Selling to the UK post-Brexit: VAT, customs and fiscal representative
Selling to the UK post-Brexit in 2026: export, UK VAT (GBP 135 threshold), GB EORI number, customs and fiscal representation. The obligations guide.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. Since Brexit, the United Kingdom is a third country: selling to the UK is no longer an intra-community supply but an export (exempt from French VAT, Article 262, I of the tax code), followed by an import into the UK. A GB EORI number is needed for UK customs operations. For business-to-consumer (B2C) sales of goods valued at no more than GBP 135, UK VAT is due at the point of sale: the seller must register for UK VAT and collect it. Above GBP 135, VAT and duties are due on import. The EU-UK Trade and Cooperation Agreement removes customs duties if the rules of origin are met.
2026 context: the UK, a major market outside the EU#
The UK remains an important outlet for French businesses, but it is no longer in the European Union. Flows that were once simple intra-community supplies have become export and import operations, with their own customs formalities and VAT rules. Selling to the UK therefore requires anticipation, as for any international operation described in our article on how to invoice a foreign client.
The UK is a third country#
The first consequence of Brexit: your sales to the UK are exports from France, and imports on arrival in the UK. This involves customs declarations (export on the French side, import on the British side), an EORI number and management of the origin of goods. Northern Ireland benefits from a particular regime for goods (Windsor framework), which deserves dedicated analysis if you deliver there.
VAT: exempt export, then UK VAT#
- From France. The export of goods outside the Union is exempt from French VAT (Article 262, I of the tax code), subject to keeping the proof of exit of the goods from the Union's territory.
- On arrival in the UK. UK VAT applies. The treatment depends on the value and the type of customer.
- B2C sales of goods up to GBP 135. UK VAT is due at the point of sale: the seller (or the marketplace, where applicable) must register for UK VAT and collect it, then declare it.
- Sales above GBP 135 or B2B. VAT and, where applicable, customs duties are due on import, according to the agreed terms (incoterms).
- Making Tax Digital. UK VAT returns are filed digitally.
The EORI number and customs#
- The GB EORI. To carry out customs operations in the UK, a UK EORI number (starting with "GB" followed by digits) is needed. On the French side, an EU EORI is required for the export.
- The declarations. An export declaration is made in France, an import declaration in the UK.
- Customs duties. The EU-UK Trade and Cooperation Agreement removes duties on most goods provided the rules of origin are met (and can be proven). Without preferential origin, duties may apply, as for other imports subject to customs duties.
Fiscal representation in the UK#
To register for UK VAT without being established there, a company may, in some cases, have to go through a tax agent in the UK. The logic is close to that which applies in France for foreign companies, which we detail in our article on the fiscal representative or agent.
The regime by flow#
| Flow | VAT | Key formality |
|---|---|---|
| Export of goods FR -> UK | Exempt in France (Art. 262, I) | Proof of exit + export declaration |
| B2C sale of goods <= GBP 135 | UK VAT at the point of sale | UK VAT registration |
| Sale > GBP 135 or B2B | VAT / duties on import | Import declaration (GB EORI) |
| Services to a UK business | Reverse charge by the customer | "Reverse charge" mention |
The formalities to anticipate#
| Element | To do |
|---|---|
| EORI | Obtain a GB EORI (and an EU EORI for the export) |
| UK VAT | Assess the registration obligation (B2C <= GBP 135, UK stock) |
| Origin | Document the preferential origin to avoid duties |
| Invoice | Export mentions and keeping of proof |
| Declaration | Digital UK VAT (Making Tax Digital) |
Special cases#
Selling via a marketplace. For B2C sales of goods <= GBP 135 made via an online marketplace, the platform may be liable for collecting UK VAT, as we discuss for sales on a marketplace.
Stock in the UK. Holding stock in the UK (warehouse, logistics) in principle triggers a UK VAT registration obligation, regardless of the GBP 135 threshold.
Services. A service to a British business customer follows the reverse-charge logic, distinct from the sale of goods, as for VAT in e-commerce.
Points of vigilance in 2026#
- The UK is no longer the EU. Every sale is an export/import: anticipate customs and formalities.
- The GBP 135 threshold is central. Below it, UK VAT at the point of sale with UK VAT registration; above it, on import.
- Origin conditions the duties. No duties if the preferential origin is met and proven; otherwise, duties apply.
- Keep the export proof. The French VAT exemption requires justifying the exit of the goods from the Union.
- UK stock changes everything. Storing in the UK often triggers a VAT registration obligation.
Our accounting firm's analysis#
Recently, an e-commerce SME regularly shipping to the UK consulted us after parcels were returned stuck in customs and customer complaints about unexpected fees. The analysis revealed two gaps: the absence of a GB EORI number and the absence of UK VAT registration for its B2C sales under GBP 135. We structured the compliance: obtaining the GB EORI, registering for UK VAT, documenting the preferential origin to avoid duties, and clarifying the incoterms so the customer would not face a bad surprise.
Our conviction, as accountants registered with the Ordre, is that selling to the UK remains entirely accessible, provided you treat the country as what it has become: a third market. The pitfalls are not in technical difficulty, but in being unprepared — a missing EORI, an ignored UK VAT, an undocumented origin. Upstream compliance, alongside tax advice, avoids blockages and customer disputes.
Hayot Expertise advice. Before selling to the UK, treat it as an export market. Obtain a GB EORI, assess your UK VAT registration obligation (B2C sales <= GBP 135, UK stock), document the origin of your products to benefit from the absence of duties, and clarify the incoterms with your customers. Keep the proof of exit to justify the French VAT exemption. A well-prepared setup turns a customs constraint into a simple routine.
Frequently asked questions
Is selling to the UK still an intra-community operation?+
No. Since Brexit, the UK is a third country: your sales to the UK are exports from France, exempt from French VAT (Article 262, I of the tax code), followed by an import into the UK. This involves customs declarations, an EORI number and management of the origin of goods, where an intra-community supply did not require it.
What is the GBP 135 threshold?+
For consumer sales of goods valued at no more than GBP 135, UK VAT is due at the point of sale: the seller (or the marketplace) must register for UK VAT and collect it. Above GBP 135, VAT and, where applicable, customs duties are due on import. This threshold is central to determining your obligations on B2C sales.
Do I need an EORI number to sell to the UK?+
Yes. A UK EORI number (starting with "GB") is needed to carry out customs operations in the UK. On the French side, an EU EORI number is required for the export. The EORI must appear on customs declarations and import-export documents. Its absence is one of the most frequent causes of goods being stuck in customs.
Are there customs duties between France and the UK?+
The Trade and Cooperation Agreement between the European Union and the UK removes customs duties on most goods, provided the rules of origin are met and can be proven. If preferential origin is not demonstrated, duties may apply. Documenting the origin of your products is therefore essential to avoid taxation on import.
Must I register for UK VAT?+
It depends on your activity. B2C sales of goods <= GBP 135 require UK VAT registration to collect the tax at the point of sale. Holding stock in the UK also, in principle, triggers a registration obligation, regardless of the threshold. Case by case, using a tax agent in the UK may be necessary to manage registration and returns.
How do I avoid bad surprises for my UK customers?+
Clarify the incoterms: they determine who bears the VAT and duties on import. A "delivered duty paid" sale spares the customer from discovering fees on delivery, but shifts the charge to the seller. Anticipate UK VAT registration for sales <= GBP 135, document the origin and keep the export proof: it is the key to a smooth customer experience.
Key takeaways#
- Since Brexit, the UK is a third country: selling to the UK = export (exempt from French VAT, Art. 262, I) + import.
- A GB EORI number is needed for British customs operations.
- B2C sales of goods <= GBP 135: UK VAT at the point of sale (UK VAT registration); above it, on import.
- The EU-UK agreement removes duties if the rules of origin are met and proven.
- Storing in the UK in principle triggers a VAT registration obligation, regardless of the threshold.
- Keep the export proof and clarify the incoterms to avoid customer disputes.
Official sources#
Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
This topic is part of our service Tax accountant in Paris | CIT, VAT & tax audits
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