Since 1 January 2021 every carton that leaves Great Britain for the EU is treated as a third-country export. Add 2024–25 rule-changes—ICS2 Phase 3 advance data, the UK’s Border Target Operating Model (BTOM), and new low-value VAT schemes—and confusion multiplies. This guide strips away the jargon so UK sellers can ship to France, Germany or Spain with zero nasty border surprises in 2025.
1. The Post-Brexit VAT Landscape at a Glance
| Scenario | Who Collects VAT? | Scheme / Threshold | Key Form |
|---|---|---|---|
| B2C orders ≤ €150 | Seller (at checkout) | IOSS | IOSS quarterly return |
| B2C orders > €150 | Carrier / customs broker | None—normal import VAT | SAD / CN23 |
| B2B any value | EU buyer (reverse charge) | VAT number required | Commercial invoice shows buyer VAT ID |
IOSS refresher: distance-sales VAT up to €150 is paid in one pan-EU return, eliminating surprise fees for customers. The original €22 VAT waiver is gone. VAT e-Commerce – One Stop Shop
2. Customs Data & Safety Declarations
2.1 ICS2 Phase 3 (March 1 2025)
All goods entering the EU must have an Entry Summary Declaration (ENS) filed via ICS2 before loading onto the plane, truck or ferry. Forwarders now demand extra data fields (HS6 code, goods description, shipper EORI) at booking. Miss it and your consignment is refused at EU borders. Taxation and Customs UnionShipGlobal.in
2.2 BTOM & UK Export Controls
From 31 January 2025 the UK requires an Exit Summary Declaration on EU-bound exports, aligning with EU rules. SPS goods face additional Health Certificates under BTOM’s second phase. GOV.UKHouse of Lords Library
3. Core Numbers Every Exporter Needs
| Code / Number | Purpose | Where to Get It |
|---|---|---|
| GB EORI | Identifies exporter to UK customs | HMRC online (same day) |
| EU EORI | Needed if you act as importer of record (DDP) | Any first-entry EU customs office |
| IOSS ID | Low-value B2C VAT remittance | Fiscal rep or marketplace |
| Commodity Code (HS8 / TARIC) | Determines duty rate & restrictions | UK Tariff Lookup + EU TARIC |
4. DDP vs DDU—Incoterms After Brexit
| Item | DDP (Delivered Duty Paid) | DDU / DAP (Duty Unpaid) |
|---|---|---|
| Importer of Record | You (seller) | Customer |
| VAT / Duty Paid By | Seller (up-front) | Buyer on delivery |
| Customer Experience | Amazon-like, no surprises | Risk of refusals |
| Admin Load | High (EU EORI, fiscal rep) | Low |
| When to Use | High AOV, brand-sensitive goods | Low-margin, price-sensitive offers |
Tip: Offer both—show DDP checkout as “Hassle-Free Shipping” and let customers choose. With this guide, you will ensure trouble-free shipping to the EU. You can also take a look at our 25-Item Warehouse Receiving Checklist to learn what needs to be done before your orders reach the warehouse.
5. Paperwork Checklist for Every EU Shipment
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Commercial Invoice—3 copies, shows HS code, origin, incoterm, IOSS or EU VAT ID.
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Packing List—weight & dimensions per carton.
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ENS data set (ICS2) via carrier portal.
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Export Accompanying Document (EAD)—generated after CHIEF → CDS export declaration.
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Proof of Origin—UK–EU Trade and Cooperation Agreement grants 0 % duty when accompanied by origin statement (for qualifying goods).
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Health / Phytosanitary Certificate (if applicable under BTOM).
6. Typical Duty & VAT Cost Calculator (2025)
Zero duty is only guaranteed if your product meets Rule of Origin tests—keep supplier declarations for 4 years. AB Avrupa Ticareti
7. Six Compliance Pitfalls to Avoid in 2025
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Using 8-digit HS codes—ICS2 rejects anything shorter than 6 digits or vague descriptions (“gift”).
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Old CN22 labels—no longer accepted for commercial parcels.
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Missing “Statement of Origin” on invoices → duty re-imposed retroactively.
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Mismatched EORI & IOSS IDs—ENS auto-validation fails.
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Under-declared freight cost—raises VAT assessment + penalties.
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Forgetting ICS2 for transhipments—even if final destination isn’t the EU (e.g., CH to IT transit).
FAQ
Q1. Do I still need Intrastat after Brexit?
No for GB exports; yes if you move goods between Northern Ireland and the EU above the reduced thresholds. Taxually
Q2. Can I ship low-value items without IOSS?
Yes, but the courier will collect VAT + a handling fee from the buyer, hurting conversion rates.
Q3. Does the €150 ceiling disappear in 2028?
The EU proposes scrapping the customs exemption and IOSS cap, but it is not yet law. Monitor 2026–27 updates. vatcalc.com
Q4. Are safety-security declarations needed when exporting to the EU?
From 31 Jan 2025 the UK requires an exit ENS; the EU already requires an ENS via ICS2 on entry.
Conclusion & CTA
Navigating post-Brexit VAT and customs is less about red tape and more about data accuracy. Master IOSS for sub-€150 orders, file ICS2 ENS ahead of loading, and choose DDP when customer experience matters most.
Need a turnkey EU shipping solution? UK Pre Fulfilment’s customs team files ICS2 automatically, provides fiscal representation for IOSS, and delivers DDP across 27-member states. Get a customs audit quote within 24 hours.
