Continuing to import to the UK in the event of a no deal Brexit 

Urgent action required


HMRC have recently released updated guidance concerning steps to be taken in the event of a no deal Brexit (29 March 2019) to ensure a relatively frictionless transition. This document sets out the actions that it’s important you take now and the changes you need to be prepared for.

At present, if you are importing products from another EU country, these will be declared as arrivals on your VAT return but unless the products are exciseable, there are no other formalities to comply with.

Following Brexit, the UK will leave the common EU VAT and customs territory meaning that you will need to account for such supplies in a different manner. Henceforth, you will be required to complete customs declarations for all of EU imports.

Importers of product from outside the UK will not need to do anything in support of EU to UK movements if they currently import non-EU goods directly to the UK as they will already have the basic arrangements in place. Some of these companies may benefit from “easements” in customs processes for goods arriving in the UK from the EU but generally probably will not.


So that you are ready, you should:

  • Register for your UK Economic Operator Registration and Identification (EORI) number.
  • Review the tariff classifications of the goods being sent to the UK and consider whether they may be liability to customs duty after Brexit.
  • If you anticipate that customs duty will be payable on goods arriving in the UK, consider whether to apply for duty deferment.
  • If you want to make declarations through a UK customs agent, then you should appoint one as soon as possible (your freight provider may well offer this service).  Alternatively, it may be desirable to do this in-house.
  • For excisable goods such as tobacco and alcohol travelling under duty suspension, the EU’s movement in EMCS will terminate at the EU border after Brexit. You will need access to the UK-only EMCS system to allow these goods to remain in duty suspension in the UK. If you currently use EMCS in the UK, the switch to UK-only EMCS should be more-or-less automatic.

Import VAT and any duties will need to be paid when the goods arrive in the UK, in full at time of import unless you have access to a deferment arrangement (either your own or that of a third party such as the courier). You will recover the import VAT using your monthly C79 document which will be issued by HMRC. You will still need to account for UK sales VAT also.


Next steps


  • You should apply for an EORI number - 4 Eyes Ltd can apply for this on your behalf.
  • Speak to your freight provider or consider appointing a customs agent.
  • Review tariff classifications and possible duty rates.
  • Consider an application for duty deferment if customs duty charges are likely to be payable.

Certain other facilitations may be available depending upon the nature of your business. Please contact 4 Eyes Ltd if you would like us to review the VAT and customs resilience of your business in a post Brexit environment.