Trade between the European Union and the United Kingdom has changed beyond recognition since January 2021, that is, since the end of the Brexit transition period. The rules of taxation, the regulations on imports and exports, and the administrative requirements for customs and border clearance have all changed. What should you know as a business owner, and how has everyday business life in trade with the UK changed? What effects of these changes can be expected? Let’s take a look.

Summary & key takeaways

  • From 2021 the UK is outside the customs union, and goods face full customs formalities.
  • Every business trading with the UK needs an EORI number.
  • Exports to the UK at the 0% VAT rate require confirmation via an IE599 message.
  • Excise goods brought into the EU are subject to excise duty when released for circulation.
  • The Polish government portal brexit.gov.pl publishes up-to-date guidance for businesses.

New customs formalities

From 2021, the United Kingdom is no longer in a customs union with the EU, with the exception of special arrangements on the border between Northern Ireland and the Republic of Ireland. As a result of this change, the customs formalities required by the European Union apply to all goods imported from or exported to the UK. This means that both on the EU side and the UK side, checks are carried out under the procedures used for transporting goods to and from third countries.

The direct consequence of the new customs formalities will be longer transport times for goods and more complicated red tape around border crossings. From 2021, every trader needs an EORI economic operator registration and identification number. How do you get an EORI number? The relevant application and further information can be found at www.puesc.gov.pl.

VAT and customs duty

Poland’s Ministry of Finance has announced that, in light of the Brexit-related changes, EU goods transported from Poland to the United Kingdom must be declared under the export procedure. Once the export procedure is complete and the goods have left the customs territory of the Union, the business receives an IE599 electronic message, which serves as proof for applying the 0% VAT rate.

In transit, in turn, goods should move between the EU and the UK under a transit procedure. It is up to the business to choose one of the procedures: the common transit procedure in the NCTS system or the TIR procedure.

The nature of VAT also changed from January 2021, with the exception of trade with Northern Ireland. According to the Ministry of Finance, transactions such as intra-Community supply/acquisition of goods and distance selling (B2C) will no longer take place; instead, there will be exports/imports of goods. If you are interested in the VAT changes in the United Kingdom, take a look at our detailed analysis in one of our articles.

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Excise duty

When the United Kingdom left the European Union, the rules governing trade in excise goods also changed. As a reminder, the goods currently covered by these rules are: alcoholic beverages, tobacco products, energy products, electricity, raw tobacco, e-cigarette liquid, novel tobacco products, and passenger cars. Excise duty on excise goods will be due when these goods are brought into EU territory and collected on release for free circulation. This is a burden that every company in England exporting excise goods after Brexit will notice.

Where to look for further information and help for businesses?

After Brexit, Poles are looking for detailed information on the changes and the new rules of cooperation between the European Union and the United Kingdom. Because the agreement between London and the EU was concluded relatively recently, the regulations still contain gaps and procedures that have not been fully worked out. So where should you look for further information?

At www.brexit.gov.pl, a dedicated Polish government portal set up to help people navigate the new reality, you will find information on the key changes for businesses, additional recommendations, and links to pages with more detailed information on trade.

Many businesses are trying to adapt to the changes brought about by the relationship between Brexit and trade. The new rules, procedures and taxes will certainly cause chaos in EU-UK relations, but over time those involved in trade should get used to the new order.

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