UK Import & Customs Guide Post-Brexit: Navigating CDS and HMRC

A mid-sized European manufacturer recently tried to ship a critical machinery part to their UK customer. Pre-Brexit, this was a seamless transaction that took two days door-to-door. This time, the shipment sat at a UK Border Control Post for nine days. Why? The supplier hadn't registered for a UK EORI number, the commodity code was entered incorrectly on the new Customs Declaration Service (CDS), and nobody had elected for Postponed VAT Accounting, leading to a cash flow dispute over who was paying the 20% import VAT.

The UK customs landscape has undergone a seismic shift. The transition away from the EU customs union, combined with the migration from the legacy CHIEF system to CDS, and the phased rollout of the Border Target Operating Model (BTOM), has created a perfect storm of compliance challenges for both domestic importers and international sellers.

This guide demystifies the current HMRC import process, helping you avoid the common pitfalls that cause expensive border delays.

The UK Import Process: Core Requirements

Importing goods into the UK commercially requires specific registrations and documentation before your goods even arrive at the border.

Step 1: Get an EORI Number

You cannot import goods into the UK without an Economic Operators Registration and Identification (EORI) number. If you are a UK business, you need a number starting with 'GB'. If you are moving goods into or out of Northern Ireland, you may also need an 'XI' EORI number. Getting one from HMRC is free and usually takes only a few days, but failing to have it active before shipping will halt your goods entirely.

Step 2: Determine Your Commodity Code

The UK uses a 10-digit commodity code for imports (based on the global Harmonized System). You can find this using the UK Trade Tariff tool online. The correct code dictates your duty rate, whether import VAT applies, and if any special licenses or Border Control Post (BCP) checks are required.

Step 3: The Customs Declaration Service (CDS)

HMRC has permanently retired the old CHIEF system. All import declarations must now be made through the Customs Declaration Service (CDS). If you use a customs broker, they will file this on your behalf, but you still need to register for a CDS dashboard account to access your postponed VAT accounting statements and manage your duty deferment accounts.

Import Duty, VAT, and Cash Flow

One of the most significant changes for UK importers post-Brexit is the cash flow impact of import VAT.

Postponed VAT Accounting (PVA)

Before PVA, importers had to pay the 20% import VAT at the border before goods could clear, later reclaiming it on their VAT return. Now, Postponed VAT Accounting allows registered businesses to account for this import VAT on their standard VAT return without paying it upfront. This is a massive cash flow benefit, but it requires electing for PVA on your CDS declaration. If your broker misses this flag, you'll be billed at the border.

The UK Global Tariff (UKGT)

For goods imported from outside the EU, the UK Global Tariff applies. If you are importing from the EU, you may qualify for zero tariffs under the UK-EU Trade and Cooperation Agreement (TCA), but only if you meet the "Rules of Origin" requirements and hold the correct supplier declarations.

Frequently Asked Questions

Do I need an EORI number to import into the UK?

Yes. Any business importing or exporting goods commercially needs an EORI number. If your business is based in Great Britain, you need a 'GB' EORI number. If you trade with Northern Ireland, you might need an 'XI' EORI number. Apply online through HMRC; it's free and typically takes up to a week to process.

How long does UK customs clearance take?

If your CDS declaration is fully compliant, commodity codes are accurate, and no physical checks are required, clearance often happens within minutes or hours. However, delays typically occur when commodity codes are missing, valuation is disputed, or goods (like animal or plant products) are subject to Sanitary and Phytosanitary (SPS) checks at a Border Control Post. These physical inspections can add several days to your timeline.

What is postponed VAT accounting and should I use it?

Postponed VAT Accounting (PVA) allows UK VAT-registered businesses to account for import VAT on their standard VAT return, rather than paying it at the port. This provides a significant cash flow advantage. You absolutely should use it, but you must ensure your customs agent selects the PVA option on the CDS entry. You then download your Monthly Postponed Import VAT Statement (MPIVS) from your CDS dashboard to complete your VAT return.

What replaced CHIEF and how does CDS work?

The Customs Declaration Service (CDS) has fully replaced the legacy CHIEF system for all imports. CDS requires more specific data elements than CHIEF did, and it integrates directly with your HMRC digital account. Even if you use a broker, you must register for CDS to authorize your broker to use your cash accounts and to access your tax statements.

Do I need a customs broker to import into the UK?

While self-declaration via commercial software is legally permitted, the complexity of CDS means the vast majority of SMEs use a licensed customs agent or broker. Typical broker fees range from £45 to £85 per standard entry. Be aware of the difference between "direct representation" (where the broker acts in your name, and you hold all liability) and "indirect representation" (where the broker shares joint liability, typical for non-UK established importers).

How are UK import duty and VAT calculated?

Duty is calculated on the CIF (Cost, Insurance, and Freight) value of the goods, based on the percentage dictated by your 10-digit commodity code in the UK Global Tariff. Import VAT is then calculated (usually at 20%) on the total sum of the CIF value plus any import duties paid.

What are rules of origin and how do they affect UK-EU trade post-Brexit?

Under the UK-EU TCA, goods traded between the UK and EU can be imported tariff-free, but only if they "originate" in the UK or EU. Simply buying goods from Germany doesn't guarantee zero tariffs if those goods were actually manufactured in China. You must hold valid "Statements on Origin" or supplier declarations proving the goods meet the specific processing rules to claim preferential zero tariffs.

What goods require special import licenses or checks at UK Border Control Posts?

Since the phased rollout of the Border Target Operating Model (BTOM), high and medium-risk animal products, plants, and plant products require pre-notification via the IPAFFS system and export health certificates, and they are subject to physical SPS checks at designated Border Control Posts (BCPs). Because BTOM phases are actively evolving through 2025 and 2026, always verify current HMRC/DEFRA guidance for your specific commodity before shipping.

Key Takeaways

• Register for your GB EORI number and set up your CDS dashboard before your goods leave the origin port.
• Instruct your customs broker explicitly to use Postponed VAT Accounting to protect your cash flow.
• Do not assume EU imports are automatically tariff-free; you must maintain strict Rules of Origin documentation.
• Monitor the BTOM phases closely if you import agricultural, animal, or plant products, as border check requirements are actively changing.