E-commerce returns UK–Poland – how to handle customs clearance without the chaos

Handling returns is one of the most complex logistics operations for e-commerce businesses trading cross-border between Poland and the United Kingdom. Since Brexit, every item returning from the UK to Poland or from Poland to the UK formally crosses a customs border — meaning a customs declaration is required, duty and VAT may be charged, and without the right paperwork, taxes on the same goods can be levied twice. The good news is that legal procedures exist — Returned Goods Relief (RGR) in the UK and Returned Products (Przywóz Powrotny) in the EU/Poland — that allow double taxation to be avoided. There is, however, one condition: you must have the correct documents from the original shipment and know how to use these procedures. This guide explains step by step how to handle returns correctly from a customs perspective — both for shops selling into the UK and for those importing goods from the UK to Poland.

Why e-commerce returns are complex from a customs perspective after Brexit

Before Brexit, goods could move freely between Poland and the United Kingdom without any customs formalities. Today, every movement of goods on the UK–PL route is either an export or an import with full customs requirements. In the context of returns, this means:

• A Polish shop selling to the UK → goods exported from Poland to the UK → return = import into Poland from the UK (requires an import customs declaration)
• A UK shop selling to Poland → goods exported from the UK to Poland → return = import into the UK from Poland (requires an import customs declaration in the UK)

In both cases, without the correct customs procedure, double duty and VAT are a risk — i.e. taxes paid both on the original shipment and again on the return.

Returned Goods Relief (RGR) — the primary relief for returns in the UK

Returned Goods Relief (RGR) is a UK customs procedure that allows goods to be re-imported into the UK without paying customs duty and import VAT, provided the goods were previously legally exported from the UK.

RGR UK conditions: 1. The goods must have been exported from the UK (not from the EU customs territory) 2. The return must take place within 3 years of export 3. The goods must not have been processed or modified in the meantime (repairs are permitted) 4. The importer must be the same entity as the original exporter, or must hold the exporter's written consent

Documents required for RGR: - Original UK export document — EAD (Export Accompanying Document) or its MRN number - Invoice for the original sales transaction - Description of the reason for return - Proof of identity of the goods (serial number, description, photographs)

Source: gov.uk — Returned Goods Relief: completing form C1314

Returned Products (Przywóz Powrotny) — the relief on the Polish side

When goods return from the UK to Poland, the Polish side may apply the Returned Products procedure (RP) in accordance with Articles 203–207 of the Union Customs Code.

Conditions for Returned Products in Poland/EU: 1. The goods must be Union goods (previously exported from the EU) 2. Return within 3 years of export 3. The condition of the goods must be unchanged (exception: normal use, necessary repairs) 4. The identity of the goods must be proven

Documents required on the Polish side: - Copy of the original EX export declaration (MRN number) - IE599 — electronic confirmation of export from the AES (Automated Export System) - Commercial invoice or credit note for the return - Correspondence with the buyer confirming the reason for the return

Note: If you do not keep the export MRN number, proving entitlement to Returned Products relief will be very difficult. Always archive the IE599 for every shipment to the UK.

Step-by-step returns procedure — Polish shop selling to the UK

The following process applies to a Polish e-commerce seller who has sold goods to a customer in the UK and received a return:

Step	Action	Responsible party
1	UK customer initiates return; shop issues a Return Authorisation	Polish shop
2	UK customer prepares return parcel marked "Returned Goods"	Customer / shop
3	Export from UK — export declaration on the UK side (customer or carrier)	UK customer / freight forwarder
4	Import into Poland — import declaration using the Returned Products procedure	Polish shop / customs agent
5	Shop provides: export MRN, IE599, original invoice, description of return	Polish shop
6	Customs office releases the goods — no duty or VAT if the procedure is correct	Polish customs office
7	Shop issues invoice correction / credit note and refunds the customer	Polish shop

Bulk returns — how to handle batch processing

E-commerce shops with high return volumes (e.g. fashion, with return rates of up to 40%) need a simplified procedure rather than filing a separate customs declaration for each parcel.

Options for bulk returns: - Batch consolidation — collecting returns over 1–2 weeks and importing them as a single consignment with one customs declaration (reduces clearance costs) - Customs Warehouse — storing returns in a customs warehouse before deciding whether to re-export or import - Simplified Customs Declaration — for authorised operators (AEOC or Entry in Declarant's Records), simplified entries without full details at each shipment are possible

Requirements for batch processing: - Each returned item must have an identifier linking it to the original export (order number, serial number) - The total value of the batch must be documented

Who is the importer on the return — the seller or the carrier?

This is a common question in e-commerce practice. The answer is clear: the importer of the return is the seller (the shop), not the carrier or the sales platform.

The carrier (DHL, UPS, DPD, GLS, InPost) acts as a customs agent in the clearance process — filing the declaration on behalf of the seller, but all customs liability rests with the shop as importer of record.

Exception: if the seller uses DAP (Delivered at Place) or DDP (Delivered Duty Paid) as the Incoterms — for returns, responsibility for customs clearance may be negotiated with the carrier or platform, but this requires an explicit written agreement.

VAT on e-commerce returns — how to reclaim it

On return of goods to Poland: - If import VAT was paid on the original import from the UK → when using Returned Products procedure, VAT is not charged again - The shop issues an invoice correction (credit note) → reduces the VAT base on the sale - The customer refund should be documented and linked to the invoice correction

On return of goods to the UK: - If the buyer paid UK VAT on import → a VAT refund is possible through HMRC (VAT reclaim procedure or via the VAT return) - A seller registered for UK VAT can deduct import VAT on the UK VAT return (Box 4)

Common mistakes in e-commerce returns customs clearance

Mistake 1: Missing original EAD / IE599 The most common and most costly mistake. Without an export document, the customs office will not accept the Returned Products procedure — the goods must be cleared as a standard import with full duty and VAT.

Mistake 2: Incorrect description on the return parcel A parcel labelled "Gift" or without a description goes through the standard import procedure. The description must state: "Returned Goods — Original Export [MRN number]".

Mistake 3: Return by a different entity than the original importer UK RGR requires the importer on the return to be the same entity as the exporter. If your UK customer sends the goods through a courier company registered differently, problems may arise.

Mistake 4: Exceeding the 3-year time limit Goods returning more than 3 years after export do not qualify for RGR or the Returned Products procedure.

Mistake 5: Goods repaired or processed without documentation Repair is permitted, but must be documented (service report, repair invoice). Without documentation, the customs office may treat the goods as a new import.