E-commerce returns from UK — avoid paying duty and VAT twice [2026]

Why an e-commerce return from UK is a second import — and why you pay twice if you do nothing

Since Brexit, every parcel crossing the UK–EU border is cleared in both directions. When a customer in Manchester sends back a jacket bought on Etsy, or a consumer refuses a parcel from Amazon UK, the goods travel back to Poland. From the Polish customs office's point of view — in Gdynia or Poznań — this is a new import from a third country, with full duty and 23% VAT.

The logic is brutal: it does not matter that the exact same item left your warehouse three weeks ago. If the import declaration in Poland does not invoke a specific relief procedure, the customs system charges the duties again from scratch. We see this routinely with clients — a company ships jackets worth £150, one customer returns one item, and at re-import it turns out 12% duty plus 23% VAT are due on their own goods. Around 37% of value, with no business reason, simply because nobody flagged a procedure.

Fortunately the UK and the EU anticipated this. There are four routes that let you either recover the second duty/VAT bill or avoid paying it in the first place. Below is a decision tree to help you pick the right one for a given scenario.

Four routes for an e-commerce return from UK — decision tree

Before you write anything on a declaration, answer three questions: (1) are the goods physically coming back? (2) where did the overpayment occur — in the UK or in Poland? (3) was there a declaration error, or a lawful clearance without relief? Three answers point to one of the four routes.

For most Polish e-commerce sellers, route #1 (RGR) is the default and the most cost-effective. The other three cover edge cases — but they are not rare; at a scale of 500+ returns a month you will run into all of them.

Route 1: Returned Goods Relief (RGR) — full relief at re-import

RGR is the key relief for e-commerce sellers. On the EU side the legal basis is art. 203 of the Union Customs Code (UCC); on the UK side — GOV.UK: Pay less import duty and VAT when re-importing goods. For Poland, art. 81 of the Polish VAT Act is the additional VAT basis.

We cover the full procedure in a separate spoke — Return of goods from UK (Returned Goods Relief). Here we summarise the conditions and traps that matter for e-commerce.

RGR conditions in 2026

• 3-year window from the export date to the re-import date. For e-commerce we count from the IE599 date, not the sale date.
• Unaltered state — goods may be tried on, used, even damaged. They must not have been repaired, upgraded or processed. Repair = Outward Processing, not RGR.
• Identity of exporter and importer — usually the same entity. In B2C sales the UK customer is not the exporter in a customs sense — the exporter was the Polish seller, so RGR still works.
• Original IE599 — the MRN of the original export goes onto the re-import declaration. Archiving IE599 is essential; without it the customs officer refuses the relief.

Procedure code

On the SAD/CDS declaration we use procedure 61 00 (reintroduction of goods after temporary export) or 61 10 (after permanent export). The exact code is chosen by the declarant after reviewing the original IE599. Our team uses 61 10 in 95% of e-commerce cases, because the original export was a sale, not a temporary movement.

VAT trap: who carried out the export

If entity A made the original sale to the UK, and entity B re-imports the return (for example a different company in the same group), the duty part of RGR may still go through — but the VAT relief will not. Polish rules require identity of the taxpayer. You will pay 23% VAT and recover it later through the VAT return. At 200 returns a month that is a real cash flow block.

Route 2: C285 — post-clearance refund in the UK

C285 is HMRC's tool for recovering duty and VAT you have already paid but should not have. Basis: GOV.UK: Apply for a repayment of import duty and VAT (C285). Full detail in the spoke — Customs value refund from UK — C285 procedure.

Typical C285 scenarios in e-commerce

• Inflated value — £200 declared instead of £150, the courier collected excess duty/VAT.
• Unrecognised TCA preference — the goods qualified for a zero rate under the EU–UK Trade and Cooperation Agreement, but the agent did not cite the proof of origin. The overpaid duty is 6–12%.
• Wrong HS tariff — goods classified at a higher duty rate than they should have been.
• Return before UK clearance was completed — if the goods went back before HMRC formally released the consignment, the correct route is BOR286 (see below).

Deadlines

HMRC gives 3 years from the declaration date to file C285 where the payer made the error, and 12 months where HMRC made the error. A decision comes back in 4–12 weeks; on claims above £500 HMRC often asks for additional documents, which extends the process.

Route 3: BOR286 — overpayment refund on UK courier parcels

BOR286 is a specific procedure for small courier and postal parcels handled by Royal Mail, Parcelforce and certain couriers. Basis: GOV.UK: BOR286 form.

When to use it: your UK customer received a parcel from Poland by post, the courier collected duty/VAT on delivery (for example £40), and the customer refused or returned the parcel. The UK recipient can submit BOR286 to reclaim that £40. From the Polish seller's perspective this is a route you point a customer towards when the overpayment hit their pocket, not yours.

BOR286 does not replace RGR — RGR covers re-import into Poland, BOR286 covers recovery of UK-side charges. In a typical e-commerce return the two run in parallel: the UK customer files BOR286 for the UK duty/VAT, and you re-import the goods into Poland under RGR.

Route 4: Re-import via a UK IOR agent — for bulk B2C returns

When a UK customer has no EORI and no grasp of customs (i.e. 99% of B2C cases), the export leg of the return must formally be filed by someone with a UK EORI. Enter the IOR agent (Importer of Record) acting as an indirect representative of the Polish seller.

The operating model: returns from UK customers flow into a central logistics hub (usually around Manchester or Dover), the IOR agent files a consolidated export to Poland, and on the Polish side we re-import the batch under RGR. Instead of 200 individual clearances a month you get 8 consolidated ones (one a week per service).

The economics: from roughly 100 returns a month this model drops to around £3–6 per unit, versus £12–25 for an individual courier clearance. The added benefit — full relief from duty and import VAT through RGR applies across the whole batch.

Realistic timeline — what to expect

A first return with no procedure prepared lands at the customs office as a plain import. Even if the clearance was correct, recovering the overpayment through C285 will take 4–12 weeks on the UK side, plus an equivalent 2–3 months of VAT correction in Poland where applicable.

A second return, and every one after it — with RGR set up and a customs agent on board — goes through on the day the vehicle enters Poland with no duty and no VAT. Instead of months of chasing HMRC and filing VAT corrections, you have zero payment up front.

This is why a one-off investment in setting up the procedure pays back after 2–3 returns. The EC team runs this for Amazon FBA UK, Etsy and independent Shopify sellers — a full write-up is in the spoke Amazon FBA UK — returns to Poland.

Most common mistakes — and how to avoid them

Mistake 1: no IE599 from the original export. Without that document RGR will not fly. The fix — archive IE599 from the first sale onwards, ideally linked to the return tracking number. More in the spoke No IE599 — UK export and 0% VAT.

Mistake 2: goods repaired in the UK declared as RGR. If the UK customer damaged the item, had it repaired and you file it as RGR, that is a formal breach. The right procedure is Outward Processing, not RGR.

Mistake 3: return sent back to a different group company than the one that exported. The duty part of RGR may go through, but the VAT relief will not. If you operate under several tax IDs, set a rule that returns always come back to the exporter entity.

Mistake 4: choosing C285 instead of RGR. Some customs agents default to clearing the return as a regular import and then filing C285 afterwards. It works, but it ties up cash flow for 2–3 months. If RGR conditions are met, use RGR from the start.

Mistake 5: ignoring BOR286 as a seller tool. Many sellers do not know they can point a UK customer towards BOR286 when the UK customer overpaid duty/VAT. It improves their buying experience and cuts down chargebacks.

Checklist for an e-commerce seller — before the first return ships

1. Archive IE599 from every export (SharePoint, Google Drive, document store — anywhere, as long as it is quickly searchable by tracking number).
2. Agree the returns process with your Polish customs agent — RGR as default, C285 only when an overpayment arose after clearance.
3. If you are over 50 returns a month — consider a UK IOR agent and a hub-and-spoke model.
4. Enforce a policy: only the entity that shipped the goods can re-import them. No exceptions for other group companies.
5. Add a clause to your shop terms: physical returns are welcome within 3 years of purchase (not the standard 14 days — after 14 days the goods still qualify for RGR).
6. Watch changes to the TCA and to the £135 e-commerce UK threshold — they affect how sub-threshold returns are classified.

When it pays to hand the process over to a customs agent

The EasyClearance Team runs both one-off returns (for small Shopify shops) and full hub-and-spoke integrations for Amazon FBA sellers with 300+ returns a month. Ongoing RGR handling is priced per declaration — exact rates for imports, T1 and special procedures are in our pricing page.

If you have your first UK return on the way and are not sure which of the four routes to pick — call or WhatsApp +44 7404 091 503. We respond 24/7 and usually set up the right procedure within the hour, so you do not pay duty and VAT on your own goods.

FAQ — common questions about e-commerce returns from UK

Does an e-commerce return from UK to Poland require customs clearance?

Yes. Any goods returning from the UK to the EU after Brexit are treated as an import — whether it is a B2C return, a faulty item or an undelivered parcel. Without the right procedure you will pay duty and VAT on your own goods.

When should I use Returned Goods Relief (RGR), and when C285?

Use RGR when the goods come back in an unaltered state within 3 years of export — it gives full relief from duty and VAT. C285 is a claim for repayment of overpaid duty/VAT after clearance (e.g. wrong customs value, wrong tariff code, incorrect origin). They are two different routes, not alternatives — you try RGR first, C285 is plan B.

Does BOR286 work for e-commerce returns?

Yes, but only for courier and postal parcels within the UK (Royal Mail, Parcelforce). BOR286 is used to reclaim duty and VAT where the courier overcharged on the original UK import. For a typical Polish e-commerce seller, RGR or re-import via an IOR agent is the right route.

How long does it take to reclaim duty and VAT after a return from UK?

With RGR applied at re-import, you don't pay at all. A C285 claim at HMRC usually takes 4–12 weeks. BOR286 is typically 4–6 weeks. In Poland, a VAT refund on an import overpayment can take up to 3 months from filing the correction.

Do I need the IE599 from the original export?

Yes, if you are using RGR. IE599 (the export-confirmation message) proves the goods legally left the EU — the MRN number goes onto the re-import declaration. Without IE599 the customs officer may refuse RGR and you will pay duty and VAT.

What if a UK customer returned a parcel with an incorrect declared value?

If HMRC charged duty and VAT on an inflated value at the original UK entry (overpayment), the correct route is C285 — a post-clearance repayment claim. It requires proof of the real customs value (invoice, contract) and the entry reference (EPU/entry number).

Is 23% VAT charged again when goods return to Poland from UK?

It depends on the procedure. RGR gives relief from import VAT if the importer is the same entity that carried out the export and the conditions of art. 81 of the Polish VAT Act are met. Without RGR — yes, 23% import VAT plus duty, which you then have to recover through a correction or PVA (UK only).

Who can be the declarant of the return — the Polish seller or a UK IOR agent?

On the UK side (export to the EU) the declaration is filed by the UK exporter — this is either the UK customer or an IOR agent acting on their behalf. On the Polish side (import) the declarant is the Polish seller with a Polish EORI. For bulk B2C returns a customs agent is used on both sides of the channel — a model the EasyClearance Team runs for sellers with 100+ returns a month.

Related articles in the knowledge base

• Return of goods from UK (Returned Goods Relief) — procedure detail
• Customs value refund from UK — C285 step by step
• Amazon FBA UK — returns to Poland, customs procedure
• eBay UK — returning goods from Poland in 2026
• Returning goods to UK (Amazon) — consumer guide 2026
• £135 e-commerce UK threshold — VAT and duty
• No IE599 — UK export and 0% VAT
• Postponed VAT Accounting (PVA) — UK

Official sources

• GOV.UK — Pay less import duty and VAT when re-importing goods (RGR)
• GOV.UK — Apply for a repayment of import duty and VAT (C285)
• GOV.UK — Refund of overpaid charges on rejected imports (BOR286)
• European Commission — Customs procedures for import and export
• EUR-Lex — Union Customs Code (UCC), art. 203 on returned goods