Operate after Brexit
Export to the EU
Export to the EU
New rules for businesses took effect on 1 January 2021 and some of the changes are significant. We’re here to help you continue trading in the new operating environment with advice on exporting and selling online.
The rules for exporting to the EU have changed. Although no tariffs or quotas will apply, UK exporters will still need to complete customs documentation.
Your EU customers and suppliers may have different interpretations of the rules following the end of the transition period. Avoid any misunderstandings by clarifying processes and responsibilities now.
Exporting goods and services
Export goods from the UK - step-by-step
Browse UK Government guidance for exporters
Selling services to the EU, Switzerland, Norway, Iceland and Liechtenstein
The Check How to Export Goods tool provides information for UK exporters about duties, rules of origin and customs procedures for over 160 markets around the world. It also provides detailed information about the UK border. Watch this 60 second walk-through video for how to use it.
You’ll need a UK EORI (Economic Operator Registration and Identification) – a 12-digit number that starts with ‘GB’ to continue to move goods in or out of the UK. HMRC has already issued EORI numbers to VAT-registered businesses. If you are not VAT-registered you will need to apply for an EORI number.
If you move goods to or from Northern Ireland you need an EORI number that starts with XI.
Decide how you're going to complete customs declarations
Many Scottish businesses appoint expert support to help them organise some or all of their customs requirements. The UK Government has published a list of specialist support from which you can choose an organisation to help you. There is also guidance available if you choose to check and make customs declarations yourself.
Further guidance is available from:
- The British International Freight Association BIFA) also has a search function to help find the appropriate customs agent.
- Find a list of customs training providers which will help you submit customs declarations
- Find a list of software developers to get help with Customs Declaration Service (CDS) and Customs Handling of Import and Export Freight (CHIEF) declarations
- Find out more about how to meet customs requirements fast and efficiently after the UK leaves the EU through customs declaration training offered through your local Chamber of Commerce
If you are responsible for customs documentation, you can:
- Check duties and customs procedures for exporting goods from the UK
- Find out more about customs declaration completion requirements when using the CHIEF and CDS trade tariffs to export goods from Great Britain.
Further information
Our dedicated article on support for export and customs documentation includes links to useful videos and contact details for more specific support.
DHL and the Post Office have both provided a list of prohibited and restricted items on their websites which you can check before sending items to ensure your parcels are delivered smoothly.
GOV.UK has provided a list of ports in the UK for Community and Common Transit, the Goods Vehicle Movement Service and Roll on Roll off ports, as well as a list of port codes to use with CHIEF and the Customs Declarations Service.
HMRC has published an interactive tool for businesses who might be delaying paying customs duty. The tool helps businesses to identify customs authorisations that might make the process of declaring goods quicker, simpler or less costly.
If you’re not sure how to classify your goods, check how to find the right commodity code.
Help via Trade Tariff: to look up commodity codes, duty and VAT rates
Commodity codes classify goods for export so you can:
- Fill in declarations and other paperwork
- Check if there’s duty or VAT to pay
- Find out about duty reliefs
Access the GOV.UK trade tariff checker
VAT on exports
The supply of goods and services by UK businesses are liable for EU VAT.
UK businesses supplying goods or services to the EU may need to register for VAT in each Member State. Exports are zero-rated from a UK VAT perspective and proof of export is needed.
Find out how and when you can apply for zero-rated VAT to exported goods
Import VAT will be due, with the liability dependent on the agreed Incoterm, though it may be possible to defer or reclaim it.
Further information
For more information on VAT in the EU, including specific situational examples, read our dedicated article.
If you are facing VAT pressures after Brexit, you may also find that customs special procedures are applicable to your business - read our article on potential solutions to VAT issues to find out more.
Meet rules of origin requirements
Check your goods meet the rules of origin to benefit from zero-tariff trade with the EU. To benefit from the zero tariffs and quotas you will need to demonstrate that your goods meet a minimum requirement for content coming from Scotland, the UK or the EU. This must show that a certain minimum percentage of the value of the goods was added in the UK.
Check whether your goods meet Rules of Origin requirements by using the Export Checker Tool, or referring to Chapter 2 and Annexes ORIG-1 to ORIG-4 of the Trade and Cooperation Agreement. The Government has published a number of steps you can take to ensure your goods meet rules of origin.
Prove origin to benefit from zero tariffs
Ensure you demonstrate origin to customs authorities. You can prove the status of your goods by providing a statement on origin made out by the exporter or the importer’s knowledge (the importer claims the preferential tariff treatment based on their own knowledge about the originating status of the imported product).
Accredited Chambers of Commerce can also provide ‘certificates of origin’.
Claiming preferential rates of duty between the UK and EU
Further information
For more information, read our article covering everything you need to know about rules of origin
The practicalities of exporting have changed and businesses need to make sure that everyone involved in sending their products to EU markets are aware of the new trading environment. You should ensure shipping responsibilities are written down and clearly understood, including commercial terms.
Changes to contract terms
Knowing the International Terms and Conditions of Service (INCOTERMS) will help you set the right contract terms to reflect potential changes of status (becoming an exporter/importer) following the transition period. Possible changes to pricing and payment policy and INCOTERMS may impact your cashflow and pose a greater risk of non-payment. Your dispute resolution or arbitration clauses may need to be amended (e.g. to the International Chamber of Commerce or trade association).
Understand the implications of changes at UK borders
Food and drink products
Customs checks at border inspection posts are now needed for certain goods including food and drink products, animals and animal products. Take account of the additional costs and delays this will entail.
Understand the main changes to food and drink labelling
Export or move live animals and animal products to the EU or Northern Ireland from 1 January 2021
Export or move fish to the EU or NI from 1 January 2021
Exporting Hubs in Scotland (advice for fish and shellfish exporters)
Prepare your HGV with necessary documentation
If your goods are leaving the UK from Dover, you need to apply for a Kent Access Permit. If you are using another port, check if you are ready to cross the border.
Our article on transport and logistics explains additional considerations when it comes to the physical shipping or receipt of goods.
Prepare invoice and other documentation for your goods
The completed invoice, licences or certificates must travel with the goods and goods must be correctly labelled or marked.
Understand the new requirements for conformity assessment and labelling
Prepare your customer
Your trading partner also needs to be ready to receive your goods in light of new regulations. The UK Government has published guidance on the steps they need to take. They may need a license or certificate to import some types of goods.
Taking goods temporarily out of the UK from 1 January 2021
If you’re taking goods to another country temporarily for business reasons and you think you’ll be over the duty free limit, you can usually get an ATA Carnet to avoid paying duty. This includes things like:
- Samples to show at trade fairs or sales meetings
- Publicity materials
- Recorded film and audio
- Equipment you need for work like laptops, cameras or sound equipment
- Goods for educational, scientific or cultural purposes
- Personal effects and sports goods
If you’re taking a vehicle, get a CPD Carnet instead.
You will need to make a customs declaration if you are taking commercial goods out of the UK in your accompanied baggage or vehicle. Find out more about carrying goods in baggage.
You also need to make a declaration if you’re carrying £10,000 or more in or out of Great Britain.
The eCommerce Directive is no longer in place in the UK.
GOV.UK guidance on the eCommerce Directive and the UK
There are three key considerations for your business:
1. If you directly sell goods and services online to the EEA in any sector, you need to check whether you now need to comply with legislation for ecommerce in the Member States you trade with. Businesses established in the UK that operate in the EEA as online retailers, for example, selling goods and services online in any sector, are now subject to legislation concerning information, advertising, shopping and contracting online.
2. You may be affected by this change if you deliver services online in any sector, which can include digital, technology and media services, such as video sharing sites, search tools, social media platforms and internet service providers; but can also include other sectors that deliver services online, such as education and financial services.
3. If you have a .eu domain name, you will need to transfer to another domain name. Businesses can no longer use .eu domain names if they are not established in the EEA. Likewise, other EU Member States only allow web addresses to be used by EEA established entities.
Government videos and webinars
Webinars and videos for organisations that trade with the EU - GOV.UK (www.gov.uk)
Chambers of Commerce - export documentation
Scottish Enterprise is working with the eight Chambers of Commerce in Scotland who are licensed by HM Government and HMRC to issue export and import-related documentation and services. Providing expert advice and support, they can answer your questions on export and customs documentation, changes to documentation systems and associated process changes brought about by Brexit.
This service is available to all companies, not just members of the Chambers. To access this support, just call your nearest Chamber. The eight licensed Chambers are:
To help companies deal with the new customs declarations requirements some of the local chambers deliver ChamberCustoms, a customs brokerage service for traders.
The ChamberCustoms offering includes:
- Making customs declarations for companies - their HMRC compliant brokerage service will look after the import and export declaration requirements of companies
- Providing specialist customs advisory services - their customs brokerage service will offer a 'one stop shop' with direct links to all sea, air, rail and road ports and terminals in the UK
- Training courses - ChamberCustoms has developed a range of training courses to respond to increasing demand. All courses are eligible for HMRC Customs Intermediary Funding
Further information can be accessed via:
- Aberdeen and Grampian Chamber of Commerce
- Ayrshire Chamber of Commerce
- Dundee & Angus Chamber of Commerce
- Edinburgh Chamber of Commerce
- Glasgow Chamber of Commerce
- Renfrewshire Chamber of Commerce
For more information, visit the ChamberCustoms website.
Trade barriers
Trade barriers are restrictions that block or delay exports or a company's potential to do business.
For example, if your business:
- is being prevented from exporting by regulations in an overseas market
- supplies services and has to pay unnecessary charges that give an advantage to domestic suppliers
- exports or wants to export goods that are delayed from getting to market by lengthy customs procedures
If you're experiencing issues with exporting, you can report a trade barrier to the Department of International Trade online. You can also check for current trade barriers.
Trader and Industry forum
You can find answers to EU Transition related queries and ask new questions on the GOV.UK EU Transition Trader and Industry Forum.
Trader Support Service
Register with the free Trader Support Service if you trade with Northern Ireland, and the Movement Assistance Scheme for certain trade in agri-food products to Northern Ireland.
The Trader Support Service will guide you through the changes for goods movements between Northern Ireland and Great Britain and can also complete declarations on your behalf.
You can find more guidance on trading with Northern Ireland in our dedicated section.
Got a question about operating after Brexit?
Get in touch with our experts for the latest on the UK's exit from the EU, its impact on Scottish businesses, and how we can help you navigate the changes facing all companies.