Dropshipping to the UK — Who Is the Customs Importer and Who Is Responsible for VAT and Duty?

Who Is the Customs Importer in the UK — Definition and Legal Responsibility

The customs importer (importer of record) is the entity responsible for filing the import customs declaration in the UK and paying the customs duty and import VAT. Under UK customs law, the importer must hold a UK EORI (Economic Operators Registration and Identification) number and be registered as an entity operating within the UK customs regime. GOV.UK sets out these rules in official guidance on "appointing a customs representative". In dropshipping to the UK the importer is not obvious — it all depends on the operating model.

UK EORI — when a seller outside the UK needs one

<p>If you are a dropshipper based in Poland and file import customs declarations in the UK in your own name — you need a UK EORI number. A UK EORI is obtained by registering on GOV.UK. Details: <a href="https://www.gov.uk/eori">gov.uk/eori</a>. If you do not have a UK EORI and do not want to file declarations yourself — you can appoint a customs agent as:</p><ul><li><strong>Direct representative</strong>: the agent acts in your name and on your responsibility. You are the importer.</li><li><strong>Indirect representative</strong>: the agent is jointly responsible for the customs debt. This is less common and carries higher risk for the agent.</li></ul><p>Source: <a href="https://www.gov.uk/guidance/appoint-someone-to-deal-with-customs-on-your-behalf">GOV.UK — Appoint someone to deal with customs on your behalf</a>.</p>

Liability for the customs debt — who pays if something goes wrong

<p>The customs debt is the amount of duty and VAT owed on imported goods. If an import is carried out incorrectly — e.g. the declaration contains an incorrect HS code or an understated value — HMRC can retroactively assess a customs debt and recover it from the importer. In dropshipping: if the formal importer (e.g. the buyer) does not pay — HMRC may pursue the seller or the customs agent that filed the declaration as indirect representative.</p><p>This is why it is essential to establish the model precisely: who is the importer, who is the customs representative and how liability is allocated. This should be regulated in the contract between the seller and the customs agent.</p>

Three Dropshipping-to-UK Models — Customs Responsibility in Each

There is no single dropshipping-to-UK model. Depending on the supply-chain structure, who files the import declaration and who holds the EORI depends on: whether goods travel through an intermediate UK warehouse or directly to the customer, and whether the seller has a UK EORI. Below we describe the three most common configurations encountered in practice.

Model A — supplier ships from outside the UK directly to the customer

<p>The most common model: a Polish dropshipper sells goods through a website or marketplace to a buyer in the UK. The supplier (e.g. a wholesaler in China or Poland) ships the parcel directly to a UK address.</p><p><strong>Who is the importer?</strong> In this model it is most often the buyer — because they are collecting the goods and they pay the VAT and duty on collection (if the courier/postal service charges fees). However, if the shipment value is below £135 and the sale goes through a marketplace (e.g. eBay) — the platform handles UK VAT.</p><p>Problem: the buyer may refuse customs charges on collection (particularly above £135). In this situation the goods stay with the courier or are returned to the sender — and you bear the return costs. We recommend clearly informing the buyer of potential UK customs charges in the product listing and order confirmation.</p>

Model B — seller imports goods into the UK and stores them in a warehouse (3PL)

<p>The seller themselves imports goods into the UK (e.g. to a 3PL warehouse or fulfilment centre) and ships to UK customers. Technically this is not "classic dropshipping" — but many businesses organise their sales this way.</p><p><strong>Who is the importer?</strong> The seller. They must hold a UK EORI, account for UK VAT (registration required if sales exceed the threshold or when importing goods into the UK). A customs agent files the import declaration on the seller's behalf. Import clearance cost: <strong>from £45 to £150</strong>. <em>Prices quoted are indicative ranges — exact quote after document review.</em></p><p>This is the safest model from a customs liability perspective — but it requires investment in an EORI, UK VAT registration and logistics management. More on UK EORI registration: <a href="https://www.gov.uk/eori">gov.uk/eori</a>.</p>

Model C — sales through a marketplace, below £135 — the simplest customs configuration

<p>If you send every shipment below £135 through a marketplace (Etsy, eBay, Amazon) — the platform handles UK VAT and you as the seller are not the formal VAT importer. The courier or postal service still files a simplified customs declaration on entry into the UK (based on invoice data). No duty for most goods below £135 — not because duty has been abolished, but because HMRC applies simplifications for low-value goods.</p><p>HMRC Notice 702 (VAT) and official guidance describe these simplifications. HMRC may, however, decide to carry out a full inspection of every shipment — so documentation (invoice, HS code) must always be in order. Source: <a href="https://www.gov.uk/guidance/vat-and-overseas-goods-sold-to-customers-in-the-uk">GOV.UK — VAT for overseas sellers</a>.</p>

How to Run Dropshipping to the UK Legally — Practical Steps

Running dropshipping to the UK legally requires a conscious decision about the model and planning who handles the customs formalities. Below are concrete steps, regardless of the model you choose. Each step links to official sources — not general recommendations.

Step 1 — establish the model and identify the customs importer

<p>Before launching sales, answer the following questions:</p><ol><li>Will shipment values consistently be below £135 and do sales go through a marketplace? If yes — Model C, minimal formalities.</li><li>Do you want the buyer to be the importer (and pay duty themselves)? You must clearly inform them of additional charges.</li><li>Do you want to be the importer yourself? You need a UK EORI, UK VAT registration and a customs agent.</li></ol><p>Not making this decision is not "neutral". If HMRC cannot identify the importer — it may hold the goods or assess duty and VAT on the total import volume, then pursue the seller.</p>

Step 2 — ensure documentation for every shipment

<p>Regardless of the model, every shipment from abroad to the UK must include:</p><ul><li><strong>Commercial invoice</strong> — value, goods description, sender and recipient details.</li><li><strong>HS code of the goods</strong> — do not guess — check in HMRC Trade Tariff: <a href="https://www.trade-tariff.service.gov.uk/">trade-tariff.service.gov.uk</a>.</li><li><strong>Importer's EORI details</strong> — if filing a full declaration.</li><li><strong>Country of origin</strong> — important for determining the duty rate (zero or full).</li></ul><p>The duty rate for goods depends on the HS code and country of origin. For goods from the EU — zero duty (Trade and Cooperation Agreement UK-EU). For goods from China — MFN rates from the UK tariff. Details: <a href="https://www.gov.uk/guidance/check-reliefs-you-can-claim-for-your-imported-goods">GOV.UK — Check reliefs you can claim for your imported goods</a>.</p>

Step 3 — when to contact a customs broker

<p>Contact a customs broker when:</p><ul><li>shipments exceed £135,</li><li>you want to be the customs importer yourself (Model B),</li><li>goods come from outside the EU and duty rates are non-zero,</li><li>the supplier requests to act as importer on your behalf without your consent — this creates a risk of liability for someone else's customs debt.</li></ul><p>Easy Clearance acts as direct representative in the UK for dropshippers, filing import declarations in CDS and managing UK VAT. Import clearance cost: <strong>from £45 to £150</strong>. <em>Prices quoted are indicative ranges — exact quote after document review.</em> Contact us via WhatsApp: <a href="https://wa.me/447404091503?text=Enquiry+about+dropshipping+UK+importer&utm_source=easyclearance.pl&utm_medium=article&utm_campaign=dropshipping-do-uk-kto-jest-importerem-vat-clo">+44 7404 091503</a>.</p>

What the current rules say

In dropshipping to the UK the customs importer is the entity that formally enters the CDS system and is responsible for duty and VAT — this can be the seller, the buyer or an appointed customs representative. Three operating models (direct-to-customer chain, via UK warehouse, via marketplace below £135) have different customs and VAT consequences. Misidentifying the importer leads to HMRC penalties — this decision should be made before launching sales, not after the first goods are held. This article reflects the legal position as at 2026-04-18. Contact a customs broker before taking action.

FAQ — frequently asked questions

Who is the customs importer in dropshipping to the UK?

It depends on the model: if you ship directly to the customer — the buyer is often the formal importer. If you import goods into a UK warehouse yourself — you are the importer and need a UK EORI. If sales are below £135 through a marketplace — the platform handles UK VAT.

As a Polish dropshipper, do I need a UK EORI number?

You need a UK EORI if you file import customs declarations in the UK yourself. If you ship via a marketplace below £135 or the buyer is the importer — generally not. If you want to be the importer yourself or use a direct representative — a UK EORI is required.

Who pays customs duty and UK VAT in dropshipping?

Below £135 via marketplace: the platform handles VAT, duty is often zero for EU-origin goods. Above £135 or without a marketplace: the buyer or seller (depending on the arrangement) pays duty and import VAT on entry into the UK.

What is the penalty for misidentifying the importer in the UK?

HMRC can retroactively assess a customs debt for every incorrect shipment. In cases of understated value or incorrect HS code — administrative penalties and seizure of goods. The entity identified as importer is jointly liable for the customs debt.

How much does customs handling for dropshipping to the UK cost through a customs broker?

Import clearance cost: from £45 to £150. Prices quoted are indicative ranges — exact quote after document review. Contact Easy Clearance via WhatsApp or phone.

Official sources

• Appoint someone to deal with customs on your behalf — GOV.UK
• VAT for overseas sellers — HMRC — GOV.UK
• UK Trade Tariff — HS code search — HMRC
• Check reliefs you can claim for your imported goods — GOV.UK