DAP vs FCA Incoterms for UK Trade 2026: Who Pays Duty, Who Books the Carrier

The choice of Incoterms® 2020 rule determines costs and risks. In trade with the UK after Brexit, two rules have emerged as leaders: DAP (Delivered at Place) and FCA (Free Carrier). Why? Because they avoid customs pitfalls encountered with EXW (Ex Works) or DDP (Delivered Duty Paid).

DAP vs FCA at a glance

Both rules leave UK import duty and import VAT with the buyer. Neither makes the seller a UK taxpayer. The real split is who books the main carriage and whose problem it is when the truck is standing at the border.

Read the table bottom-up if you are choosing under time pressure: the duty and VAT rows are identical, so the decision is really about carrier control and demurrage risk. A more detailed cost split is in our guide on who pays duty and VAT on transport to the UK.

FCA (Free Carrier) – "I load, you carry"

It is a modern and safer version of the old EXW.

How does it work? You (Exporter) are responsible for: 1. Packing the goods. 2. Loading onto the vehicle provided by the client. 3. Performing export customs clearance.

The client (Importer) is responsible for: 1. Main transport (from PL to UK). 2. Import clearance in the UK. 3. Customs duty and VAT in the UK.

Why is it better than EXW? With EXW, the client is responsible for export clearance. When this is done poorly or through a foreign agent, you risk not receiving the IE599 confirmation. Under FCA you commission export clearance to your own agent, giving you full control over export evidence (and the 0% VAT rate).

DAP (Delivered at Place) – "I deliver, you clear customs"

The most popular Incoterm in road transport to the UK.

How does it work? You (Exporter) are responsible for: 1. Export clearance. 2. Transporting the goods to the client’s door in the UK (or other agreed location). 3. Risk during transport.

The client (Importer) is responsible for: 1. Import clearance in the UK. (Must find an agency to submit the goods to CDS). 2. Payment of customs duty and VAT in the UK. 3. Unloading of goods.

Key border: Your responsibility ends at delivering the goods "ready for unloading". But note: the driver cannot enter the UK until the client completes clearance (or at least a pre-lodged declaration). If the client is late, your vehicle waits at the border.

DAP vs FCA – which to choose?

Choose FCA if:

• You don’t want to worry about finding transport and ferries.
• The client has their own logistics and wants to collect goods with their own vehicle.
• You want to transfer your risk at the moment of loading in Poland.

Choose DAP if:

• You want to offer the client better service ("door-to-door delivery").
• You have a good transport company that manages ferry crossings.
• You want to control delivery time.

What to avoid?

• Avoid EXW: You lose control over IE599.
• Avoid DDP (unless you know what you are doing): You enter tax obligations in the UK (GB VAT registration), which generates significant administrative costs if done as a one-off.

Summary

In B2B relations with the United Kingdom:

• FCA = "You collect the goods, but I will handle export paperwork." (Tax safe).
• DAP = "I will deliver the goods to you, but you pay the customs duty". (Convenient for both parties).

Both rules are safe for the Polish exporter, provided export clearance in Poland is properly managed.

Three UK rules that Incoterms do not cover

Incoterms® 2020 are ICC contract rules. They allocate cost and risk between two companies — they do not decide who UK law will accept as the declarant, and they do not transfer ownership. Three UK-specific rules override the assumptions people make when they pick DAP or FCA.

1. A seller with no UK establishment cannot simply file the import entry

If a Polish seller decides to take on UK import clearance anyway (effectively moving towards DDP), it cannot act as its own declarant. HMRC guidance is explicit: for clients who are not established in the UK, indirect representation must be used, and the representative must itself be established in the UK. Under indirect representation, the agent and the principal are jointly and severally liable for any customs debt — so the agent is carrying the seller's duty exposure, and prices accordingly.

2. DDP triggers UK VAT registration from the first sale, with no threshold

The £90,000 registration threshold applies to UK-established businesses. It is not available to a non-established taxable person (NETP). An NETP must register for VAT if it makes any taxable supply in the UK, within 30 days of the first supply. This is the real cost behind the usual advice to avoid DDP for one-off shipments — not the customs paperwork, but a permanent UK VAT registration and filing obligation.

3. Postponed VAT accounting belongs to the buyer, and only if the declaration says so

Under both DAP and FCA the UK buyer can account for import VAT on its VAT Return instead of paying it at the border. No prior approval from HMRC is needed, but two conditions must both hold: the goods are for the importer's business use, and the importer's VAT registration number appears on the import declaration. If a customs agent is filing, HMRC requires written instructions from the importer before the agent may use postponed VAT accounting. Postponed accounting is not available for consignments over £135 received through Royal Mail Group.

And one border rule that decides whether DAP hurts

At GVMS locations the haulier must hold a goods movement reference (GMR) containing the declaration references for everything on the vehicle before presenting the goods at the port. Missing or incomplete instructions can attract a penalty of up to £2,500. Under FCA that is the buyer's truck and the buyer's problem. Under DAP it is the seller's truck sitting in a queue — which is why DAP quotes should carry a waiting-time clause. If it has already happened, see what to do when a GMR is missing at the UK border.

Official sources

• GOV.UK: Customs declarations — direct and indirect representation — GOV.UK / HMRC, 2026-08-27
• HMRC VATREG37150: non-established taxable persons (NETPs) — GOV.UK / HMRC, 2026-08-27
• VAT Notice 700/1: who should register for VAT — GOV.UK / HMRC, 2026-08-27
• GOV.UK: check when you can account for import VAT on your VAT Return — GOV.UK / HMRC, 2026-08-27
• GOV.UK: get a goods movement reference (GVMS) — GOV.UK / HMRC, 2026-08-27
• GOV.UK: customs debt liability — GOV.UK / HMRC, 2026-08-27
• GOV.UK: using the Customs Declaration Service — GOV.UK / HMRC, 2026-08-27