual arrangements. Check your Incoterms to understand who bears responsibility.
- Data requirements. The ENS requires details of the consignor, consignee, goods description, commodity codes, container/vehicle identifiers, and routing information.
- Non-compliance consequences. Goods without a valid ENS can be refused entry at the border. In practice, this causes delays and storage charges while the declaration is filed retrospectively.
This change brought EU imports into line with imports from the rest of the world and is now a permanent feature of UK-EU trade.
Documentation checklist
Every EU-to-UK import should be supported by the following documentation. Missing or incorrect documents are the primary cause of customs delays and duty overpayment.
Always required:
- Commercial invoice — must include a full description of goods, quantity, unit price, total value, currency, Incoterms, and consignor/consignee details
- Packing list — itemising the contents, weights, and dimensions of each package or pallet
- Bill of lading, CMR note, or airway bill — the transport document proving the carrier’s receipt of goods
- EORI number — the importer’s EORI number must be valid and active
- Commodity codes — each product line must be classified under the correct commodity code
- Customs declaration — submitted via CDS by the importer or their broker
Required if claiming TCA preference:
- Statement on origin — from the EU exporter, in the prescribed TCA format, on the invoice or a linked commercial document
- Supplier declarations — if the exporter is not the manufacturer, they may need supplier declarations from their own supply chain to support the origin claim
Required for specific goods:
- Phytosanitary certificates — for plant products, fresh produce, and certain food items
- Health certificates — for animal products and products of animal origin
- Conformity documentation — CE/UKCA marking, product safety certificates
- Import licences — for controlled goods such as firearms, certain chemicals, or textiles under quota
- Excise documentation — for alcohol, tobacco, and fuel products
Good practice:
- A duty calculation spreadsheet or summary for each consignment, cross-referencing commodity codes, values, and applicable duty rates
- A record of all statements on origin held, linked to the relevant import entries, for audit purposes
Common mistakes importers make
After five years of post-Brexit trade, certain errors recur with remarkable consistency. These are the ones that cost importers the most money and cause the most disruption.
1. Not claiming TCA preference. This is by far the most expensive mistake. If your goods qualify for 0% duty under the TCA and you are not claiming it, you are paying duty you do not owe. The fix is straightforward: request a statement on origin from your EU supplier for every shipment. If they refuse or claim they cannot provide one, push back — the vast majority of EU-manufactured goods will qualify.
2. Wrong commodity codes. An incorrect commodity code means the wrong duty rate, which can go in either direction — you might overpay, or you might underpay and face a retrospective demand from HMRC plus potential penalties. Classification is not guesswork. Use the UK Trade Tariff tool or get a Binding Tariff Information (BTI) ruling for your key product lines. Our commodity codes guide explains the process.
3. Confusing country of origin with country of dispatch. Goods shipped from Germany are not necessarily of German origin. If a German distributor is shipping products manufactured in China, the country of origin is China, not Germany — and the TCA preference does not apply. This distinction matters enormously for duty purposes.
4. Incomplete or missing invoices. A commercial invoice that lacks the Incoterms, a proper goods description, or the supplier’s details will cause delays at customs. Worse, an incorrect customs value leads to incorrect duty and VAT calculations. Get your invoicing right at source.
5. Ignoring Incoterms. The Incoterms on your purchase order determine who is responsible for transport, insurance, customs clearance, and cost. Many UK importers buy on EXW (Ex Works), which means they take responsibility from the supplier’s premises — including EU export formalities. If you do not have an EU-based agent to handle export customs, consider buying on FCA or DAP instead.
6. No deferment account. Paying duty and VAT per consignment creates unnecessary cash flow pressure. A duty deferment account (backed by a Customs Comprehensive Guarantee) lets you defer to monthly payment. For any business importing regularly, this is essential.
7. Failing to keep records. HMRC can audit your import entries for up to three years (and longer in cases of suspected fraud). If you claimed TCA preference but cannot produce the statement on origin, HMRC will reassess duty at the MFN rate — plus interest. Maintain a clean, auditable filing system for all origin documentation.
Frequently asked questions
Do I need a customs broker to import from the EU?
Legally, no. You can submit your own customs declarations through CDS. Practically, most businesses use a customs broker or their freight forwarder’s customs team. The complexity of tariff classification, procedure codes, and preference claims means errors are common without specialist knowledge. For most importers, the broker’s fee is far less than the cost of a single misclassified entry. Read our customs clearance guide for more detail on how the process works.
Is there still 0% duty on EU goods?
Only if the goods qualify under the TCA’s rules of origin and you actively claim the preference on your customs declaration with a valid statement on origin. Without a preference claim, MFN rates apply — and these can be anywhere from 0% to over 20% depending on the product. Check our import duty guide for the full picture on UK tariff rates.
What is the difference between a statement on origin and a EUR.1?
Under the TCA, the EUR.1 movement certificate is not used. Instead, the system relies on statements on origin — a self-declaration by the exporter included on the commercial invoice or another trade document. For consignments over EUR 6,000, the EU exporter must be a Registered Exporter (REX) and include their REX number in the statement. UK exporters use their EORI number. The statement follows a prescribed wording set out in the TCA annexes.
How long does customs clearance take for EU goods?
For well-documented shipments with a competent broker, customs clearance can be completed in a matter of hours — often pre-cleared before the goods arrive. Delays typically result from missing documentation, incorrect commodity codes, or goods selected for physical inspection under the BTOM. The best way to avoid delays is to have all documentation complete and accurate before the goods are dispatched.
Can I reclaim duty if I forgot to claim TCA preference?
Yes, but only within a limited window. You can submit a C285 amendment request to HMRC to claim a retrospective preference within three years of the original import date. You will need to provide the statement on origin that was valid at the time of import. This is worth doing for high-value or high-volume shipments where the duty saving is significant — but it is far better to get the claim right at the point of import.