Dropshipping from UK to Poland – VAT, customs documents and how to do it legally

Dropshipping from the United Kingdom to Poland is a model that worked almost seamlessly before Brexit — goods moved within the EU with no customs clearance and no complex VAT settlement. Today the situation is entirely different. Since 1 January 2021, the UK is a third country with respect to the European Union, which means that every shipment from the UK to Poland is subject to export from the UK and import into the EU. For the owner of a Polish e-commerce store operating a dropshipping model with a British supplier, this means specific obligations: EORI registration, proper structuring of the supply chain, deciding who is the actual exporter from the UK and who is the importer into Poland — and, finally, how to account for VAT correctly on both sides of the border. This article explains each of these elements step by step so that you can run UK→PL dropshipping legally, without the risk of goods being stopped by HMRC or the Polish Customs and Tax Service.

How UK → Poland dropshipping works — three parties to the transaction

In classic UK dropshipping there are three parties:

Party	Role	Country
Polish store (your business)	Seller to the end customer	Poland / EU
UK supplier (wholesaler, manufacturer)	Physical sender of the parcel	United Kingdom
Polish customer	End buyer	Poland

The transaction works as follows: a customer places an order in your store, you pass the order to your UK supplier, the UK supplier packs the goods and ships them directly to the customer in Poland. You never physically handle the goods.

The post-Brexit problem is that this simple triangle now requires customs handling at two borders: export from the UK and import into Poland/EU.

Who is the exporter from the UK — the key question

This is the most important question, as it determines everything else. Two parties may export from the UK:

Option A: The UK supplier exports independently

The UK supplier declares the goods for export in the CHIEF/CDS system (the UK customs system), provides their UK EORI number as the exporter, and dispatches the shipment to Poland. The UK export declaration names the UK supplier as the consignor.

This is the simplest option for the Polish store. Your obligations on the UK side are minimal — you do not need a UK EORI. However, you lose control over the export documentation.

Option B: The Polish store exports from the UK (as "exporter of record")

If your Polish store holds a UK EORI and optionally a UK VAT number, you can be listed as the exporter from the UK. This gives you full control over the documentation and is required by some UK suppliers who do not wish to handle export declarations themselves.

Option C: No export customs declaration at all

HMRC is increasingly stopping commercial shipments that lack a correct export declaration. The risk: seizure of goods.

Who is the importer into Poland (Importer of Record)

On the Polish side, the importer is the party responsible for: - lodging the customs declaration (SAD/AES) in Poland - paying any applicable duty and import VAT - meeting the documentary requirements (commercial invoice, packing list, customs value declaration)

In the UK→PL dropshipping model, the importer of record is typically the Polish store, because you: - purchase the goods from the UK supplier (you are the buyer) - are registered as a business entity in Poland - hold a Polish NIP and EORI number (required for import declarations)

The end customer is NOT the importer — you, as the store, are responsible for the clearance. If you attempt to shift that responsibility onto the customer by sending parcels marked "gift" or to a private address without a declaration, you are acting contrary to customs regulations.

VAT in UK → Poland dropshipping — two levels

VAT on the UK side

If your Polish store is not registered for VAT in the UK: - The UK supplier sells you the goods without UK VAT (B2B export sale, zero-rated) - The UK supplier issues an invoice without VAT and declares the goods for export

If your Polish store is registered for VAT in the UK (e.g. you hold stock there or exceed the threshold): - The transaction becomes more complex and requires analysis with a tax adviser

VAT on the Polish side (import VAT)

On importation into Poland you pay import VAT. The rate is: - 23% for most goods - 8% or 5% for goods subject to reduced rates (food, medicines, etc.)

The taxable base for import VAT is the customs value of the goods plus duty plus transport and insurance costs to the EU border.

Good news: if you are VAT-registered in Poland, you may deduct import VAT as input tax (provided the goods are used for taxable business activities). You may also use the simplified procedure to deduct import VAT through JPK_VAT without actually paying it to the tax office upfront.

How to value goods correctly for customs clearance

This is a common mistake: Polish sellers declare the purchase price paid to the UK supplier (their wholesale price) as the customs value, whereas they should declare the transaction value — that is, the price paid by the buyer (the end customer to the Polish store).

Customs legislation (EU Regulation 952/2013 — the Union Customs Code) is clear: the customs value is the price actually paid or payable for the goods. In dropshipping, when the store purchases from the UK supplier, the customs value is the store→supplier price, not the customer→store price.

In practice, the commercial invoice should show: - the value of the goods (purchase price) - freight and insurance costs to the EU border (CIF/CFR) - the correct HS code

Risks for Polish sellers without a UK EORI

If you run dropshipping from the UK and: - you have no UK EORI or UK VAT number - your UK supplier ships as "gift" or understates the value - you do not file import declarations in Poland

You are exposed to: - shipments being stopped by HMRC at the export stage (missing export declaration) - goods being stopped by the Polish Customs and Tax Service at the Polish border due to absence of an import clearance - penalties for undervaluing the customs value - VAT arrears plus interest

Since 2022, HMRC has stepped up controls on B2C shipments from China and the USA, but the same rules apply to goods exported from the UK to the EU.

Solutions — how to organise UK→PL dropshipping legally

Option 1: UK supplier exports, Polish store imports

The cheapest and most common solution: 1. The UK supplier holds a UK EORI and lodges the export declaration themselves 2. They issue you a commercial invoice showing the correct value 3. You, as the Polish store (holding a Polish EORI), lodge the import declaration in Poland through a customs agent 4. You pay import VAT and deduct it in JPK_VAT

Option 2: Fiscal representative in the UK

If your UK supplier is unwilling to handle the export, you may appoint a UK fiscal representative or a customs agent in the UK to lodge the export declaration on your behalf. Costs: from £30–£80 per commercial shipment.

Option 3: Your own UK EORI (if the volume justifies it)

At high turnover it is worth considering registering for a UK EORI and optionally UK VAT. Cost of EORI registration: free (online registration via HMRC). UK VAT: mandatory once you exceed the £90,000 annual turnover threshold from UK customers.

Documents required for every UK→PL dropshipping shipment

Document	Issued by	Required by
Commercial invoice	UK supplier	Polish customs authority
Packing list	UK supplier	Polish customs authority
Export Declaration (EX)	UK exporter	HMRC UK
Import Declaration (IM)	PL importer / agent	Polish customs authority
Customs value declaration (DV1)	Importer	For consignments >20,000 EUR
Conformity declaration / certificates	Depending on goods	Depending on category

Windsor Framework and dropshipping from Northern Ireland

If your UK supplier is based in Northern Ireland (Belfast, Derry, etc.), the situation is different. The Windsor Framework (successor to the Northern Ireland Protocol) means that Northern Ireland remains within the EU customs area for goods. This means that goods shipped from Northern Ireland to Poland do not require a UK export or EU import in the traditional sense — they are treated as an intra-EU consignment. This is a significant simplification and is worth exploiting if you have suppliers in Northern Ireland.