Post-Brexit UK Customs: EORI, CDS, UKCA, and VAT Guide for US Exporters
What Changed After Brexit for US Shippers?
When the United Kingdom left the European Union’s Single Market and Customs Union on January 1, 2021, every shipment entering the UK became subject to full customs declarations, regardless of origin. For US exporters, the practical change was less dramatic than for EU shippers (US goods already required customs clearance before Brexit), but the regulatory framework shifted significantly.
The UK now operates its own customs system (CDS), its own tariff schedule (UK Global Tariff), its own product standards regime (UKCA marking), and its own VAT collection mechanism (postponed VAT accounting). These are all separate from the EU equivalents that previously applied when the UK was a member state.
The UK government publishes comprehensive guidance for importers and exporters at gov.uk/topic/business-tax/import-export. HM Revenue and Customs (HMRC) administers the customs and VAT systems.
EORI Numbers: The Starting Point
Every business importing goods into the UK needs an EORI number (Economic Operators Registration and Identification) starting with “GB”. This is a prerequisite for filing customs declarations, and without it, goods cannot clear customs.
Key facts about UK EORI numbers:
– UK EORI numbers are separate from EU EORI numbers. If you previously had a UK EORI when the UK was in the EU, it was automatically converted to a GB-prefixed number.
– US exporters do not need their own UK EORI. The UK-based importer (your buyer, distributor, or customs broker) needs the EORI.
– If you sell DDP (Delivered Duty Paid) to UK buyers, you or your customs representative need a UK EORI and UK VAT registration.
– EORI applications are processed by HMRC and typically take 5 to 7 working days. The application is submitted online at gov.uk/eori.
– An EORI number is valid indefinitely unless the business ceases trading or HMRC revokes it.
For Northern Ireland, the situation is different under the Windsor Framework. Businesses moving goods into Northern Ireland need an EORI starting with “XI” and must comply with the EU’s Union Customs Code for goods entering from outside the EU.
CDS: The UK’s Customs Declaration Service
The Customs Declaration Service (CDS) replaced the legacy CHIEF (Customs Handling of Import and Export Freight) system in full by March 2024. All UK import and export declarations are now filed through CDS.
CDS is operated by HMRC and accessed through the Government Gateway. Customs brokers and freight forwarders file declarations on behalf of importers using community system provider (CSP) software that interfaces with CDS.
A standard UK import declaration through CDS includes:
– Importer’s GB EORI number
– Commodity code from the UK Trade Tariff (available at trade-tariff.service.gov.uk)
– Customs Procedure Code (CPC) indicating the type of import (standard import, temporary import, inward processing, etc.)
– Customs value (transaction value under the applicable Incoterm)
– Country of origin and country of dispatch
– Transport details (vessel/flight, port of loading, port of arrival)
– Document references (invoice number, B/L or AWB number, certificates)
CDS uses the WCO Data Model and requires more data fields than the old CHIEF system. Importers and their brokers should ensure their commercial invoices contain all required information to avoid queries that delay customs release.
The HMRC guidance on making declarations through CDS is at gov.uk/guidance/making-a-full-import-declaration.
UK Global Tariff: Duty Rates for US Goods
The UK Global Tariff (UKGT) replaced the EU Common External Tariff on January 1, 2021. The UKGT simplified many tariff lines and eliminated duties on certain products that the UK does not produce domestically.
There is currently no free trade agreement between the United States and the United Kingdom. US goods therefore enter the UK at MFN (Most Favored Nation) rates under the UKGT.
Typical UKGT duty rates for US export categories:
– Industrial machinery: 0% to 3.7%
– Electronics and computers: 0% to 14% (many at 0%)
– Medical devices: 0%
– Automotive parts: 2.5% to 6.5%
– Chemicals: 0% to 6.5%
– Plastics: 0% to 6.5%
– Textiles: 6.5% to 12%
– Clothing: 8% to 12%
– Footwear: 8% to 17%
– Food and beverages: 0% to 20%+ (agricultural products have complex tariff structures)
– Furniture: 0% to 3.7%
The UK government’s online tariff lookup tool at trade-tariff.service.gov.uk provides the exact duty rate for any commodity code. This tool also shows any anti-dumping duties, countervailing duties, or tariff suspensions that may apply.
UKCA Marking: Product Compliance for the UK Market
The UK Conformity Assessment (UKCA) mark is the UK’s post-Brexit equivalent of the EU’s CE mark. It indicates that a product meets the safety, health, and environmental requirements set out in UK legislation.
The timeline for UKCA implementation has been extended multiple times. As of 2026, the UK government has announced that CE marking will continue to be accepted for most product categories placed on the market in Great Britain (England, Scotland, Wales) until at least 2027. However, UKCA marking is already mandatory for certain categories, and the transition deadline will eventually require all applicable products to carry the UKCA mark.
Product categories within UKCA scope include:
– Electrical equipment (Low Voltage Directive equivalent)
– Electromagnetic compatibility
– Machinery
– Personal protective equipment
– Toys
– Radio equipment
– Pressure equipment
– Medical devices (separate MHRA regime)
– Construction products
The UKCA marking process requires:
1. Identify the applicable UK statutory instrument (the UK equivalent of the EU directive)
2. Ensure the product meets the essential requirements
3. Have the product tested by a UK Approved Body (the UK equivalent of an EU Notified Body) where third-party assessment is required
4. Prepare the UK Declaration of Conformity
5. Affix the UKCA mark to the product or packaging
The official UKCA guidance is at gov.uk/guidance/using-the-ukca-marking.
Northern Ireland follows different rules. Products placed on the Northern Ireland market must carry the CE mark (or UKNI mark when a UK body is used for conformity assessment), in accordance with the Windsor Framework.
VAT on UK Imports: Postponed VAT Accounting
UK VAT at 20% applies to all imports, calculated on the customs value plus any duty payable plus freight and insurance costs. A reduced rate of 5% applies to some products (children’s car seats, home energy), and a zero rate applies to most food, children’s clothing, books, and newspapers.
Since January 2021, the UK has offered Postponed VAT Accounting (PVA) as the default method for accounting for import VAT. PVA works similarly to the Netherlands’ Article 23 mechanism:
– Import VAT is not paid at the border
– Instead, it is accounted for on the importer’s quarterly VAT return (Box 1 as output tax, Box 4 as input tax)
– The net effect is zero cash outlay for VAT-registered businesses
– HMRC issues monthly postponed import VAT statements through the Customs Declaration Service, which importers use to complete their VAT returns
PVA is available to all UK VAT-registered businesses. No separate license or application is required. The importer simply selects the PVA option in the customs declaration through CDS. This is a significant advantage over the pre-Brexit process where import VAT had to be paid at the port or deferred through a specific duty deferment account.
The HMRC guidance on PVA is at gov.uk/guidance/check-when-you-can-account-for-import-vat-on-your-vat-return.
Safety and Security Declarations
All goods entering the UK require a safety and security declaration, known as an Entry Summary Declaration (ENS). For ocean freight, the ENS must be submitted at least 24 hours before loading at the port of departure. For air freight, it must be submitted before departure.
The ENS contains information about the goods, shipper, consignee, and transport routing that allows HMRC and Border Force to assess security risks. The declaration is filed by the carrier or their agent through the S&S GB system.
For US exporters, this means your shipping documents (commercial invoice, packing list, bill of lading) must be accurate and complete well before the vessel departure date. Incomplete or incorrect information can result in the ENS being rejected, which prevents loading of the cargo.
UK REACH: Chemical Regulations
The UK has established its own chemical registration system, UK REACH (Registration, Evaluation, Authorisation and restriction of Chemicals), separate from EU REACH. UK REACH is administered by the Health and Safety Executive (HSE) at hse.gov.uk/reach.
If you export chemicals or products containing chemical substances to the UK, you may need to register under UK REACH. The transition period has been extended multiple times, and the current deadlines depend on the substance tonnage band and whether it was previously registered under EU REACH.
For US chemical exporters, a UK-based “Only Representative” can be appointed to handle UK REACH registration on behalf of a non-UK manufacturer, similar to the Only Representative role under EU REACH.
How ExFreight Handles Post-Brexit Compliance
ExFreight’s USA-to-UK freight forwarding service includes full post-Brexit customs management. Our UK customs brokers file all CDS declarations, handle duty and VAT calculations, and advise on UKCA requirements for your products. We manage ocean freight from all major US ports (New York/Newark, Savannah, Norfolk, Houston, LA/Long Beach) to UK ports (Felixstowe, Southampton, London Gateway, Liverpool, Tilbury) with transit times of 8 to 14 days.
For air freight, we operate on the JFK-LHR, ORD-MAN, and ATL-LHR corridors with 1 to 2 day door-to-door delivery. All shipments include real-time tracking from US pickup through UK customs clearance and final delivery.
