The exporter or its customs representative is responsible for export clearance from the EU, and the importer (or its representative) for import clearance in the UK. Who actually handles the formalities on the British side depends on the commercial arrangements and delivery terms, such as DAP or DDP.
Contents
When exporting to the UK, the biggest source of chaos very often is not the documents, but a lack of clarity about who is responsible for what. The salesperson assumes one thing, the carrier assumes another, and the customer on the UK side assumes a third. The result is that the question of who is responsible for clearance only comes up once the transport is already ready to go.
The key question
Who formally and operationally handles the clearance, and who supplies the data for that process. Without an answer to this, even a good invoice and a well-prepared shipment do not give you full security.
Two clearances, two sides of the border
Exporting from Poland to the UK means two separate procedures. On the EU side, goods leaving the customs territory of the Union are covered by an export declaration, lodged by the exporter or a customs representative acting on its behalf. On the British side, the goods must be entered for import in CDS, by the importer or its representative, who needs an EORI number with the GB prefix. Export details are in how exporting to the UK works after Brexit.
How delivery terms affect the split of roles
Incoterms divide costs and risk, but do not by themselves decide who the importer is in law. Under DAP, import clearance in the UK is usually arranged and paid for by the buyer. Under DDP the seller takes on the formalities and duty on the UK side, so as the importer it needs an EORI number starting with GB and usually works through a UK customs representative. Which model more often causes problems is covered in DDP or DAP when exporting to the UK, and the document sequence in the guide to the commercial invoice to the UK.
What needs to be settled before shipping
- who is the importer on the UK side and whether it has a GB-prefixed EORI number,
- who lodges the export declaration in the EU – the exporter or a customs agency,
- who supplies the commercial and transport data,
- who keeps track of reference numbers (such as the MRN) and border formalities,
- who pays duty and VAT in the UK,
- who is responsible for quick corrections if something goes wrong.
Summary
Exporting to the UK works best when the roles are settled before the goods move. If you want to sort out responsibility in your trading model, get in touch with us.
If you want to explore this topic further
If, alongside the division of responsibility, you also want to put your documents and the sequence of actions before shipping in order, this expert resource will also help: Poland-UK Export - the Complete Guide.
Related guides
This topic also pairs well with: Commercial invoice to the UK - 8 mistakes, DDP or DAP when exporting to the UK, and Export to the UK.
Frequently asked questions
Is the exporter always responsible for import clearance on the UK side?
No. It depends on the trading model, the arrangements with the counterparty, and who formally acts as the importer and takes on the obligations on the UK side.
Who lodges the export declaration from the EU to the UK?
The exporter or a customs representative acting on its behalf, such as a customs agency. The export declaration is separate from import clearance in the UK.
What changes between DAP and DDP?
Under DAP the buyer usually arranges UK import clearance; under DDP the seller does. Incoterms divide costs and risk but do not decide who the importer is in law.
Does this division need to be settled before the documents are issued?
Yes. Without this, it is easy to end up with a mismatch between the invoice, the carrier's instructions and the expectations of the customer on the UK side.
What data is worth locking down before shipping?
The roles of the parties, the delivery model, the importer's details with its GB EORI number, the reference numbers, and the person responsible for quick corrections if an error appears.
Related guides
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