Key Takeaways
- Incoterms are 11 standardised trade terms published by the International Chamber of Commerce (ICC) that define who pays for what — and who bears the risk — when goods move between buyer and seller
- Incoterms 2020 is the current edition, in force since 1 January 2020, and applies to all international and domestic trade contracts that reference it
- Seven terms apply to any mode of transport; four apply exclusively to sea and inland waterway transport
- For UK importers and exporters, choosing the right Incoterm directly affects your customs obligations, duty liability, insurance costs, and who controls the logistics chain
- Post-Brexit, UK businesses trading with the EU now face full customs formalities — making Incoterm selection more consequential than ever
What Are Incoterms?
Incoterms — short for International Commercial Terms — are a set of 11 rules that define the responsibilities of buyers and sellers in international trade. They are published by the International Chamber of Commerce (ICC) and updated roughly every 10 years.
Each Incoterm specifies three things:
- Cost allocation — who pays for transport, insurance, customs duties, and handling at each stage
- Risk transfer — the exact point where responsibility for loss or damage passes from seller to buyer
- Obligations — who arranges transport, export and import clearance, and documentation
Incoterms do not define ownership of goods, payment terms, or jurisdiction for disputes. They deal strictly with the physical movement and associated costs.
When a contract states “CIF Southampton, Incoterms 2020,” both parties know precisely who is responsible for what, from the seller’s warehouse to the named destination. This clarity prevents disputes, reduces delays, and ensures both sides budget correctly.
Why Incoterms Matter for UK Businesses
Before Brexit, most UK-EU trade moved without customs declarations or border checks. Incoterm selection mattered less because the administrative burden was lighter.
That changed on 1 January 2021. Every goods movement between the UK and EU now requires full customs clearance, duties assessment, and documentation. The Incoterm you agree determines:
- Who submits the customs declaration — and therefore who needs a valid EORI number
- Who pays import duty and VAT — a significant cost that catches businesses out when they assume the other party covers it
- Who controls the logistics — and whether you have visibility over transit times, carrier selection, and routing
- Who bears the risk if goods are damaged, delayed, or lost in transit
Getting this wrong is expensive. Choosing an Incoterm where you bear costs you have not budgeted for — or where the other party controls logistics you depend on — creates problems that ripple through your supply chain.
The Four Groups: E, F, C, and D
The 11 Incoterms are organised into four groups based on the seller’s level of obligation. Obligations increase as you move from E through to D.
E Terms — Minimum Seller Obligation
EXW (Ex Works) is the only E term. The seller makes goods available at their premises. The buyer arranges and pays for everything from that point — collection, export clearance, transport, import clearance, and delivery. This is the minimum obligation for the seller and maximum obligation for the buyer.
F Terms — Seller Delivers to Carrier
The three F terms require the seller to deliver goods to a carrier or transport point nominated by the buyer. The buyer arranges and pays for the main carriage.
- FCA (Free Carrier) — seller delivers goods to a named place (their premises or another location) where the buyer’s carrier takes over
- FAS (Free Alongside Ship) — seller delivers goods alongside the vessel at the named port (sea/waterway only)
- FOB (Free on Board) — seller delivers goods on board the vessel at the named port (sea/waterway only)
C Terms — Seller Arranges Main Carriage
The four C terms mean the seller arranges and pays for transport to the destination — but risk transfers to the buyer at the point of shipment, not arrival. This is the critical distinction: the seller pays for carriage but is not responsible for loss or damage during transit.
- CFR (Cost and Freight) — seller pays for transport to the destination port; risk transfers when goods are loaded on the vessel (sea/waterway only)
- CIF (Cost, Insurance and Freight) — same as CFR, plus the seller must arrange minimum insurance cover (sea/waterway only)
- CPT (Carriage Paid To) — seller pays for transport to the named destination; risk transfers when goods are handed to the first carrier (any mode)
- CIP (Carriage and Insurance Paid To) — same as CPT, plus the seller must arrange all-risks insurance cover (any mode)
D Terms — Seller Delivers to Destination
The three D terms place maximum obligation on the seller. The seller bears all costs and risks until goods arrive at the named destination.
- DAP (Delivered at Place) — seller delivers goods to the named destination, ready for unloading; buyer handles import clearance and duties
- DPU (Delivered at Place Unloaded) — seller delivers and unloads goods at the named destination; buyer handles import clearance
- DDP (Delivered Duty Paid) — seller delivers goods cleared for import at the named destination, including all duties and taxes; maximum seller obligation
Responsibility Comparison Table
This table shows who bears responsibility for each major cost and risk element under each Incoterm. S = Seller, B = Buyer.
| Incoterm | Export Packing | Export Clearance | Inland Transport (Origin) | Main Carriage | Cargo Insurance | Import Clearance | Import Duties & VAT | Inland Transport (Dest.) | Risk Transfer Point |
|---|---|---|---|---|---|---|---|---|---|
| EXW | S | B | B | B | B | B | B | B | Seller’s premises |
| FCA | S | S | S* | B | B | B | B | B | Named place / carrier |
| FAS | S | S | S | B | B | B | B | B | Alongside vessel |
| FOB | S | S | S | B | B | B | B | B | On board vessel |
| CFR | S | S | S | S | B | B | B | B | On board vessel |
| CIF | S | S | S | S | S (min.) | B | B | B | On board vessel |
| CPT | S | S | S | S | B | B | B | B | First carrier |
| CIP | S | S | S | S | S (all-risks) | B | B | B | First carrier |
| DAP | S | S | S | S | Negotiable | B | B | S | Named destination |
| DPU | S | S | S | S | Negotiable | B | B | S | Named destination (unloaded) |
| DDP | S | S | S | S | Negotiable | S | S | S | Named destination |
*FCA: inland transport depends on whether goods are delivered at the seller’s premises or another named place.
Transport Mode Restrictions
Not all Incoterms apply to every shipment. Four terms are restricted to sea and inland waterway transport only:
| Any Mode of Transport | Sea and Inland Waterway Only |
|---|---|
| EXW, FCA, CPT, CIP, DAP, DPU, DDP | FAS, FOB, CFR, CIF |
Common mistake: Using FOB or CIF for containerised cargo. These terms define risk transfer at the ship’s rail, which makes sense for bulk goods loaded directly onto vessels. For containers that are packed and sealed well before reaching the port, FCA or CIP is more appropriate because risk transfers when goods are handed to the carrier — not when the container happens to be lifted onto a ship.
Which Incoterms Are Most Common in UK Trade?
UK businesses most frequently use:
EXW and FCA for exports — particularly SMEs that want buyers to arrange international transport. EXW is popular because it appears simple, though it creates complications for export customs declarations (see common mistakes below).
CIF and FOB for sea freight imports — traditional terms deeply embedded in commodity and manufacturing supply chains. CIF is especially common for imports from Asia, where sellers quote inclusive of freight and basic insurance.
DAP is increasingly popular for UK imports from the EU post-Brexit. European sellers delivering to UK destinations on DAP terms handle transport but leave the UK buyer responsible for import clearance, duties, and VAT. This suits EU sellers who do not want to register for UK customs obligations.
DDP is used when the seller wants full control and the buyer wants a landed cost. It requires the seller (or their agent) to handle UK import clearance — which means they need a UK EORI number and often a fiscal representative for VAT.
Post-Brexit Considerations
Brexit introduced customs formalities to UK-EU trade that did not exist before. This has made Incoterm selection more consequential:
EXW and export clearance. Under EXW, the buyer is technically responsible for export clearance in the seller’s country. For a UK buyer purchasing from a German supplier on EXW terms, this means the UK company must arrange export clearance in Germany — which is impractical without a local agent. Post-Brexit, FCA is almost always a better choice than EXW for UK-EU trade because the seller handles export formalities in their own country.
DDP and the seller’s UK obligations. If an EU seller delivers to the UK on DDP terms, they must handle UK customs clearance, pay UK import duty and VAT, and hold a UK EORI number. Many EU sellers are reluctant to take on these obligations. This has pushed much UK-EU trade towards DAP, where the UK buyer handles import formalities.
Northern Ireland and the Windsor Framework. Goods moving between Great Britain and Northern Ireland may be subject to different arrangements under the Windsor Framework. The Incoterm should reflect which party handles the relevant declarations — a point that requires careful attention depending on the goods and their final destination.
Practical Guidance: Choosing the Right Incoterm
Selecting the right Incoterm depends on your leverage, logistics capabilities, and risk appetite.
Choose FCA if you are a UK exporter who wants to fulfil export obligations without managing international transport. You handle packing and export clearance, then hand goods to the buyer’s carrier. Clean, practical, and avoids the EXW problems.
Choose CIF or CIP if you are importing and want the supplier to arrange and pay for transport and insurance. CIF for ocean freight; CIP for air, road, or multimodal. You still handle UK import clearance and duties.
Choose DAP if you want door-to-door delivery but need to control your own import clearance. The seller pays for transport to your premises; you handle HMRC declarations and duty payments. This is the most common arrangement for UK imports from Europe.
Choose DDP if you want a fully landed cost with no customs administration. The seller handles everything including UK import clearance and duties. Confirm the seller has a UK EORI number and understands UK customs requirements — if they do not, you will face delays.
Avoid EXW for international purchases unless you have an agent in the seller’s country who can manage export clearance. For domestic UK-to-UK transactions, EXW works fine.
Five Common Incoterms Mistakes
1. Using FOB for Containers
FOB defines risk transfer when goods pass the ship’s rail. For containerised cargo sealed days before loading, the risk gap between packing and loading is a grey area. Use FCA instead — risk transfers when the container reaches the carrier.
2. Assuming CIF Means Full Insurance
CIF only requires the seller to arrange minimum insurance cover (Institute Cargo Clause C). This covers major casualties but excludes theft, pilferage, and some weather damage. If you need comprehensive cover, negotiate explicitly or use CIP, which under Incoterms 2020 requires all-risks insurance (Institute Cargo Clause A).
3. EXW for International Trade
EXW places export clearance obligations on the buyer — in the seller’s country. This is impractical and in some jurisdictions legally problematic. For cross-border trade, FCA is simpler and avoids the export compliance headache.
4. Confusing Cost and Risk in C Terms
Under CFR, CIF, CPT, and CIP, the seller pays for transport to the destination but risk transfers at the point of shipment. If goods are damaged in transit, the buyer bears the loss — even though the seller arranged the transport. This catches businesses out regularly.
5. Not Specifying the Named Place Precisely
“DAP UK” is not specific enough. State the exact address: “DAP Buyer’s Warehouse, Unit 5, Birmingham Business Park, B37 7YN, Incoterms 2020.” Vague named places lead to disputes about where costs and responsibilities end.
What Changed Between Incoterms 2010 and 2020
The ICC published Incoterms 2020 to replace the 2010 edition. Key changes practitioners should note:
| Change | Detail |
|---|---|
| DAT renamed to DPU | Delivered at Terminal (DAT) became Delivered at Place Unloaded (DPU) to clarify that delivery can occur at any place, not just a terminal |
| CIP insurance increased | CIP now requires Institute Cargo Clause A (all-risks) instead of Clause C (minimum). CIF remains at Clause C |
| FCA bill of lading option | FCA now includes a provision for the buyer to instruct their carrier to issue a bill of lading to the seller — useful for letter of credit transactions |
| Own transport in FCA, DAP, DPU, DDP | Incoterms 2020 explicitly allows the seller or buyer to use their own transport rather than a third-party carrier |
| Security-related obligations | Expanded allocation of security clearance costs and obligations across all terms |
Important: Both Incoterms 2010 and 2020 remain valid if specified in a contract. Always state which edition applies — “FCA London, Incoterms 2020” — to avoid ambiguity.
Summary
Incoterms are not optional fine print. For UK businesses navigating post-Brexit trade, they determine who bears real costs, who faces customs obligations, and who carries the risk when something goes wrong in transit.
Choose the Incoterm that matches your operational capability, not the one that looks cheapest on paper. An apparently low-cost EXW purchase from overseas can become expensive when you factor in arranging export clearance in another country, managing carriers you did not choose, and insuring cargo over routes you do not control.
When in doubt, FCA for exports and DAP for imports are reliable defaults for most UK businesses. And always — always — specify “Incoterms 2020” alongside the named place.
Further Reading
- EORI Number UK: The Complete Guide — essential for any business handling UK import or export clearance
- Customs Clearance UK: The Complete Step-by-Step Guide — the process that Incoterms determine who is responsible for
- Import Duty UK: The Complete Guide — how duty is calculated and how to reduce it
- UK Commodity Codes Guide — classifying goods correctly for customs
- ICC Incoterms 2020 — the official ICC publication and reference
- GOV.UK: Trade with the EU — HMRC guidance on post-Brexit customs requirements
This article is for general guidance only and does not constitute legal or professional advice. Always verify specific Incoterm obligations against the official ICC Incoterms 2020 publication and seek professional advice for complex transactions. Last reviewed: April 2026.