First export from Poland to the UK — checklist from EORI to export confirmation

Before you send your first shipment — what to settle first

Before the goods leave your warehouse, you need to know what you are shipping, what it costs, what customs duty rules will apply, and whether you are entitled to a tariff preference. These are business and regulatory decisions simultaneously, so it is worth making them consciously.

1. Check the CN code (HS/commodity code)

Every product has a Combined Nomenclature (CN) code, the same in Poland and the UK. The code is 8 digits for customs purposes (in the UK Global Tariff you may encounter 10 or 15 digits for additional detail). The code determines the duty rate, VAT treatment, and the required documents (certificates, permits, health declarations). Check the code in TARIC (https://ec.europa.eu/taxation_customs/dds2/taric/) for Poland, or the UK Global Tariff tool for the UK. If you are unsure, use the broadest category code within the relevant chapter.

2. Establish the target duty rate in the UK Global Tariff

The UK Global Tariff is the UK's unilateral duty rate applied by default. The rate depends on the commodity code. Note: without the TCA (Trade and Cooperation Agreement) preference, you will pay this rate. The 0% preference is possible but requires the rules of origin to be satisfied and evidence to be provided.

3. Assess TCA rules of origin — do you qualify for 0%?

The TCA allows 0% duty, but only if the goods satisfy the rules of origin (RoO). What matters is where the primary material originates and how much processing has been carried out in Poland. If your product contains components from third countries, it may not qualify. As the exporter, you can attach a "statement on origin" — a self-declaration confirming that the rules have been met. Alternatively, the UK importer may rely on "importer's knowledge". Without evidence — MFN rates apply, sometimes significantly higher.

4. Agree Incoterms 2020 with your buyer

You need to know who pays for transport and insurance, and who deals with the customs agent. The most common terms: EXW (collection from your premises), FOB (you cover costs to the port of loading), CIF (cost, insurance, freight — you cover to the port of destination). Incoterms determine who must hold an EORI and who signs the customs documents.

Step by step: from EORI to export confirmation

On the Polish side

Step 1 — Obtain/check your EORI with a PL prefix

If your company has not yet registered in PUESC, do it now. EORI (Economic Operators Registration and Identification) is a unique number — each company has one. In Poland the prefix is PL, e.g. PL1234567890. Registration is done via the PUESC portal (https://puesc.gov.pl/) — managed by the Ministry of Finance. Proof of registration will be required for every export and import declaration. If you already have a number, verify that it is active.

Step 2 — Confirm your buyer has a GB EORI

The UK importer must have their own EORI number with a GB prefix (e.g. GB123456789). They register themselves at gov.uk/eori by completing an online form. This is their responsibility, but make sure to check early — if they do not have a number, a UK import declaration will not be possible. If your buyer uses a customs agent, that agent must also hold an EORI (or be registered as a representative).

Step 3 — Prepare commercial documents: invoice, packing list, certificates

The standard commercial document set is: (1) Commercial invoice (proforma or commercial) — includes product description, quantity, FOB/CIF value, seller and buyer details, dates. (2) Packing list — shows what is in each parcel/pallet, weights, dimensions, reference numbers. (3) CN codes for each line item (if different codes apply). (4) Certificates/declarations where required (origin, quality, conformity). (5) Transport documents: CMR (road transport), B/L (bill of lading) for sea, AWB (airway bill) for air. All documents must be legible and consistent — discrepancies frustrate customs agents on both sides.

Step 4 — Submit an export declaration in the AES system (PUESC)

This is the critical step. In the PUESC portal you complete an Administrative Entry Summary (AES) form — i.e. the export declaration. You enter: the exporter's EORI (yours), the importer's EORI (the buyer's), the commodity code, quantity, weight, value, carrier, reference document (invoice number), place of loading, place of unloading (UK). The AES system validates your data and procedures — it may sometimes request additional information. Once correctly submitted, the declaration enters the system. The system may request confirmation of "Goods departed" — i.e. physical exit of the goods. In practice this happens automatically when the border control confirms the departure.

Step 5 — Download IE599 (export confirmation)

After confirmation of the actual exit of goods from EU customs territory (when the goods leave the EU border — typically at a port or airport), the AES system generates the IE599 message. This is a digital document, which you download from PUESC. IE599 is proof that the goods have left the EU and serves as confirmation for the Polish 0% VAT reclaim on exports (if you are VAT-registered). Always archive the IE599 — it is essential for audit purposes. If IE599 never arrives, something has gone wrong — the declaration may have been rejected, the goods may have returned, or there is a procedural error. Read the article on what to do when IE599 is missing.

On the UK side

Step 6 — Haulier/agent creates a GMR in GVMS (if route is covered)

If the goods travel through a port covered by the GVMS (Goods Vehicle Movement Service) — e.g. Dover, Eurotunnel, most UK ports — the haulier or their customs agent must log into GVMS and create a GMR (Goods Movement Reference). The GMR links all customs documents for a single consignment and allows HMRC to track cargo movement. Creating a GMR requires: the haulier's EORI, load details (quantity, weight), customs documents (CDS import declaration or MRN — Movement Reference Number). The GMR must exist before the vehicle arrives at the border. If the route is not covered by GVMS (some land routes to smaller checkpoints, some air routes), a GMR may not be required, but the system will tell you upfront. Always ask the haulier: "Does this route require a GMR?"

Step 7 — Haulier submits an ENS declaration to S&S GB

Before goods arrive in the UK (usually 24 hours in advance), the haulier or their agent must submit an Entry Summary Declaration (ENS) in the S&S GB (Safety and Security) system. The ENS is a safety declaration — HMRC needs to know what is arriving and from where. For Northern Ireland the requirement is ICS2 (Import Control System 2). The ENS contains: the haulier's EORI, goods description, origin, loading/unloading places, and reference documents. Once the ENS is accepted the system issues confirmation — without this, entry to the UK border is not permitted. (If you have previously experienced a hold at the border for a missing ENS, this is exactly why.)

Step 8 — UK customs agent submits an import declaration in CDS

This is the final but essential step: the UK customs agent (or the importer themselves if qualified) submits a full customs declaration in CDS (Customs Declaration Service) within a prescribed time frame (usually up to 1 hour before arrival or within 3 days — depending on the procedure). The declaration includes: the importer's EORI, commodity code, quantity, weight, value, origin, duty rate (UK Global Tariff if no preference), VAT (on the value of goods plus duty), reference to IE599 (if available), statement on origin (if qualifying for TCA). Once accepted, CDS issues an MRN (Movement Reference Number). The MRN is the reference for each declaration — you must archive it for record-keeping.

IE599 and the 0% VAT rate — how it works

The Polish VAT rate on exports is 0% — provided you meet the conditions. One of these is holding IE599, i.e. confirmation that the goods have actually left EU territory. Without IE599 you cannot document the export to the tax authority and risk being liable for the standard VAT rate (usually 23%). This is why almost every exporter waits for IE599 immediately after shipment. The process is: sale for export (0% VAT) → AES declaration + departure confirmation → IE599 → declaration to the tax authority (if you are VAT-registered). If IE599 never appears, something has gone wrong — the declaration may have been rejected, the goods may have returned, or there is a procedural error. IE599 documentation is mandatory for audit purposes.

TCA proof of origin — when 0% duty applies

0% duty under the TCA (UK–EU trade agreement) is available but not automatic. The conditions are: (1) The goods satisfy the rules of origin (sufficient EU content and processing). (2) Proof is attached: either a "statement on origin" (signed exporter's declaration) or "importer's knowledge" (importer's declaration). (3) The proof is provided or available in CDS. Without proof — MFN UK Global Tariff rates apply, sometimes considerably higher (e.g. 15–20% duty). In practice: small businesses sometimes send a simple letter or email with a statement — this is sufficient as long as it is on company letterhead. Larger companies prepare formal declarations. Always ask: "Do my goods qualify for TCA?" — if in doubt, it is better to be conservative and assume duty than to risk rejection at the border.

The most common mistakes made by first-time exporters

Mistake 1 — importer has no EORI

The most common scenario: shortly after shipment it turns out the buyer never registered for EORI. The goods are held at the border and a CDS declaration cannot be submitted. Always: check the importer's EORI BEFORE shipping.

Mistake 2 — using the wrong CN code — entering the packaging code instead of the product

The code must represent the goods, not the box. The error leads to the wrong duty rate and potential penalties. Always verify the code with the importer or against the tariff.

Mistake 3 — no statement on origin when counting on TCA

You ship goods counting on 0% TCA duty but do not provide a "statement on origin". The importer attempts "importer's knowledge" and if HMRC does not accept it — MFN rates apply. Always send the statement with the documents or confirm in writing to the importer that the declaration can be passed to HMRC.

Mistake 4 — incorrect FOB/CIF value on the invoice

UK duty and VAT are calculated on the CIF value (cost of goods + insurance + freight). If the Incoterms are CIF but you enter an FOB value (without freight), the HMRC system may add an estimated transport element — usually higher than the real cost. Always: declare the full CIF value if those are the applicable terms.

Mistake 5 — mixing up export documents with goods documents

Export documents (AES, IE599) are one thing; transport documents (CMR, invoices, packing lists) are another. Both sets must be consistent: same dates, same quantities, same codes. Discrepancies between documents are the primary trigger for detailed examination at the border.

Key takeaways

A first export from Poland to the UK requires 8 steps spread across both sides of the border. On the Polish side: EORI (PL), AES declaration, IE599. On the UK side: importer's EORI (GB), GMR, ENS (S&S GB), CDS. All commercial documents (invoice, packing list, CN codes) must be consistent and retained. TCA proof of origin is conditional — always check whether your goods qualify and provide a statement. IE599 is the key to 0% VAT in Poland. The most common mistakes are: no importer EORI, wrong codes, missing origin declarations, and unclear values. The process is not complicated, but it demands attention to detail and agreement among all parties (you, your buyer, the haulier, customs agents).

FAQ — frequently asked questions

Do I need EORI numbers on both sides of the border?

Yes. The Polish exporter registers in the PUESC system and receives an EORI number with a PL prefix. The UK importer must have their own EORI number with a GB prefix, which they obtain by applying at gov.uk/eori. Both numbers are essential — each side of the border requires its own identification number for customs purposes.

What is IE599 and why does it matter?

IE599 is the message confirming the actual exit of goods from the EU customs territory, generated by the AES system after the Polish export declaration. The exporter downloads IE599 from the PUESC portal — this document is proof entitling them to the 0% VAT rate on exports (under Polish VAT rules) and should accompany the transport documents.

What is a GMR and who creates it?

A GMR (Goods Movement Reference) is a number created in the GVMS system, mandatory when transporting goods through ports covered by that system (e.g. Dover, Eurotunnel). The GMR links all import declarations for a single consignment. It is created by the haulier or their agent based on the customs documents. For routes not covered by GVMS a GMR may not be required, but the system automatically advises whether one is needed.

Is export to the UK eligible for 0% duty under the TCA?

Potentially yes, but conditionally. Preferential 0% duty under the TCA (Trade and Cooperation Agreement) applies ONLY when the goods meet the rules of origin AND a proof is attached: either a "statement on origin" (signed exporter's declaration) or "importer's knowledge". Without proof of origin and compliance with the rules, UK Global Tariff MFN rates apply — sometimes significantly higher. Always verify whether your goods qualify.

Which system is used for import declarations in the UK?

UK import declarations are submitted in the CDS (Customs Declaration Service). CHIEF, the older system, has been retired. CDS handles both full import declarations and simplified entries. Declarations may be submitted by the importer themselves or by their customs agent.

Official sources

• EORI — how to register and manage your number — GOV.UK
• Goods Vehicle Movement Service (GVMS) — registration and GMR — GOV.UK
• Customs Declaration Service (CDS) — import declarations and procedures — GOV.UK
• Making a full import declaration — detailed CDS instructions — GOV.UK
• Making an Entry Summary Declaration (ENS) — Safety and Security — GOV.UK
• Claiming preferential rates of duty between the UK and EU (TCA) — GOV.UK
• PUESC Portal — Polish customs and trade system and EORI PL — Ministry of Finance