Goods sent from Great Britain to a business or consumer in the EU are now exports: you can zero rate them for UK VAT if you meet the Notice 703 conditions, but the goods need an export declaration and the EU country of arrival treats them as imports, with its own VAT and duty. Northern Ireland is different. Under the Windsor Framework, goods sent from Northern Ireland to the EU are dispatches, with EU style rules for business sales and a distance selling threshold of £8,818 (10,000 euros) for consumer sales.

How is a sale from Great Britain to the EU treated for UK VAT?

VAT Notice 703, paragraph 2.2, says goods located in Great Britain that are sent to an EU destination follow the export rules. The supply can be zero rated as long as the goods leave the UK and you obtain valid evidence of export, generally within 3 months of the time of supply. HMRC’s exports guide states the 3 month limit and says you must not zero rate if the customer asks you to deliver to a UK address. The detail on evidence and time limits is in zero rating exports of goods. Exports go in box 6 of the VAT return.

The same treatment applies whether the customer is a business or a private individual. There is no longer a separate category of zero rated intra EU supply to a VAT registered customer from Great Britain, and EC Sales Lists are only required for goods supplied from Northern Ireland to EU VAT registered traders (Notice 700, paragraph 5.8.1). What differs between business and consumer sales is mostly what happens at the EU border and who deals with it.

What customs steps does a GB seller need to take?

The GOV.UK step by step guide to exporting sets out the practical sequence:

  1. Get an EORI number starting with GB. Moving goods to or from Northern Ireland may need one starting with XI.
  2. Check duties, rules and restrictions in the destination country, and any UK export licences for controlled goods.
  3. Decide who will make export declarations and transport the goods. Most businesses appoint a customs agent or carrier, but remain responsible for the VAT conditions (Notice 703, paragraph 2.5).
  4. Classify the goods with the correct commodity code.
  5. Prepare the commercial invoice using the selling price, with freight and export insurance shown separately, and any licences or certificates.
  6. Get proof of origin if the goods qualify for a reduced or zero rate of duty in the destination country.
  7. Make the export declaration so the goods are cleared by UK customs, then keep the invoices and customs paperwork.

The guide also tells exporters to check that whoever receives the goods can import them, because the recipient may need to make an import declaration in their country.

Origin and duty

Zero UK VAT on the export does not mean zero cost at the EU border. Preferential duty rates depend on the goods meeting rules of origin. HMRC’s guidance on proof of origin explains that an origin declaration, also called an invoice declaration or statement on origin, can be made on a commercial document that identifies the goods in enough detail. Goods that do not meet the origin rules may face duty even though the seller is in the UK.

What changes when the customer is a consumer?

For UK VAT, nothing: a GB sale to an EU consumer delivered abroad is a zero rated export if the evidence conditions are met. For posted goods, Notice 703 paragraph 7.6 accepts a stamped certificate of posting for letter post, and Parcelforce or courier records for parcels.

The practical difference is that a consumer cannot be expected to handle an import declaration or a surprise VAT bill. Before selling to EU consumers, decide in your terms of sale who acts as importer and who pays the EU import VAT and any duty, and check the destination country’s rules as the exporting guide advises. Those EU charges are governed by the law of the EU country concerned, not by HMRC.

Some consumer sales cannot be zero rated at all. Under Notice 703, paragraph 3.4, goods sold to an overseas visitor for personal use who takes them home in accompanied baggage are not zero rated as an indirect export, so an EU tourist buying in a GB shop pays UK VAT.

What if goods are held in an EU warehouse first?

Sending your own stock from Great Britain to a warehouse in the EU is not a supply. Notice 703, paragraph 2.13, says you need proof of export as evidence of the transfer, you can deduct related input tax under the normal rules, and you do not include the value of the transferred goods in box 6. When you later sell the goods from the EU warehouse, Notice 700, paragraph 4.8.2, treats goods located outside the UK when supplied as supplied outside the UK, so the sale is outside the scope of UK VAT. Any VAT on that sale is a matter for the EU country where the goods are, and you should expect to deal with its tax authority.

How are Northern Ireland sales to the EU different?

Under the Windsor Framework, goods moving from Northern Ireland to the EU are not exports. HMRC calls them dispatches.

Sales to EU VAT registered businesses

HMRC’s dispatches guidance says you can zero rate the supply if all of these apply:

  • the goods leave the UK from Northern Ireland to an EU country
  • the customer is VAT registered in an EU country
  • you obtain the customer’s VAT registration number, including the 2 letter country code, and show it on your invoice
  • you dispatch the goods and obtain evidence of removal within 3 months

Evidence of removal must show your details, the customer’s details, a detailed description and value, the transport method and route, and the destination, and must be kept for 6 years. You also send EC Sales Lists (Notice 700, paragraph 5.8.1). The value also goes in box 8 of the return, as well as box 6 (Notice 700/12, paragraphs 3.7 and 3.9).

Sales to EU consumers

Notice 725, paragraph 6.6, says that from 1 July 2021 the pan EU distance selling threshold is £8,818 (10,000 euros), measured on total sales to consumers throughout the EU in a calendar year. Below it, you charge UK VAT. Above it, VAT is due in the country of arrival. You can then either register in each EU country or use the One Stop Shop Union scheme through HMRC. To use it you must be UK VAT registered and trading under the Windsor Framework. You must apply by the 10th day of the month after your first eligible supply, file a single quarterly return and payment for all eligible distance sales, and keep records of each sale for 10 years.

A worked example

Illustration only. A Leeds based online retailer sells a £500 order to a German consumer, posted by tracked courier, and a £20,000 pallet to a French trade customer, shipped by its own haulier.

  • Both are exports from Great Britain. If the courier and haulier records meet Notice 703, both are zero rated and the £20,500 goes in box 6.
  • Neither appears on an EC Sales List, and the retailer is not using the One Stop Shop Union scheme, which is for Northern Ireland distance sales.
  • At the German and French borders the goods are imports. The retailer’s terms say who pays the import VAT and any duty. Unless origin is proved, preferential duty treatment may not apply.

Had the same retailer been based in Newry and sending from Northern Ireland, the German consumer sale would carry UK VAT until its EU consumer sales passed £8,818 in the calendar year, and the French sale could be zero rated as a dispatch if the customer’s EU VAT number was on the invoice.

What mistakes do sellers make?

  • Assuming a sale to an EU VAT registered business is still an intra EU supply when shipped from Great Britain, and putting it on an EC Sales List.
  • Charging UK VAT on GB exports to EU consumers when the evidence exists to zero rate them.
  • Zero rating without export evidence because the parcel “obviously” went abroad.
  • Selling to EU consumers without deciding who handles the import charges, leading to refused deliveries.
  • Applying GB rules to Northern Ireland stock, or forgetting the £8,818 pan EU threshold.

If goods come back, for example as returns, they are imports into the UK and may qualify for Returned Goods Relief, as explained in HMRC’s guidance on paying VAT on imports. For VAT on the import itself see postponed VAT accounting. Selling downloads or other e services to EU consumers follows separate rules, covered in VAT on digital services to overseas consumers.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.