Customs Clearance in the UK for Importers from Poland

Since Brexit, moving goods from Poland (an EU member) to the UK is no longer an intra-community transfer; it is a full international import. As a new importer, you are now liable for customs declarations, potential tariffs, and VAT handling.

Here is a step-by-step guide to Customs Clearance for new UK importers bringing goods from Poland.

Phase 1: Immediate Prerequisites (Do this before you buy)

1. Get a GB EORI Number
   You cannot import goods without an Economic Operators Registration and Identification (EORI) number starting with “GB”.

• Action: Apply via GOV.UK (it usually takes 5-10 minutes if you are VAT registered).
• Note: Your Polish supplier must have an EU EORI number to export the goods from Poland.

2. Classify Your Goods (Commodity Codes)
   Every item has a 10-digit Commodity Code (HS Code). This code dictates the duty rate and any restrictions.

• Action: Use the UK Integrated Online Tariff tool.
• Why: If you use the wrong code, you may pay too much tax or face fines for underpayment.

3. Agree on Incoterms
   Incoterms (International Commercial Terms) define who is responsible for shipping, insurance, and customs.

• Common for Beginners: DAP (Delivered at Place). The Polish seller pays for transport to your UK door, but you (the UK buyer) are responsible for UK Import Customs Clearance, Duty, and VAT.
• Avoid: DDP (Delivered Duty Paid) unless you trust the seller entirely, as they handle UK taxes (which is hard for a Polish company to do). EXW (Ex Works) puts all the burden and risk on you to pick up the goods from the Polish factory.

Phase 2: Duties and VAT

1. Claiming “Zero Tariffs” (Rules of Origin)
   Under the UK-EU Trade and Cooperation Agreement (TCA), goods are duty-freeonly if they originate in the EU.

• The Trap: If your Polish supplier is simply re-selling goods made in China, full UK tariffs apply.
• The Requirement: The Commercial Invoice from the Polish supplier must contain a specific “Statement on Origin” declaring the goods are of EU preferential origin.

2. Import VAT (20%)

• Standard Method: Pay VAT at the border before goods are released (bad for cash flow).
• Recommended Method: Postponed VAT Accounting (PVA). This allows you to “account” for import VAT on your next VAT return rather than paying cash at the border. You simply tell your customs broker to select this option on the declaration.

Phase 3: The Documentation

You must ensure your Polish supplier provides the following documents before the truck leaves Poland:

1. Commercial Invoice: Must include EORI numbers (both parties), Commodity Codes, Value, Weight, Incoterms, and the Statement of Origin.
2. Packing List: Details exactly how the goods are packed (pallets, boxes, weight).
3. Transport Document: CMR (Road Consignment Note).
4. Certificates (If applicable): If importing food, animal products, or wood, you may need health certificates or phytosanitary certificates.

Phase 4: The Clearance Process (The “How-To”)

Unless you are a large corporation with dedicated software, do not attempt to do the customs declaration yourself. The UK now uses a system called CDS (Customs Declaration Service), which is complex.

The Workflow:

1. Hire a Broker/Forwarder: Find a UK Customs Broker or Freight Forwarder.
2. Pre-Lodgement: You send the invoice and packing list to your broker before the truck arrives at the Channel Tunnel or Ferry Port (Calais/Dunkirk/Hook of Holland).
3. The Declaration: The broker submits the import entry into CDS.
4. MRN & GMR: The broker gives the entry number (MRN) to the haulier (truck driver). The driver enters this into the GVMS (Goods Vehicle Movement Service) system to generate a GMR (Goods Movement Reference).
5. Crossing the Border: The driver scans the GMR at the ferry/tunnel.
   • Green Light: Goods are cleared automatically upon arrival in the UK.
   • Orange/Red Light: Goods are held for documentary or physical inspection at an Inland Border Facility (IBF).

Phase 5: Specific Rules for Food & Animal Products (BTOM)

If you are importing food, meat, dairy, or plants from Poland, the rules changed significantly in 2024 under the Border Target Operating Model (BTOM).

1. IPAFFS: You must pre-notify UK authorities of the arrival of these goods using the IPAFFS system 24 hours before arrival.
2. Export Health Certificate (EHC): The Polish exporter must get a vet/inspector to sign an EHC in Poland.
3. Entry Point: These goods must enter through a port designated to handle those specific goods.

Summary Checklist for New Importers

1.  GB EORI Number secured.
2.  Commodity Codes identified for all products.
3.  Customs Broker appointed (and “Standing Authority” given to them to act on your behalf).
4.  Incoterms agreed with Polish supplier (Recommend DAP).
5.  Origin Statement confirmed on the supplier’s invoice to claim 0% duty.
6.  Postponed VAT Accounting set up with your accountant.

Common Pitfalls to Avoid

• Undervaluation: Do not lower the value on the invoice to save tax. Customs checks values against market rates.
• Missing “Made in EU” Statement: Without the specific text on the invoice, Customs will charge you full international tariffs (Global Tariff) even if the goods are Polish.
• Wood Packaging: Ensure pallets used by the Polish supplier are ISPM15 compliant (heat treated and stamped). If not, the shipment can be rejected at the border.

Disclaimer: This article provides general information and does not constitute legal or financial advice. Customs regulations are subject to change. Always consult a professional customs broker or tax advisor for your specific situation.