B2B import of electrical equipment & electronics from the UK — RoHS, WEEE and customs documents

Electronics and electrical equipment (HS code 85) represent one of the largest trade flows on the UK–Poland corridor. Estimated values run into hundreds of millions of pounds a year — transformers, electric motors, PLC controllers, switchgear, cables, industrial and diagnostic equipment all flow from the UK to Polish manufacturers, system integrators and distributors. B2B import in this category is, however, far more than a customs declaration with an HS code and payment of duty. An importer must navigate regulations that have changed significantly on both sides of the border since Brexit: diverging RoHS (Restriction of Hazardous Substances) rules, WEEE registration requirements, the CE vs UKCA marking question, and documentary obligations on the UK export side. This article is a practical guide for Polish B2B importers sourcing electrical equipment and electronics from Great Britain.

HS85 classification — what falls within this chapter

HS code 85 (Electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers) is one of the broadest and most important chapters in the customs tariff. For B2B importers from the UK the most common subcategories are:

HS subcategory	Description	Examples
HS 8501	Electric motors and generators	Three-phase motors, servo motors
HS 8504	Transformers and converters	Mains transformers, UPS units
HS 8537	Switchboards and control panels	Control cabinets, PLCs
HS 8544	Electric cables and conductors	Industrial cables, wiring harnesses
HS 8471	Computers and data-processing equipment	Industrial PCs, IPCs
HS 8543	Other electrical apparatus	Welding machines, high-voltage power supplies
HS 8536	Switching apparatus	Circuit breakers, relays, connectors

Correct HS classification is critical — different sub-headings carry different duty rates and different documentary requirements. A misclassification can result in incorrect duty calculations and difficulties during HMRC controls.

Duty rates on electronics imported from the UK to Poland

Since Brexit the UK sits outside the EU Common Customs Tariff. Imports into Poland (EU) are subject to EU Common Customs Tariff (CCT) rates:

HS85 category	Duty rate (EU CCT)	TCA preference available
Electric motors (8501)	2.7%	Yes, if rules of origin met
Transformers (8504)	0–1.5%	Yes
Electric cables (8544)	2.7–3.7%	Yes
Switchgear (8537)	0%	N/A (already 0%)
Industrial computers (8471)	0%	N/A (ITA Agreement)
Welding machines (8515)	2.1%	Yes

TCA (Trade and Cooperation Agreement) preferences: Goods manufactured in the UK (meeting the TCA rules of origin) may be imported into the EU/Poland at a 0% rate. This requires an origin document: - For consignments below EUR 6,000: a statement on origin on the invoice (the exporter may issue this themselves) - For consignments above EUR 6,000: a statement on origin from a REX (Registered Exporter) or an EUR.1 certificate

Note: Many electronics products sold in the UK originate from China, Japan or other third countries. In such cases the TCA preferential rate (0%) does NOT apply — standard CCT rates apply instead.

UK RoHS vs EU RoHS — key differences after Brexit

RoHS (Restriction of Hazardous Substances) is the directive restricting the use of hazardous substances in electrical and electronic equipment. After Brexit the UK adopted its own version — UK RoHS — which is almost identical to EU RoHS 3 (Directive 2011/65/EU and amendments) but operates under a separate legal framework:

Aspect	EU RoHS (Directive 2011/65/EU)	UK RoHS (SI 2012 No. 3032 + amendments)
Regulatory body	European Commission + national authorities	Office for Product Safety and Standards (OPSS)
Legal basis	EU Directive	UK Statutory Instrument
Substances covered	Pb, Hg, Cd, Cr(VI), PBB, PBDE + 4 phthalates	Identical to EU RoHS
Marking	CE	UKCA (England/Wales/Scotland)
Declaration of conformity	EU DoC	UK DoC
Technical documentation	Manufacturer/EU importer	Manufacturer/UK importer

Practical consequence for a Polish importer: Electrical equipment purchased from a UK manufacturer with UK RoHS certification and a UKCA marking does not automatically carry EU RoHS certification with a CE mark. These are two entirely separate systems.

If you are importing equipment from the UK into Poland and intend to: - Use it in your own production — UK RoHS compliance may be sufficient (verify with a legal adviser) - Resell it in the EU / Poland — EU RoHS compliance and CE marking are required

Source: gov.uk — Restrictions on hazardous substances in electrical and electronic equipment (RoHS)

CE vs UKCA — which mark is required and where

After Brexit the UK introduced its own product safety mark — UKCA (UK Conformity Assessed). It replaces the CE mark on the Great Britain market (England, Wales, Scotland). Northern Ireland has separate provisions (Windsor Framework protocol — CE marking is still accepted there).

Target market	Required mark	Legal basis
Great Britain (England/Wales/Scotland)	UKCA	UK Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019
Poland (EU)	CE	Low Voltage Directive 2014/35/EU, EMC Directive 2014/30/EU
Northern Ireland	CE or UKCA	Windsor Framework

What this means for a Polish B2B importer purchasing equipment from the UK: - If the equipment carries only UKCA — you must check whether the manufacturer also holds an EU DoC with CE marking - Without CE, imported equipment should not be placed on the EU market (for sale, rental or leasing) - For own use within a manufacturing plant: the position is less clear-cut — seek advice from an occupational health and safety lawyer and the market surveillance authority (UOKiK)

Practical tip: When ordering equipment from the UK, always ask the supplier for an EU CE declaration of conformity (EU DoC) and EU RoHS compliance — separately from the UK UKCA and UK RoHS DoC.

WEEE obligations for importers in Poland

WEEE (Waste Electrical and Electronic Equipment Directive) is the EU directive governing the collection and recycling of waste electrical and electronic equipment. Poland implements it through the Act on Waste Electrical and Electronic Equipment (the ZSEE Act).

Obligations of a Polish importer/producer placing equipment from the UK on the market in Poland:

1. Registration in BDO (the Product and Packaging Database) — mandatory for anyone placing EEE (electrical and electronic equipment) on the market in Poland, including importers from third countries (the UK is a third country following Brexit)

2. Collection system — the importer must ensure a system for collecting waste equipment, either independently (own scheme) or by joining a recovery organisation (e.g. Elektroeko, REMONDIS, Alba Group)

3. Product fee — if the importer fails to meet the required collection targets, a product fee must be paid to NFOŚ (the National Fund for Environmental Protection)

4. Records of equipment placed on the market — documentation of the quantities and categories of equipment placed on the market, retained for 5 years

5. Reporting to BDO — annual reports on the quantities of equipment placed on and collected from the market

EEE categories covered by WEEE (selected): - IT equipment (computers, servers, printers) - Telecommunications equipment - Industrial equipment containing electronics - Electric motors and transformers (category depends on application)

Penalties for failure to register under WEEE in Poland: up to PLN 500,000 plus withdrawal of the authorisation to place goods on the market.

Customs documents required for importing electronics from the UK

Complete document checklist for B2B electronics imports from the UK to Poland:

Document	Required?	Notes
Commercial invoice	Yes	Value in GBP/EUR, description, HS code
Packing list	Yes	Gross/net weight, quantities
B/L or AWB	Yes	Sea: B/L; Air: AWB
CMR document	Yes (road)	Consignment note
Statement on origin or EUR.1	If TCA preference claimed	For 0% rate where UK origin applies
EU Declaration of Conformity (CE)	Yes, for EU resale	RoHS + LVD + EMC
EU RoHS certificate	Recommended	Confirmation of compliance
Customs value declaration (DV1)	Above PLN 150,000	Required by customs authority
Calibration certificate	For measuring equipment	Where applicable
Import licence	For dual-use products	HS85xx items subject to export controls

Common B2B mistakes when importing electronics from the UK

Mistake 1: Treating UKCA as equivalent to CE Equipment bearing the UKCA mark does not carry a CE certificate — these are two distinct, independent systems. Importers distributing equipment in the EU risk market withdrawal action by UOKiK or building-products supervisory bodies.

Mistake 2: Failing to register for WEEE in BDO Many B2B importers are unaware that by importing electrical equipment from the UK (a third country) they have the status of a "producer" within the meaning of the ZSEE Act and must register in BDO.

Mistake 3: Incorrect HS classification A transformer and a converter can have different HS codes (8504.21 vs 8504.40) with different duty rates. An incorrect classification can result in an HMRC or Polish customs authority audit up to three years later.

Mistake 4: No origin documentation when buying from a UK reseller When purchasing equipment from a UK distributor (rather than the manufacturer), it is often difficult to obtain a statement on origin confirming UK origin. Without it, the TCA preference is unavailable — you pay standard duty.

Mistake 5: Overlooking dual-use regulations Certain electronic devices (e.g. encryption equipment, telecommunications equipment, oscilloscopes with specific parameters) may be subject to UK Strategic Export Licensing controls. Importing without the appropriate licence may be unlawful.