United Kingdom Brexit FAQ

Q:  What is changing in the UK’s import/export system after Brexit? What are the new rules?

A:  Changes are coming to the way Her Majesty’s Revenue and Customs (HMRC) handles import and export of goods and services.  Your best starting point is to visit the main HMRC Brexit Transition webpage.

Q:  What will the new tariff system look like? 

A:  You can find more information here. 

Q:  My business is registered in the U.S, and I’m selling directly to UK-based businesses, not consumers. Do I need to register for VAT? 

A:  According to the HRMC, the UK VAT registered business should provide you with their VAT registration number and needs to be listed on your documentation. After listing that number on your invoice, the responsibility to account for VAT will switch to the UK VAT registered business customer, who will account for it by means of a reverse charge procedure. Therefore, your business will not be liable to account for the VAT in these circumstances.

Your business must add a note to the invoice it issues to the UK business customer to make clear that the customer needs to account for VAT. The OMP or direct seller should include a reference to ‘reverse charge’ on the invoice, for example, ‘reverse charge: customer to account for VAT to HMRC’.

Follow this link for more information.

Q:  I am a U.S.-based business selling goods directly to consumers in the UK. Do I need to register my business for VAT in the UK? 

A:  According to the HRMC, from 11pm on 31 December 2020, UK supply VAT is due at the point of sale on consignments of goods that are outside Great Britain (England, Scotland and Wales) and sold directly to customers (not through an online marketplace) in Great Britain with a value of £135 or less.

You can find more information about VAT here. 

Q:  What are the main changes to the way VAT will be handled in the post-Brexit era? 

A:  For imports of goods from outside the UK in consignments not exceeding £135 in value, the HMRC will be collecting the VAT at the point of sale. This will mean that UK supply VAT, rather than import VAT, will be due on these consignments. Online marketplaces (OMPs), where they are involved in facilitating the sale, will be responsible for collecting and accounting for the VAT. 

For goods sent from overseas and sold directly to UK consumers without OMP involvement, the overseas seller will be required to register and account for the VAT to HMRC.

For more information, please visit this link. 

Q:  I live in the U.S.A, and selling goods online to consumers in the UK. Do I need to register my business for VAT in the UK after Brexit? 

A:  According to the HRMC, from 11pm on 31 December 2020, UK supply VAT is due at the point of sale on consignments of goods with a value of £135 or less that are outside Great Britain (England, Scotland and Wales) and are sold in Great Britain.
Where those goods are sold through an online marketplace, the online marketplace will be liable for the VAT.

Online marketplaces will also be liable for the VAT on goods of any value that are located in the UK at the point of sale and sold by an overseas business through an online marketplace.

You can find more information here. 

Q:  Can I reclaim the VAT I paid purchasing goods and services from the UK? 

A:  Yes, you can likely reclaim the VAT, for the most part. You can find details here. 

Q:  Will my EU CE mark be accepted in the UK after Brexit starts?

A:  Yes. The government intends to extend recognition of the CE marking for placing most goods on the market in Great Britain, indefinitely, beyond December 2024. The UKCA (United Kingdom Conformity Assessment) mark will also be accepted.  For more information, please visit the HRMC UKCA Guidelines. 

Q:  I cannot find the answer I am looking for, who can I contact? 

A:   Please contact Office.London@trade.gov if you have questions or are seeking additional information.