Exporting to the UK After Brexit
By Rafael Paulo Krüger · Customs Expert & CEO
Since Brexit, GB is a third country. What exporters now need to know about export declarations, customs duty and proof of origin — explained simply.
A machinery maker in southern Germany had shipped spare parts to Birmingham for years much as it shipped them to Bavaria: write the invoice, hand over the parcel, done. Then came 1 January 2021. Suddenly the first shipment was stuck at the port of Calais — no export declaration, no ABD, no proof of origin. The customer waited, the truck stood idle, and the office was at a loss. Anyone still delivering to Great Britain today should understand why a routine delivery turned overnight into a full third-country export.
What changed on 1 January 2021
When the transition period ended on 31 December 2020, the United Kingdom (Great Britain and Northern Ireland) left the EU customs union and the single market. Since 1 January 2021, from the perspective of EU customs law, it is a third country, comparable to the United States or Switzerland.
An important distinction: the Republic of Ireland, by contrast, remains an EU member — it must not be confused with the United Kingdom in customs terms.
In practical terms: what used to be an intra-Community supply is now an export with all the formalities — the export on the EU side, the import on the British side.
Export declaration & ABD now mandatory
Anyone exporting goods from Germany to GB must lodge an electronic export declaration in the ATLAS system. The legal basis is the Union Customs Code (UCC), in particular Article 263 et seq. From the accepted declaration, the Export Accompanying Document (ABD) with its MRN (Movement Reference Number) is generated; it travels with the shipment to the customs office of exit.
The obligation to declare generally arises once the value of the goods exceeds €1,000 or the gross weight of the consignment exceeds 1,000 kg. Below both thresholds, simplified procedures may be possible in certain cases — but for commercial shipments, the full declaration is the norm.
What an ABD is exactly and how it is produced is explained in detail in our article What Is an ABD?. For exports to GB, the key point is this: without a valid ABD, your goods do not leave the EU customs territory properly — and the VAT zero-rating of the export cannot be demonstrated later.
Customs duty & EU–UK preferential origin
This is where the biggest misunderstanding lies. Under the Trade and Cooperation Agreement, the EU and the UK agreed on zero percent preferential customs duty — but not automatically for all goods. Zero duty applies only to goods that meet the rules of origin of the agreement, that is, goods that qualify as products originating in the EU.
Proof is provided by a statement on origin on the commercial invoice or another commercial document. This is a self-certification by the exporter — so no officially stamped movement certificate such as an EUR.1 is required. The condition is that the goods genuinely have originating status and that this can be substantiated on request.
Two points are often overlooked in practice:
- If goods do not meet the rules of origin, the standard third-country duty rate applies on the British side. The actual rate depends on the commodity code — blanket assumptions are dangerous here.
- The agreement does not remove UK Import VAT. This is charged regardless of the preferential customs duty.
Import on the UK side (EORI, import)
On the British side of the border, an import declaration is required. Who lodges it and bears the import charges depends on the agreed delivery terms (Incoterm).
For the EU export, you use your EU/DE EORI number. If you do not yet have one, our article Applying for an EORI Number describes how to get there. You need a British GB EORI only if you also act as the importer in the UK — that is, if you lodge the import declaration yourself. If you act only as the exporter and your customer handles the import, your EU/DE EORI is sufficient.
Common mistakes
After Brexit, the same stumbling blocks appear again and again in practice:
- Assuming zero duty applies automatically: without a correct statement on origin there is no preferential duty — and British customs duty is charged.
- Missing or incorrect proof of origin: the statement on origin must appear correctly on the commercial document.
- Missing EORI: without a valid EU/DE EORI, customs will not accept the export declaration; anyone importing into the UK additionally needs a GB EORI.
- Incomplete commercial invoice and commodity codes: wrong HS codes lead to queries, delays and incorrect duty calculation on the British side.
- Confusing the UK with the Republic of Ireland: the United Kingdom is a third country, while the Republic of Ireland remains an EU member — the two must not be treated the same in customs terms.
Conclusion
Exporting to Great Britain is no longer a foregone conclusion since Brexit, but with proper preparation — an export declaration with an MRN on the EU side, correct proof of origin for zero duty, and a clearly defined import role on the British side — it all runs smoothly. Anyone who has these building blocks under control delivers as reliably as before — just with the right paperwork.
For a full overview of the process, the obligations and our support with UK exports, see our page Exporting to the UK. There we guide you from the export declaration through to the proof of origin.