Your guide for the export of goods to the UK after Brexit

Formalities concerning export to the UK

In order to export products to the United Kingdom, you have to arrange certain matters in the Netherlands first.

• Request a Dutch EORI number. To export goods, you have to request an Economic Operator Registration and Identification Number in the Netherlands. You will find more information on this topic on the website of the Netherlands Tax and Customs Administration.
• You should, of course, also register your goods with UK customs. If you are in charge of the export, you will also need a British EORI number. If you outsource the export to a representative, be sure to check whether they have an EORI number. If that is the case, you most likely will not have to request a British EORI number. If you need to, you can request a British EORI number on the UK government website.
• Arrange for an export declaration. With an export declaration confirmation that meets the trade obligations that the Netherlands has agreed upon internationally. The Dutch Tax and Customs Administration also provide a step-by-step plan. Are you exporting goods to the UK often or are you planning to? In that case, it is prudent to request an AEO (Authorised Economic Operator) status. This status means that more physical inspections are carried out and priority is given to inspections. You will find more information on the AEO status on the Dutch Tax and Customs Administration website.
• Make sure that you request the correct export documents. Not all export documents are mandatory, but they are recommended, especially as customers might ask for them. On Acces2Markets, you will find the documents that you need for export to the UK. The Netherlands Chamber of Commerce website provides extensive information on export documents.
• If necessary, arrange to have product certificates. Depending on the product you want to export, you might need a product certificate. More information on this topic can be found on the Netherlands Enterprise Agency (RVO) website.
• Arrange the terms and conditions for delivery and the Incoterms.
• Pre-notify transport by ferry via Portbase.
• Check whether suppliers are taking the post-Brexit rules into account.
• Do you provide ICT or digital services to the UK? Be sure to check whether there are any new laws regarding digital data in the UK that differ from the EU. You will find more information on this topic on the RVO website.

Brexit customs fees. Import duties on exports to the UK

The UK and EU have agreed that British Customs do not impose duties on goods that originate from the EU. In order to determine the origin of a product, a few aspects are taken into account:

• Which country the product has been produced in. For example, flowers that have been grown in the Netherlands, are deemed as from Dutch preferential origin.
• Which country the product undergoes a significant change in which alters its place of origin. This is a more arbitrary aspect. For example, a machine could be made up of multiple parts that are not all originally from the EU. Only if sufficient value is added in the Netherlands is the machine deemed to have the Netherlands as its preferential origin.

The My Trade Assistant tool in combination with the ROSA (Rules of Origin Self-Assessment) of Access2Market are useful aids for determining the rules of origin that apply for a product. Among other things, they offer a checklist, explanations and practical examples. If you export products to the UK that are of preferential origin from the EU, you can attach a Statement on Origin on the sales invoice. The Netherlands Chamber of Commerce offers examples of a Statement on Origin.

For invoices amounting to less than €6000, you are allowed to draw up an invoice declaration without customs approval. For invoices totalling more than €6000, you need a REX certification from the Dutch Tax and Customs Administration. This acknowledges you as an exporter with customs offices. The REX certification number should be stated on the invoice you send to your clients.

If products are not from preferential EU origin, you will have to pay import duties. More information on this can be found on Gov.uk.

VAT on exports to UK after Brexit

If you export products to the UK, you charge 0% VAT to the client. This is only allowed if you can prove that your products have left the European Union. You can prove this with, for example, an export declaration or Bill of Lading. Although you do not owe Dutch VAT, you do have to register the revenue of your export to the UK on your VAT declaration. Register this under column 3a, delivery to countries outside of the EU.

The UK charges VAT for products exported to the UK. Who pays this VAT depends on your client and the Incoterms that are applicable.

Product requirements for export to the UK

The EU-wide CE marking has been dropped in the UK since Brexit was adopted. However, the UK will accept products with a CE marking until January 1, 2023. After this date, the UKCA marking will replace the CE marking. Medical devices are an exception to this rule and CE marking will be accepted for these devices until July 1, 2023.

More information on the UKCA marking and how to apply for it can be found on the UK Government website.

Some goods require export certificates. On Acces2Markets, you can find the certificates that apply to your products. You will also find on Acces2Markets information on packaging and labelling requirements for products in the UK.

Export to Northern Ireland. Special status

To avoid a hard border between Ireland and Northern Ireland, the UK and the EU have decided that Northern Ireland will be treated in practice as part of the EU's internal market and customs union when it comes to deliveries of goods.

This means that goods can cross the land border between Ireland and Northern Ireland without strict controls. Shipments between the EU and Northern Ireland do not require customs formalities. Nor do import duties that apply to the rest of the UK apply to exports to Northern Ireland.

Deliveries of goods to Northern Ireland are treated as deliveries to an EU country for VAT purposes. You should also state this in the declaration of Intra-Community supplies (ICP). Northern Ireland's special status does not apply to the provision of services. For the provision and purchase of services, Northern Ireland is considered a non-EU country.

These rules took effect on January 1, 2021 and are valid for 4 years. After this, the Northern Ireland Parliament will decide whether or not to continue the scheme for another period of 4 years.

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Article update: Since January 1, 2022, new rules have been in place for the export of goods to the UK. You can read about these in our new blog post New Brexit rules 2022 for export to the UK.

Useful links

• My Trade Assistant (Access2Markets)
• Netherlands Chamber of Commerce example texts and invoice declarations
• Information Dutch Tax and Customs Administration Rex registration
• Information on requesting a Netherlands EORI number
• Information on requesting a UK EORI number
• Brexit toolkit Dutch Tax and Customs Administration
• Information Authorised Economic Operator
• Information on the export of goods Netherlands Chamber of Commerce
• Product requirements UK after Brexit
• Pre-notify transport via Portbase
• Information digital data and export to the UK
• Information UKCA marking UK government