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Customs rules for trade with the EU

Since the UK has left the EU customs union, single market and VAT area, some businesses and individual constituents find the changing import and export procedures for goods challenging. The Trade and Cooperation Agreement (TCA) sets out the terms of UK trade with the EU from 1 January 2021. Below are the main sources of information that may help people dealing with constituency casework questions about customs rules.

This document is intended as a brief overview of some issues arising from trade with the EU. It is not a comprehensive guide to all aspects of imports and exports and does not cover the circumstances of any specific case.

Tariffs and rules of origin

The TCA ensures that no tariffs (taxes on imports) or quotas (quantitative import restrictions) apply to goods moving between the EU and UK, provided those goods meet the rules of origin (RoO). The RoO determine the ‘economic nationality’ of a good based on where it is made or where the materials (or inputs) used in its production come from. The RoO prevent goods manufactured in third countries from being re-routed through the UK (or the EU) to avoid paying third country tariffs.

To benefit from the TCA zero tariff, businesses must show the origin of their goods. A product qualifies as ‘originating’, if it is ‘wholly obtained’ in the UK or EU, or has been substantially transformed in one or both markets. As reported by the Financial Times, UK businesses re-exporting goods from third countries with little or no further processing may still face tariffs when trading with EU Member States.

Rules of origin are product-specific, and compliance can be onerous. Businesses sometimes cannot, or do not wish to, claim zero tariffs offered by the TCA. Overall, UK exporters make effective use of preferential rates, though their use varies by sector. In 2024, 83% of goods exported from GB to the EU27 made use of preferences where available. For agricultural exports from GB to the EU27 the preference utilisation rate was nearly 93%. Among the lowest rates were those for textiles (57%) and footwear and headgear (24%).

Great Britain-EU customs processes

Customs controls ensure customs tariffs are paid on goods moving across the border, and goods comply with safety, security, health, and environmental requirements.

The EU introduced full customs controls on 1 January 2021.

The UK Government has been phasing in border controls for goods imported from the EU since 2021. Customs declarations are now required for all goods imported into Great Britain. However, the introduction of full customs checks has been postponed several times.

The Border Target Operating Model (BTOM), first published in August 2023, set out the UK’s risk-based approach to imports into Great Britain of live animals, products of animal origin, plants and plant products from all countries, including the EU. Under the BTOM, agrifood goods are subject to identity and physical checks according to the risk they pose to biosecurity, public health, and food safety and security.

The BTOM proposed a phased introduction of the remaining post-Brexit border controls, including:

• health certification and sanitary and phytosanitary (SPS) checks on agrifoods;
• physical SPS checks on relevant EU imports at designated Border Control Posts; and
• safety and security declarations, which border authorities use to assess potential risks posed by goods crossing the border.

The BTOM also set out plans to digitise customs processes by introducing a Single Trade Window for businesses: a single digital gateway for most border requirements. However, in November 2024 the government announced that work on the Single Trade Window would be paused during 2025-26 while it reviews future border requirements and user needs.

SPS agreement on agricultural products, food and drink

As agreed at the UK-EU summit in May 2025, the UK and EU are negotiating a UK-EU SPS agreement to establish a common SPS area. Government guidance says the proposed agreement would remove most export certification and reduce routine border controls for many agrifood products. It would also facilitate trade in products such as chilled sausages, shellfish and seed potatoes, which has been affected by restrictions since Brexit. Guidance indicates that the government intends the agreement to take effect in mid-2027, although exact timings and detailed requirements are subject to the outcome of negotiations. Businesses in the agrifood sector are being encouraged to prepare for future changes to certification, border checks and regulatory requirements.

Which checks are in place?

From 31 January 2024, businesses must pre-notify imports of animals, certain plants and plant products, and high-risk food and feed. Certain high-risk animal and plant products require health certificates and checks. From 30 April 2024, documentary and physical checks on EU imports were gradually rolled out at Border Control Posts, focusing on medium-risk goods and goods with the highest biosecurity risk.

To cover the cost of SPS checks, businesses must pay a common user charge on imports of various risk categories of animal and plant products entering Great Britain through the Port of Dover or Eurotunnel.

In advance of an SPS agreement with the EU, the government has further postponed physical checks on medium-risk fruit and vegetable imports from the EU until 31 January 2027.

In short, businesses are responsible for:

• Making customs declarations on all goods exported from and imported into the UK (rules differ for moving goods in and out of Northern Ireland).
• Checking which special rules of licensing or certification apply to goods such as agrifoods or chemicals.
• Classifying goods and recording their origin. Incorrect commodity codes or inaccurate recording of origin in customs declarations may lead to incorrect amounts of tax or duty being charged. HMRC has published guidance on proving originating status and claiming a reduced rate of Customs Duty for trade between the UK and EU. Importers can check the applicable UK tariff duties and VAT rates using the HMRC Trade Tariff tool.
• Following the EU and UK requirements on safety and security declarations. On 31 January 2025, the UK introduced entry summary declarations for EU imports. Exports to the EU must include UK safety and security information and meet EU import safety and security requirements.

Expert help

Classifying goods and submitting customs declarations can be complex. HMRC maintains a list of private customs intermediaries – unvetted customs agents and express operators – whom businesses can ask to complete the paperwork on their behalf.

Further information

• HMRC website on import, export and customs for businesses has step-by-step guides on processes for international trade. HMRC’s Customs & International Trade Helpline number is 0300‌ ‌322‌ ‌‌9434.
• The gov.uk has a dedicated export support team for businesses exporting to the EU and the rest of the world.
• Dedicated gov.uk guidance explains how businesses can export food, drink and agricultural products.
• Different rules apply to Northern Ireland. Businesses moving goods between Great Britain and Northern Ireland can register for the free Trader Support Service.
• The European Commission portal, Access2Marketsis intended to help businesses importing into and exporting from the EU. A Commission website gives a brief overview of changes to trade with the UK brought in by the TCA. In individual cases, it is advisable to consult the involved EU Member State’s customs authorities.