Selling car parts online to the UK — duty, VAT and proof of origin

Selling car parts online from Poland to the UK requires three things lined up: correct tariff classification (different CN codes in chapter 87 carry different rates — from 0% to 6.5%), proof of EU preferential origin under the TCA (statement on origin on the invoice for consignments ≤£5,500, REX above that), and the right VAT setup (UK VAT for B2C ≤£135, standard import VAT above). Without these three elements, HMRC will charge full MFN duty, and the UK consumer will get an invoice from the courier covering additional VAT + a handling fee + potential duty — and return the order. Legal basis: UK-EU TCA, UK Global Tariff, Taxation (Cross-border Trade) Act 2018.

This article is a spoke of the E-commerce to the UK cluster. Related foundations: UK customs value (a statement on origin does not release you from correct valuation), Importer of Record UK (who is liable under DDP vs DAP), HS code — how to find it, Amazon FBA to the UK — importer and VAT.

Classification: CN 8708 is not one single rate

The most common mistake Polish sellers of aftermarket parts make: treating chapter 87 as a uniform group with one duty. In reality the UK Global Tariff has dozens of separate lines within CN 8708 (parts and accessories for motor vehicles), with very different MFN rates.

Practical consequence: if your catalogue has 3,000 SKUs, do not classify them all as "CN 8708 99" just because it feels like a "catch-all" accessories category. HMRC audits post-clearance — a mis-classification over 2 years on 50,000 units per year is a typical £40,000-£150,000 back duty + penalty case. See HS code — how to find and verify.

Where to check a specific code

Open the UK Integrated Online Tariff, enter a description (e.g. "brake pads") or a 4-digit CN. The system shows the full hierarchy with MFN and a "preference" column (where, for TCA / EU, 0% appears if the origin rules are met). Also check footnotes — some CN codes carry additional requirements (e.g. DVSA type-approval certificates for homologated car parts).

TCA preferential origin — when 0% duty applies

The TCA (UK-EU Trade and Cooperation Agreement) grants 0% duty on goods originating in the EU — but "originating" is a technical term. Car parts qualify for TCA preferential origin if:

1. They are wholly obtained in the EU — e.g. a silencer forged from Polish steel, brake pads manufactured in a German plant from German materials. Simple, but rare in the aftermarket.
2. They meet the product-specific rule (PSR) — for CN 8708, the PSR is typically: (a) a change of tariff heading (CTH) — i.e. the incoming components have a different 4-digit code from the finished product, or (b) a non-originating content limit (usually up to 45-50% of ex-works value). The exact PSRs are in Annex ORIG-2 of the TCA.

Key test: if you buy Made-in-China parts from a wholesaler in Poland and resell them to the UK, they are not EU-origin goods. Packing, labelling or consolidation = minimal operations and do not count as transformation. Full MFN duty applies.

Practical EC scenario: a Wrocław-based aftermarket parts seller sources brake pads from Germany (TRW, Textar) and resells to the UK. The pads are EU-origin (manufactured in DE from German metal) — the seller obtains a supplier's declaration from TRW confirming EU origin, issues a statement on origin on their own invoice to the UK, HMRC accepts the preference — 0% duty instead of 4.5% MFN. A saving of around £4,500 per £100,000 of turnover.

Statement on origin vs supplier's declaration

Statement on origin wording (to copy onto the invoice)

This wording must appear on the export invoice (ideally in English), on every consignment to the UK for which you claim preference. Without it, HMRC will charge full MFN — even if the goods are genuinely EU-origin.

When to request a supplier's declaration from a supplier

Scenario: you sell repair kits containing brake pads (DE) + discs (PL) + ABS sensors (China). The kit as a whole is not "wholly obtained in the EU" (there are non-originating elements). You must calculate origin via PSR — typically a non-originating content limit (e.g. up to 50% of ex-works value). To prove the origin of the DE pads and PL discs, you need a supplier's declaration from TRW (DE) and the Polish disc manufacturer. Without these documents you cannot issue an SoO for the kit — because in an audit HMRC will ask for the proof.

Keep the supplier's declaration on file for 4 years. HMRC may request it in an audit — if you don't have it, they re-classify the declaration as non-preferential and charge MFN retrospectively.

VAT for B2C up to £135 — the UK low-value regime

The UK operates its own low-value consignment regime for B2C e-commerce. When you sell a UK consumer a parcel with a goods value ≤£135 (excluding transport and insurance), the rules are:

• UK VAT registration is mandatory for the seller (no threshold under this regime — from the first B2C shipment).
• VAT collection at 20% at checkout — you include VAT in the final price; the consumer pays nothing extra at the border.
• The invoice must disclose the VAT charge and the seller's UK VAT number.
• Duty nil — B2C parcels ≤£135 are duty-free (£135 is the threshold for both the VAT regime and customs duty relief).
• Quarterly UK VAT return — payment to HMRC on the standard cycle.

Above £135 — standard import. If you sell DDP, you are the Importer of Record (you need a GB EORI + UK VAT + full CDS declaration). If DAP — responsibility shifts to the buyer (the courier typically contacts them about the duty and VAT charge at the border). For B2C DAP above £135 is a UX problem — the consumer receives an unexpected invoice from the courier and often refuses the parcel.

Marketplace sales (Amazon UK, eBay UK)

For sales via an online marketplace (OMP), the platform takes over VAT collection in selected scenarios: (a) all B2C sales ≤£135 from non-UK sellers, (b) B2C sales of any value with stock held in the UK by a non-UK seller. In practice: if you sell on Amazon UK as a PL seller, Amazon collects UK VAT automatically and remits it to HMRC, and your payouts are net of VAT. See Amazon FBA to the UK — importer and VAT for the full setup.

Incoterms — DDP vs DAP for parts online

Incoterms determine which party is the Importer of Record in the UK and who bears the duty + VAT:

• DAP (Delivered at Place) — the buyer handles the import. For B2B: standard, because the buyer holds a GB EORI and reclaims VAT. For B2C: a problem — the consumer receives an invoice from the courier.
• DDP (Delivered Duty Paid) — you, the seller, are responsible. You need a GB EORI + UK VAT + a customs agent (EasyClearance). For B2C above £135: the only acceptable UX — the consumer pays one price, no surprises.
• EXW / FCA — do not use for e-commerce; they shift export responsibility to the buyer, which breaks the chain of origin documentation.

For a PL→UK e-commerce seller, the typical EasyClearance setup: B2B DAP with an invoice carrying a statement on origin; B2C ≤£135 UK VAT-registered + collection at checkout + DAP on paper (but duty-free, because below the threshold); B2C >£135 DDP with full CDS clearance.

Operational checklist — what you need before the first shipment

1. PL EORI — exporter number (from PUESC).
2. GB EORI — if DDP or stock held in the UK.
3. UK VAT registration — if B2C ≤£135, DDP, or stock held in the UK.
4. REX — if any single consignment is worth >£5,500 and you claim TCA preference.
5. CN classification — every SKU with a 10-digit code in the ERP/Excel, verified in the UK tariff.
6. Supplier's declarations — from every EU supplier delivering non-fully-obtained components. 4-year retention.
7. Invoice template in EN with the statement on origin clause, exporter/importer details, CN code, FOB value, country of origin.
8. Packing list and CMR/AWB — for every shipment, even courier.
9. UK customs agent — EasyClearance or another broker clearing CDS on your behalf (for DDP).
10. Returns procedure — Returned Goods Relief (RGR) for returns within 3 years of export without paying duty.

Frequently asked questions — car parts PL→UK

Are tyres also CN 8708?

No. New tyres fall under CN 4011, used tyres under CN 4012. The UK MFN rate is around 4% for pneumatic tyres, 0% under the TCA for EU origin. If tyres are Made in China or non-EU, MFN duty applies + potential additional anti-dumping measures.

What about used or refurbished parts?

Used (second-hand) parts are classified under the same CN as new, but the customs value is lower (used market price) — more in UK customs value. Refurbished parts are usually treated as new with full value. HMRC may require proof of the refurbishment process and the original manufacturer — keep the process documentation.

Do type-approved parts (DVSA / e-mark) carry additional requirements?

Yes. Selected categories (steering, braking and lighting components) require EU e-mark marking (accepted in the UK) or UK/NI type approval. A missing mark = the goods can be detained by the DVSA, even if customs clearance went through correctly.

Can my wholesaler issue a statement on origin on my behalf?

No. The statement on origin is issued by the exporter — i.e. the entity that ships the goods to the UK. The wholesaler issues a supplier's declaration (to you), but the SoO goes on your invoice. If the wholesaler is the formal exporter (ships directly to the UK), then they issue the SoO, not you.

What about Northern Ireland (NI)?

NI operates under the Windsor Framework — imports into NI from the EU are treated effectively as intra-Union (no duty when the not-at-risk conditions are met). For GB (England, Scotland, Wales) the normal TCA rules apply. If you are shipping to an NI address — check whether the buyer requires a specific marking.

Can I combine different CN codes in one shipment?

Yes — a CDS declaration allows multiple items. Each CN has its own line in the declaration with its own duty and VAT. Condition: the invoice must clearly map SKU → CN → value. Without this, the customs agent has no way of splitting the declaration correctly.

How much does clearance at EasyClearance cost?

Standard import clearance for e-commerce consignments: £55-£85 net per declaration, including statement-on-origin checks and classification. For volumes of 100+ clearances per month, Business/Enterprise rates are available — see EC pricing or WhatsApp +44 7404 091 503.

Selling car parts to the UK? We'll sort your origin, VAT and CDS

The EasyClearance Team runs the e-commerce aftermarket parts setup PL→UK: CN classification, TCA preferential origin audit, SoO invoice template, UK VAT registration and customs agent on CDS. Average client saving in aftermarket: £5,000-£15,000 per year on duty + elimination of B2C abandoned carts.

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What next — related articles

• UK customs value — 6 valuation methods
• Importer of Record UK — who is liable under DDP vs DAP
• HS code — how to find and verify it
• Amazon FBA to the UK — importer and e-commerce VAT

Disclaimer: This article is informational and does not constitute legal, customs or tax advice. Duty rates and origin rules depend on the specific 10-digit CN code, the origin of components and the circumstances of the shipment. Before implementing, verify the UK Integrated Online Tariff and TCA Annex ORIG-2 (product-specific rules). Where uncertain, consult a customs agent.