Since Brexit, exports from Poland to the United Kingdom stopped being an intra-EU delivery and became an export outside the EU customs territory - requiring an export declaration in the AES/ECS system and an EAD document accompanying the shipment. On the UK side, the goods are subject to a separate import declaration in the CDS system, and since January 2025 also to full safety and security checks (S&S GB) for most shipments. Companies also had to obtain EORI numbers valid on both sides of the border, since a single number no longer covers the whole route.
Contents
In short — what you'll learn
- ✓ How to prepare the process and documents
- ✓ How the declaration and checks work
- ✓ How to stay compliant and keep clean records
How to prepare the process and documents
Scope of responsibility between the parties
Minimum data set for the declaration
Comprehensive customs handling on the Poland-UK route is provided by a UK customs agency.
How the declaration and checks work
In post-Brexit customs declarations, it's essential to distinguish responsibility between the importer, the exporter and the customs representative, because this determines what data is submitted to the official systems.
Operational stages from notification to release
The most common risk points and how to reduce them
How to stay compliant and keep clean records
Staying compliant on customs matters requires a systematic approach to record-keeping and regularly reviewing the procedures used in light of current EU and UK rules.
Record-keeping, corrections and evidence of due diligence
An internal checklist should link the documentation requirements to the responsibilities of individual teams: logistics, accounting, and the person responsible for compliance. Customs documents should be kept on file for a minimum of 5 years from the date of clearance. If a declaration needs correcting, the relevant customs office must be notified without delay, with documents attached to justify the change in value or classification.
Working with a customs agency and internal audit
A customs agency holding AEO status provides additional compliance guarantees and speeds up clearance through simplified procedures. A regular internal audit helps identify risk areas before they become the subject of an official inspection. The process stays repeatable and resistant to misinterpretation when it is based solely on official guidance from KAS, the Ministry of Finance and HMRC.
Summary
In summary: when it comes to 'how has export changed since Brexit', what matters most is running the process according to current official guidance, with a clear division of responsibility and every decision documented. This approach limits delays, reduces the number of corrections and makes it easier to defend your records during an inspection. If any requirement is unclear, check the current guidance from KAS, the Ministry of Finance or HMRC before submitting a declaration.
Legal basis and sources
- KAS: Polish National Revenue Administration
- Ministry of Finance: Podatki.gov.pl
- HMRC: Safety and Security ENS API
If regulations or system notices are updated, check the current guidance on GOV.UK or KAS before submitting a declaration.
Frequently asked questions
What documents are mandatory for exports to the United Kingdom since Brexit?
Since Brexit, every export shipment to the UK requires: a commercial invoice, a transport document (CMR or AWB), an EX export declaration in the AES system, and, for certain goods, a EUR.1 certificate of origin or a statement on the invoice. On the UK side, the importer submits a separate import declaration in the CDS system. Incomplete documentation can result in the load being held at the border.
Does a Polish company exporting to the UK need an EORI number?
Yes, an EORI number issued by the relevant customs authority is mandatory for every Polish company exporting to the United Kingdom. Without an EORI number, it is not possible to submit an export declaration through the electronic system. The application for an EORI number is submitted to the Tax Administration Chamber - the process usually takes a few working days.
How did Brexit change the rules of trade between Poland and the United Kingdom?
Since 1 January 2021, the United Kingdom has been treated as a third country, which means full customs clearance is required every time goods cross the UK-EU border. The free movement of goods and the intra-Community VAT rule disappeared, replaced by an import procedure in the UK and an export procedure in Poland. New requirements appeared around ENS, phytosanitary checks, and rules of origin arising from the Trade and Cooperation Agreement (TCA).
What is an ENS declaration, and when is it required for exports to the UK?
An ENS (Entry Summary Declaration) is an electronic safety and security declaration that must be submitted before the goods arrive in the United Kingdom. It is mandatory for all commercial shipments and is submitted by the haulier or their representative through the S&S GB or ICS2 system. ENS deadlines depend on the mode of transport: for road transport, at least 1 hour before arrival; for sea transport, 24 hours before loading (containers), 4 hours before arrival (bulk/break bulk), or 2 hours before arrival (short sea routes).
How long do customs documents need to be kept after exporting to the United Kingdom?
Under the Polish Customs Code and VAT legislation, customs documents must be kept for a minimum of 5 years from the end of the year in which the customs debt arose or clearance took place. This covers invoices, export declarations, declaration confirmations, correspondence with the customs office, and transport documents. Missing documentation during an inspection can be treated as a breach of due diligence and result in financial penalties.
Related guides
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