Selling to the UK from the EU After Brexit: VAT, EORI & the £135 Rule
Since 2021, Great Britain has been a third country for VAT — no reverse charge on goods, no VIES, no EC Sales Lists. This guide gives EU sellers the complete 2026 playbook: the £135 consignment rule, both EORI numbers, postponed VAT accounting, the Northern Ireland exception, and customs-ready invoicing.
Part 1: What Brexit Changed (and What Didn't)
Before 2021, selling to the UK worked like selling to France: reverse charge, VIES checks, EC Sales Lists. All of that ended for Great Britain. What changed:
- Goods are now exports/imports: every shipment needs a customs declaration on both sides — an EU export declaration and a UK import declaration.
- No EU reverse charge on GB goods sales: you zero-rate the export (with proof of shipment) instead of reverse-charging.
- No VIES for GB numbers: verify UK customers with HMRC's checker, not VIES. EU numbers are still checked in the VAT validator.
- No EC Sales Lists for GB: Great Britain is outside the system, so GB sales are never recapitulative-statement items.
- What didn't change: your EU-side obligations for other member states continue exactly as before — OSS, ESL and Intrastat are untouched by the UK sale itself.
Background on the UK system — rates, thresholds, returns — is in the UK VAT Guide.
Part 2: The £135 Consignment Rule (B2C Goods)
The single most important rule for EU online sellers. For business-to-consumer consignments of goods imported into Great Britain valued at £135 or less:
- VAT moves to the point of sale: you, the overseas seller, charge 20% UK VAT at checkout instead of the customer paying import VAT at the border.
- Customs value is what counts: the £135 is the intrinsic goods value excluding transport, insurance and VAT — not the checkout total.
- Above £135: normal import rules apply — the buyer (or their courier) handles import VAT and any duty, and you zero-rate the export.
- Marketplaces: if you sell through an online marketplace, the platform typically collects the UK VAT on low-value consignments on your behalf — check your platform's terms so you don't charge twice.
Worked Example: Two Parcels to London
Part 3: EORI Numbers — You Need Two
An EORI (Economic Operators Registration and Identification) number identifies you to customs. Post-Brexit sellers need both sides covered:
Apply before your first shipment: a missing EORI is the most common reason parcels stall at the border in week one of a new trade lane.
Part 4: Postponed VAT Accounting for EU Importers
If you import into Great Britain yourself — stock for a UK warehouse, Amazon FBA inventory, exhibition goods — you face 20% import VAT in cash at the border unless you use PVA:
- Register for UK VAT first (non-established traders register from the first sale — no £90,000 threshold).
- Put GB EORI + VAT number on the import declaration and select PVA — goods clear with £0 paid.
- Declare Box 1 / reclaim Box 4 on the same UK VAT return; net value in Box 7.
- Archive the monthly statement from HMRC as evidence (there is no C79 under PVA).
Full mechanics with a £40,000 worked example: Postponed VAT Accounting guide.
Part 5: Northern Ireland — The Exception
Goods moving between the EU and Northern Ireland still run under EU VAT rules (XI prefix): reverse charge, VIES checks and EC Sales Lists all apply as if Brexit never happened for those flows. Services follow UK rules everywhere including NI. Operational rule: confirm GB vs NI before you invoice — the same customer address format can hide a different VAT regime, and the wrong treatment means an invalid invoice plus a missing ESL line.
Part 6: Services and Digital Sales
Services never clear customs, but place-of-supply rules still decide where VAT lands. The patterns EU sellers hit most:
- B2B services to UK clients: usually taxed where the customer belongs (UK) under the general rule — the UK client self-accounts; you invoice without VAT and reference the reverse-charge-style treatment. Confirm the client's VAT status with HMRC's checker.
- B2C digital services to UK consumers: UK VAT typically applies at 20% — the EU OSS does not cover the UK, so a separate UK VAT registration may be required above the relevant thresholds.
- Used the OSS for EU sales? Keep it — just remember the UK sits outside it entirely. One interface, two systems.
Part 7: The Customs-Ready Invoice
Your commercial invoice doubles as a customs document now. Every GB-bound goods invoice should carry:
- Both EORI numbers (EU exporter, GB importer of record) and both parties' VAT numbers.
- Commodity (HS) codes per line item — couriers and customs brokers will ask for these before anything else.
- Incoterms (e.g., DDP vs DAP) — they decide who pays duty and import VAT, which is exactly what the £135 logic turns on.
- Currency and value basis — state whether values are goods-only or include freight/insurance, since the £135 test uses intrinsic goods value.
- Zero VAT with reason — show €0/£0 VAT with "Export — zero-rated" rather than a blank, so the invoice is valid on both sides.
Build it with the Invoice Generator (sequential numbering, VAT breakdowns, PDF export), convert totals at ECB rates with the Currency Converter, and validate any EU-side VAT numbers with the VAT Validator.
Seller's Checklist: First Shipment to Britain
- Get both EORIs (EU + GB) before booking freight.
- Classify consignments above vs below £135 — different VAT treatment for each.
- Set checkout to charge 20% UK VAT on sub-£135 B2C carts (or confirm your marketplace does it).
- Register for UK VAT + PVA if you import stock yourself — never fund 20% upfront unnecessarily.
- Split NI customers into XI treatment (goods) from day one.
- Issue customs-ready invoices with EORI, HS codes, Incoterms and zero-VAT reasoning.
- Archive everything — export proofs, VIES/HMRC checks, PVA statements — for 7+ years.
Frequently Asked Questions
Do I charge VAT when selling from the EU to the UK?
For B2C goods consignments of £135 or less, you generally charge 20% UK VAT at the point of sale. For larger consignments and most B2B sales, you zero-rate the EU export and UK import VAT is handled on the UK side — often via Postponed VAT Accounting. Services follow separate place-of-supply rules.
What is the £135 rule for UK imports?
For business-to-consumer goods consignments valued at £135 or less imported into Great Britain, VAT is collected at the point of sale: the overseas seller charges 20% UK VAT at checkout instead of the buyer paying import VAT at the border. Above £135, normal import procedures apply.
Do I need a GB EORI number as an EU seller?
Yes, if goods move in or out of Great Britain on your behalf. You need a GB EORI number starting with GB for UK customs declarations, in addition to your EU EORI number for the EU side. Apply free via HMRC before your first shipment.
Can EU businesses use Postponed VAT Accounting?
Yes, once UK VAT registered with a GB EORI number. PVA lets you declare UK import VAT on your VAT return (Box 1 and Box 4) instead of paying cash at the border — removing the 20% upfront funding cost on every shipment.
Is Northern Ireland treated like the rest of the UK?
No. For goods, Northern Ireland follows EU VAT rules under the XI prefix — EU sellers treat NI goods sales as intra-EU supplies with reverse charge and EC Sales Lists. For services, UK rules apply. Always confirm whether your customer is in NI or Great Britain before invoicing.
Do I still file EC Sales Lists for UK sales?
No. Since Brexit, Great Britain is a third country outside the EU VAT system, so GB sales are exports — not intra-EU supplies — and do not go on EC Sales Lists. The exception is goods sales to Northern Ireland (XI), which are still reported as intra-EU supplies.
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Disclaimer: This article provides general information about EU–UK trade VAT rules. Customs and VAT rules change; this is not tax or customs advice — confirm with HMRC, your national authority, or a customs agent. Information is current as of September 2026.