| Customs union | the UK has been outside the EU customs union since 1 January 2021 |
| Tariffs | 0 % on goods of EU or UK origin under the TCA rules |
| EORI for Great Britain | number starting GB; for Northern Ireland, XI where needed |
| GB EORI | usually immediate, up to 5 working days if HMRC needs to check |
| Proof of origin | keep records for at least 4 years |
| Import VAT | with a UK VAT registration, declared on the return via postponed VAT accounting, nothing paid up front |
What changed on 1 January 2021
When the transition period ended, the United Kingdom left the single market and the customs union. Since then customs formalities apply to all goods moving between the EU and Great Britain, duty or no duty. The Trade and Cooperation Agreement did not change that. It only ensures that goods meeting the rules of origin face no tariffs and no quotas.
In practice every shipment needs an export declaration on the EU side and an import declaration on the British side. In the EU, customs declarants generally have to be established in the EU, and the UK applies the same principle in reverse. That is why most businesses hand their declarations to a forwarder or customs agent. It is not a weakness; it is the norm, for British importers too.
The EORI number: GB, XI and your EU one
The EORI number is how customs identifies you in every declaration. For exports from the EU you use the EORI your own customs authority issued you; in the EU, economic operators generally need one.
For imports into England, Scotland or Wales the importer needs an EORI starting with GB. You normally only get a GB EORI if your business is established in the UK: a registered office, a central administration or a permanent business establishment with staff there. If you are not, someone who deals with customs on your behalf takes over, and that representative needs the number. When HMRC has nothing to check, the GB EORI comes immediately; otherwise it takes up to five working days.
Northern Ireland uses numbers starting with XI. If you already hold an EORI from an EU country, you do not need an XI number for Northern Ireland. Quote a wrong EORI, or none, and you risk delays and storage costs while the goods wait for the right number. How the EORI fits with British VAT is covered in VAT and the UK after Brexit.
UK commodity codes: HS, CN, TARIC and the UK Trade Tariff
Every product in a declaration needs a commodity code. It decides the duty rate, the import VAT and whether you need a licence. Codes everywhere build on the same international base, the Harmonized System (HS). The EU adds its Combined Nomenclature (CN) on top, which applies directly in every member state, and the TARIC with the EU's own measures on top of that.
Since Brexit the UK has had its own tariff. The right code for importing into the UK is in the UK Trade Tariff on gov.uk, which also shows the duty rate, VAT and any preferences. The first digits are usually the same as in the EU, because both rest on the HS. The later digits can differ, so never copy your EU code across unchecked.
For tricky products, binding tariff information on the EU side gives you legal certainty about the classification. Any business can request it from its customs authority.
Rules of origin: turning the TCA into actual zero duty
The trade agreement's zero tariff is not automatic. It applies only to goods originating in the EU or the UK, and you must be able to prove it.
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1. Check origin
Look up the rule of origin for your commodity code under "rules of origin" in the UK Trade Tariff. Goods made in Asia and repacked in the EU usually have no EU origin.
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2. Issue the proof
The usual route is the exporter's statement on origin on the invoice or another commercial document. Alternatively, the British importer can rely on importer's knowledge.
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3. Rethink it for every shipment
Change the material, the supplier or the place of manufacture and the origin can change. HMRC expects the rules to be met for every preference claim.
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4. Keep the records
Declarations, proof of origin and evidence on production and materials must be kept for at least four years. HMRC checks after the event.
Import VAT: postponed accounting instead of paying up front
Import VAT is due when goods enter Great Britain. If you are registered for UK VAT you can declare it on your return through postponed VAT accounting (PVA) and reclaim it as input tax in the same return, instead of paying it at the border. No approval is needed, but a UK VAT registration is.
If you have no UK establishment, tell your customs agent to select PVA in the import declaration and enter you as the importer. The "PVA number" many people search for is not a separate number: they mean the monthly postponed import VAT statement, which you download from the Customs Declaration Service. It stays available there for only six months, so save it.
Sales of goods up to £135 to British consumers follow a different logic: you charge the VAT at the point of sale. And when goods come back, the rules are in returns, VAT and duty after Brexit.
Food, plants, animals: the border checks
Since the end of January 2024 the British Border Target Operating Model has been phased in for animals, animal products, plants and plant products, with health certificates, pre-notification and checks at border control posts. If you ship cheese, cured meat, seeds or cut flowers to the UK, you need far more paperwork than a machinery maker does.
Relief is in sight but not here yet. The EU and the UK are negotiating an agreement on food and plant health (SPS). The EU-UK summit planned for July 2026 was postponed; according to the UK's Food Standards Agency the talks are well advanced, and it is preparing to implement in summer 2027. Until an agreement is signed and in force, today's checks apply.
Questions about EORI and UK customs
What do I need an EORI number for?
For every customs declaration: imports, exports, transit, customs decisions. For goods into Great Britain the importer needs a GB EORI; for the export out of the EU you use your EU EORI.
How do I find or check a GB EORI?
Your own GB EORI is in HMRC's confirmation. Ask your British customer for theirs and check it with the checking service on gov.uk.
Is the EORI the same as my EU VAT number or a UK VAT number?
No. The EORI is a customs number; VAT numbers are tax numbers. Depending on your business you may need all of them.
Where do I find the commodity code for the UK?
In the UK Trade Tariff on gov.uk. The first digits usually match the EU code; the later digits can differ.
Why am I paying when the TCA promises zero tariffs?
Duty is only due if your goods fail the rules of origin or the proof is missing. Import VAT is always due, though: zero duty does not mean zero tax.
Sources: GOV.UK: Get an EORI number; GOV.UK: Import goods into the UK, step by step; GOV.UK: Finding commodity codes for imports or exports; GOV.UK: Trade Tariff; GOV.UK: Pay less Customs Duty on goods from a country with a UK trade agreement; GOV.UK: Check when you can account for import VAT on your VAT Return; GOV.UK: The Border Target Operating Model; GOV.UK: Food Standards Agency, SPS programme update September 2026; European Commission: EU-UK Trade and Cooperation Agreement; GOV.UK: Check an EORI number; GOV.UK: Get your postponed import VAT statement; GOV.UK: Get proof of origin for your goods
