Exporting goods to the UK - Complete 2026 Guide
Exporting from Poland to the UK requires two clearances: export clearance in the EU (a declaration in the AES system on PUESC) and import clearance in the UK (a declaration in CDS with an EORI number starting with GB), plus an S&S GB declaration and – for RoRo transport – a GMR number. 0% duty requires documented origin of the goods under the TCA.
Status
verified against official sources
Author
easyclearance.pl teamPublished
18 February 2026
Updated
25 October 2026
Quick definition
Four things decide whether an export to the UK runs smoothly: (1) EORI numbers on both sides, (2) the correct commodity code, (3) proof of origin if you want 0% duty, (4) a full set of references (MRN, S&S GB, GMR) before boarding the ferry or entering the tunnel. Below is each step with the name of the system and the party responsible.
The formalities on the UK side (import declaration in CDS, ENS, GMR) are described on the page UK customs clearance for businesses.
Since 1 January 2021 the United Kingdom has been a third country for Poland, so a sale to the UK is an export from the European Union and, at the same time, an import into Great Britain. Below we go through the whole route: from the export declaration in Poland, through the documents and proof of origin, to the import clearance in the UK. This information is operational and is not legal or tax advice.
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Exporting to the UK after Brexit – what has changed
Before 2021 goods moved between Poland and the UK without customs clearance. Today every commercial shipment goes through two procedures: a Polish (EU) one and a British one. Both parties need an EORI number, and who is responsible for each declaration depends on the Incoterms agreed in the contract – so it is worth starting with the comparison of DDP, DAP and EXW in trade with the UK. Exports to England, Scotland and Wales follow the rules described in this article; Northern Ireland has separate rules (including an EORI number starting with XI), which we cover separately.
Exporting to the UK step by step
- EORI numbers. A Polish exporter needs an EU EORI number (how to get one). Importing into England, Scotland and Wales requires a UK EORI number starting with GB – GOV.UK notes that an EORI number that does not start with GB has to be replaced with a new one.
- Commodity code. The code in the import declaration determines the rate of duty and whether a licence is needed. You can check it in the UK Trade Tariff; practical tips are in our article on HS/CN classification.
- Commercial documents. Invoice, packing list, transport document and – for 0% duty – a statement on origin (details below).
- EU export declaration. Submitted electronically in the AES system on the PUESC platform (see the section on the export procedure).
- S&S GB declaration. A safety and security declaration made before the goods arrive in Great Britain.
- GMR/GVMS. A GMR number for RoRo movements through ports using GVMS.
- UK import clearance. A declaration in CDS, payment of duty and VAT, or accounting for VAT through PVA.
Customs clearance in the UK – who makes the import declaration and how
According to GOV.UK, you can make the import declaration yourself or hire a customs agent or transporter to do it; GOV.UK notes that most businesses that import goods use a transporter or customs agent. The value of the goods helps work out the duty and VAT, and HMRC tells you how much to pay after you submit the declaration.
Accounting for import VAT. A business registered for VAT in the UK can account for import VAT on its VAT Return (postponed VAT accounting) instead of paying it at the border. If an agent makes the declaration, they must be told in writing that you want to use it, and the declaration must include your details as the consignee. More on the costs on the other side in the article duty and VAT in trade with the UK. The UK import clearance service is described on the page export to the UK – clearance; prices are given only in the price list.
Import declarations are submitted in the Customs Declaration Service (CDS) – see CDS: how the declaration system works.
Customs procedures in Poland – the export declaration and proof of exit
The Union Customs Code (Regulation (EU) No 952/2013) provides that Union goods to be taken out of the customs territory of the Union are placed under the export procedure (Article 269) and are to be covered by a pre-departure declaration (Article 263). Goods brought out of the customs territory of the Union are subject to customs supervision (Article 267). On PUESC, the export customs declaration is submitted in the AES system (Automated Export System).
VAT on export. The VAT Directive (2006/112/EC, Article 146(1)(a) and (b)) requires Member States to exempt supplies of goods dispatched or transported outside the Union by or on behalf of the vendor, or by or on behalf of a customer not established in the Member State concerned. In practice, the 0% rate relies on evidence that the goods actually left the Union. What to do if the confirmation of exit is missing: missing IE599 when exporting to the UK and 0% VAT on exports to the UK.
Documents for exporting to the UK
The basis is a commercial invoice with full details: the parties to the transaction, description of the goods, quantity, net and gross weight, value, Incoterms and country of origin. Errors on the invoice are a common cause of goods being held – see required invoice elements and the most common invoice errors. The full list of documents is in PL–UK export documentation. Some goods also need licences, certificates or an inspection before release – GOV.UK notes that you might have to pay a fee for the inspection.
0% duty and origin of goods (the TCA)
The preferential rate of duty in EU–UK trade applies only to goods that meet the rules of origin of the Trade and Cooperation Agreement (TCA). The preference is claimed by the importer in the import declaration, and the importer must have one of two proofs: a statement on origin made out by the exporter, or the importer’s knowledge.
- The statement on origin is a text set out in the agreement, which the exporter puts on the invoice or another document describing the goods. The exporter must hold information proving the origin, including supplier declarations where needed.
- A REX number is required in the EU if the exporter’s consignments have a total value of more than 6,000 euros; in the UK, the exporter’s reference number is the EORI number.
- Validity: for imports into the UK the statement is valid for 2 years from the date it was made out; it may cover multiple shipments of identical products within a period of up to 12 months.
- Small consignments: for imports into the UK, no formal proof is required where the total value of the goods is under £1,000.
- Claiming after import: preference can also be claimed after importation, within 3 years of the import date, with a valid proof of origin.
- Records: the exporter and the importer keep the evidence for at least 4 years.
Goods that do not meet the rules can still be sold, but are subject to the standard duty. A practical overview: the REX system and the statement on origin.
S&S GB and GMR – declarations before the border
Safety and Security GB (S&S GB). The safety and security declaration is made before the goods arrive in Great Britain (GOV.UK allows it to be submitted up to 200 days in advance). The carrier is responsible for it, but may use a third party, such as a customs agent; if a third party files the declaration, do not file one yourself for the same goods. A business not established in Great Britain needs an EORI number starting with GB. The temporary waiver for goods from the EU no longer applies – see ENS/S&S GB declarations.
GMR and GVMS. A GMR number is created in the GVMS system; for RoRo movements GOV.UK lists the ports where it is always mandatory: Dover, Eurotunnel, Fishguard, Heysham, Holyhead, Liverpool, Pembroke and Newhaven. The GMR includes, among other things, the vehicle or trailer registration number and the declaration references (MRN), depending on the route. GOV.UK states that a carrier must tell a haulier with an invalid GMR that they cannot embark until they get the correct information, and that using the wrong GMR option can lead to delays and a penalty. See: GMR and GVMS.
UK customs clearance and regulated sectors
Some goods need additional certificates or marking: electronics, medical devices, cosmetics, food of animal origin, alcohol and tobacco. Sector guides are listed below. Check the requirements for food and agricultural products on the GOV.UK sector pages on the day of transport.
The most common mistakes when exporting to the UK
- No UK (GB) EORI number held by the party that is to make the import declaration.
- Incoterms not assigned – nobody knows who declares the goods in the UK.
- No statement on origin while expecting 0% duty.
- A missing or incorrect GMR when entering a port using GVMS.
- No confirmation of exit and, as a result, a problem justifying the 0% VAT rate.
If the goods are already stuck: what to do when goods are stuck at the border. A detailed description of the process: export customs clearance step by step and the export procedure in Poland.
Sector guides: exporting to the UK by type of goods
- Commercial invoice to the UK – 7 elements required by HMRC
- Errors on commercial invoice – 7 major faults that will hold your goods
- REX system and Statement of Origin – how to use 0% customs duty in exports to the UK?
- Commodity code (HS Code / CN) – how to avoid classification errors?
- Electronics export to the UK – plugs, UKCA and ROHS
- Export of construction materials to the UK – product certification
- Export of medical devices to the UK – registration with MHRA
- Export of tobacco products to the UK – Track & Trace and excise
- Export of industrial machines to the UK – UKCA, CE, declaration of conformity [2026]
- Export of windows and joinery to the UK – requirements, duties and UKCA [2026]
- Exporting cosmetics to the UK – UK REACH, UKCA and SCPN requirements [2026 Guide]
- Export of fertilisers and chemicals to the UK – UK REACH and precursors
- Export of timber and wood products to the UK – FLEGT and CITES
- Exporting furniture to the UK – customs, certificates and UKCA requirements [Guide 2026]
- Export of ceramics and glass to the UK – customs duty and heavy metals
- Export of toys to the UK – safety and UKCA marking
- Export of dietary supplements to the UK – registration and labelling
- Export of alcohol to the UK – excise, EMCS and duty stamps
- Export of pet food to the UK – veterinary requirements
- Food export (POAO) to the UK – meat, dairy and health certificates
- Export of clothing and textiles to the UK – high duty and labelling requirements
- Export of steel and metal products to the UK – quotas and 0% duty
- Export of fruits and vegetables to the UK – phytosanitary controls
- Export of car parts to the UK – Automotive post-Brexit
- Export customs clearance in Poland – step by step [Procedure 2026]
FAQ – frequently asked questions about exporting to the UK
What does exporting from Poland to the UK involve?
It consists of export clearance in the EU (a declaration in the AES system on PUESC) and import clearance in the UK (a declaration in CDS). You also need EORI numbers, an S&S GB declaration and, for RoRo transport through ports using GVMS, a GMR number.
Does every shipment to the UK require customs clearance?
Yes. Since 1 January 2021 the United Kingdom has been a third country for Poland, so commercial goods need an export declaration in the EU and an import declaration in the UK. This does not mean that every shipment will be physically inspected.
Is there customs duty on exports to the UK?
Not always. Goods that meet the TCA rules of origin can benefit from the preferential rate of duty if the importer has a proof of origin – the exporter's statement on origin or the importer's knowledge. Goods that do not meet the rules are subject to the standard duty, and import VAT is due regardless.
Which EORI number do I need to export to the UK?
A Polish exporter needs an EU EORI number. Importing into England, Scotland and Wales requires a UK EORI number starting with GB, and for Northern Ireland a number starting with XI may sometimes be needed.
Who makes the import declaration in the UK?
You can make it yourself or hire a customs agent or transporter; according to GOV.UK, most businesses that import goods use a transporter or customs agent. Who is responsible for the UK declaration follows from the agreed Incoterms.
When is a GMR number needed?
A GMR number is needed for movements through ports using GVMS. For RoRo movements it is always mandatory at, among others, Dover, Eurotunnel, Holyhead, Fishguard, Heysham, Liverpool, Pembroke and Newhaven. GOV.UK states that a haulier with an invalid GMR cannot embark until they get the correct information.
How can I avoid delays at the border?
Send the documents to the customs agency before the transport leaves, so that the declarations and references (MRN, S&S GB, GMR) are ready before clearance. The driver must have all the numbers before reaching the port or terminal.
See also the clearance price list and the UK export knowledge hub.
Need help exporting to the UK?
Easy Clearance is a customs agency registered in CDS, with a UK EORI number. We handle import declarations in Great Britain for Polish exporters. Send an enquiry through the contact form or see the service page: export clearance to the UK. For transit see T1 transit, and for RoRo transport – GMR/GVMS.
What the current official rules mean
The rules above are based on GOV.UK / HMRC, the Union Customs Code, the VAT Directive and PUESC. Before shipping, compare them with the position on the day of transport, because systems and port requirements change.
Official sources
- GOV.UK: Import goods into the UK – step by step — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Get UK customs clearance when importing goods — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Rules of origin and claiming duties between the UK and EU — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Proving originating status and claiming a reduced rate of Customs Duty — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Making an entry summary declaration (S&S GB) — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Get a goods movement reference — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Check if a goods movement reference is valid — GOV.UK / HMRC, 2026-10-25
- GOV.UK: List of ports using the Goods Vehicle Movement Service — GOV.UK / HMRC, 2026-10-25
- GOV.UK: Check when you can account for import VAT on your VAT Return — GOV.UK / HMRC, 2026-10-25
- GOV.UK: UK Trade Tariff — GOV.UK / HMRC, 2026-10-25
- EUR-Lex: Regulation (EU) No 952/2013 – Union Customs Code — EUR-Lex, 2026-10-25
- EUR-Lex: Directive 2006/112/EC (VAT) — EUR-Lex, 2026-10-25
- PUESC: Export of goods (in Polish) — National Revenue Administration (KAS), 2026-10-25
- European Commission: customs procedures – import and export — European Commission, 2026-10-25
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