The import market was £483.9 billion.
The import market was £421.9 billion.
The total imports was £905.8 billion.
Do you have your trade routes and product requirements ready?
CERT can provide Authorised Representation for your products in both the UK and EU market. Feel free to arrange a no-obligation consultation to see how we can help you.
An overview explaining how CERT implements the Product Authorised Representation service:
Companies must understand the impact of Brexit on their supply chains. Ensuring compliance with current customs rules and regulations is now more critical than ever. Non-compliance can have severe consequences, including increased audits, delays in goods clearance, and the loss of duty reliefs. Combined with the additional checks on international shipments, this could prove highly disruptive to business operations.
The current Brexit terms have been agreed with the EU and approved by the UK Parliament. The UK has reclaimed control of its trade policy and has left both the EU Customs Union and the Single Market. The agreement, however, remains contingent on the UK continuing to uphold its obligations.
The Agreement is structured into seven Parts:
Part 1 – common and institutional provisions;
Part 2 – trade and other economic aspects of the relationship (e.g. aviation, energy, road transport, and social security);
Part 3 – cooperation on law enforcement and criminal justice;
Part 4 – “thematic” issues, notably health collaboration;
Part 5 – participation in EU Programmes, principally scientific collaboration through Horizon;
Part 6 – dispute settlement;
Part 7 – final provisions.
The key areas affecting import/export businesses are:
Customs processes
Third-country treatment for regulatory purposes
Sanitary and phytosanitary checks
Recognition of qualifications
Movement of people
Note: Movement of People is not addressed in this documentation.
The United Kingdom formally left the European Union on 31 December 2020 at 11:00pm. The principle of the free movement of goods within Europe no longer applies to the UK, and this agreement does not reinstate it. The 1,200+ page Brexit agreement does, however, provide extensive detail regarding future product regulation, with some positive signals.
Importantly, the EU and UK have jointly agreed a free trade agreement (FTA), which establishes zero tariffs and no quotas on trade between the two markets – welcome news for businesses. Nonetheless, the UK’s exit from the EU means exporters must address new tax obligations and, in many cases, secure EU representation for their products.
If you have queries regarding market entry, we can provide both technical and legislative support. We are also able to offer EU and UK product representation, depending on your requirements. Please contact CERT or see the details below for further information on how Brexit may affect your business.
So how does this affect my business?
UK Government support is available for import and export procedures, including guidance on customs, VAT, and regulatory compliance.
Key considerations for businesses include:
- Verifying the ability to recover import and export VAT within both the UK and the EU
- Assessing potential additional withholding tax costs on interest, royalties, and dividend payments
- Scheduling system updates, including invoice wording and Accounts Payable/Receivable coding
- Forecasting cashflow impacts and implementing suitable hedging strategies for currency exposure
- Mapping goods and service supply chains to identify related tax implications
- Reviewing Financial Reporting Council (FRC) requirements to identify and disclose any Brexit-related risks
- Determining additional VAT registration and fiscal representative obligations
Customs Procedures and Authorisations
- An individual guarantee or a customs comprehensive guarantee is required to enter goods into a customs special procedure and defer duty.
- Businesses may wish to consider Authorised Economic Operator (AEO) status, which demonstrates secure management of customs processes and compliance with both UK and EU standards.
- Another option is applying for a customs comprehensive guarantee to cover customs debts.
Taxation for Exported Products
- For guidance on VAT requirements and compliance for goods traded with the EU, see the European Commission’s advice: EU rules in the field of Value Added Tax (VAT) for Goods.
Representation Services
CERT provides technical and legislative support, along with EU and UK product representation depending on your requirements. Please get in contact for more information about product representation services.
Note: CERT is not offering finance or insurance services at this time.
If you are exporting products between the UK and EU markets, you must have an EORI (Economic Operator Registration and Identification) number. For the UK, EORI numbers begin with “GB…”; for Northern Ireland, they start with “XI…”; and for the EU, the prefix is “EU…”. The EORI number is essential for customs clearance on both import and export shipments between the UK and EU. As the exporter, you are required to obtain an EORI number for the country from which you are exporting, while the recipient (importer) must have the appropriate EORI number in their country to receive the goods. This ensures tax requirements are correctly applied and that customs authorities can accurately track stock and product movement.
While the practical details of the UK’s post-Brexit trading relationship with the EU continue to evolve, the following is established:
- Customs declarations are mandatory for all exports from the UK to the EU.
- All goods imported into the UK require customs paperwork in line with the UK Border Operating Model.
- The European Commission has implemented the Import Control System 2 (ICS2) for improved customs security and risk assessment on shipments entering the EU.
For further official guidance, see:
- ICS2 Factsheet — a concise, two-page summary of the system
- European Commission guidance on EU customs rules and preferential origin related to the UK withdrawal
Key points businesses should address include:
- Applying for the Customs Freight Simplified Procedures (CFSP) to streamline customs declarations at the border.
- Agreeing on suitable INCOTERMS with trading partners to clarify responsibilities and costs.
- Determining how to capture and manage the data necessary for accurate customs declarations, including verifying product classification codes.
- Ensuring all parties have valid EU and UK EORI numbers to comply with customs requirements.
- Engaging a logistics or customs compliance provider authorised to submit customs declarations on your behalf.
Keeping these points in mind will help ensure smoother cross-border trade and compliance with current UK and EU customs regulations.
If further detail or clarification is required about any of these topics, please feel free to ask.
The UK’s departure from the EU has introduced new challenges and operational requirements, including border controls and specific restrictions. In response, the UK Government has established the Trader Support Service (TSS), which provides £200 million in customs support for businesses trading with Northern Ireland.
Key considerations for businesses engaging in cross-border trade include:
- Mapping current and proposed supply chains to identify and mitigate any additional costs and administrative burdens arising from new customs formalities.
- Confirming INCOTERMS with trading partners, ensuring clarity over responsibilities for shipping, insurance, and duties.
- Identifying critical suppliers and assessing their readiness for customs and regulatory changes, preferably secured through supplier declarations or statements.
- Engaging closely with stakeholders to clarify obligations and expectations under both UK and EU regulations, including authorisations, licences, and compliance requirements, and resolving any potential bottlenecks.
The UK Government has published comprehensive guidance on importing and exporting goods between the UK and EU, including:
- Standard export procedures
- Customs documentation and requirements
- Licensing obligations
- Check if you need to complete customs declarations (official guidance)
For shipping and transit, it is important to note that INCOTERMS remain unaffected by Brexit, as they are international commercial terms defined by the International Chamber of Commerce. Understanding and correctly applying INCOTERMS is crucial for clarifying freight costs, responsibility for carriage, risk transfer, and insurance between buyers and sellers. A helpful summary can be found here: Quick overview on shipping INCOTERMS.
Brexit has also had considerable impacts on transit routes and documentation requirements:
- Under new customs arrangements, goods moving between Great Britain and the EU must comply with customs declarations and may be subject to additional checks at the border.
- The EU’s Import Control System 2 (ICS2) requires advance electronic notification for goods entering the EU to enhance security and risk assessment.
- Transit goods may be subject to further scrutiny and specific transit procedures, which businesses need to understand to avoid delays and penalties.
- The Northern Ireland Protocol introduces a unique customs and regulatory regime, meaning goods moving between Great Britain and Northern Ireland face different requirements than those moving between Great Britain and the rest of the EU.
To assist with these complexities, the European Commission has published detailed scenarios to support businesses navigating customs and transit processes post-Brexit:
Careful planning, clear communication with partners, and understanding regulatory requirements are essential to managing these changes effectively and maintaining smooth shipping operations.
Taking these factors into account will assist businesses in navigating the complexities introduced by Brexit and maintaining compliance in their cross-border operations.
Distributor & Importer
From 1 January 2021, where manufactured goods are brought into the UK from the EU/EEA (or exported in the opposite direction), the status of the company responsible for placing the goods on the market changes. What was previously regarded as a “distributor” is now legally considered an “importer”.
Labelling is a particularly complex area, as it must address a wide range of product categories. Further below, we have set out examples of product-specific sectors with an overview of the anticipated changes. However, it would not be possible to provide a complete response to every potential labelling query within a single document, as the level of detail required could easily amount to an encyclopaedia’s worth of guidance.
By way of illustration, in the section on food products, we have not explored in depth the rules governing the naming of certain foods and ingredients linked to geographical origin, nor in the section on detergents the dedicated Brexit-specific guidance that extends beyond the standard chemical requirements.
If you have a particular question or require more detailed information on any of the areas highlighted, please do get in touch and we will be happy to advise further.
Testing Standards
The European Committee for Standardization (CEN) has confirmed that the British Standards Institution (BSI) will retain its membership of CEN, regardless of the United Kingdom’s withdrawal from the European Union without a negotiated agreement. Accordingly, in the event of a no‑deal scenario, BSI standards will remain valid, and the United Kingdom will continue to participate in the development of new European standards. Furthermore, all European harmonised standards will continue to be adopted and implemented in the United Kingdom as designated standards.
Ireland / Northern Ireland
From 1 January 2021, the Protocol on Ireland/Northern Ireland entered into effect. The Protocol is subject to periodic consent by the Northern Ireland Assembly, with the initial period of application extending for four years following the conclusion of the transition period. Under the Protocol, EU rules continue to apply in Northern Ireland, which is thereby treated, for regulatory purposes, as if it were an EU Member State.
Made In
In accordance with EU regulatory requirements, the country of manufacture must be indicated on the product label where that country lies outside the European Union. Consequently, products manufactured in the United Kingdom and placed on the EU/EEA market must display an origin statement confirming that they are made in the UK.
Certain product categories are subject to additional sector‑specific requirements concerning the use and presentation of the “Made in” statement, which are addressed in greater detail within the relevant sub‑sections of this guidance. Stakeholders seeking clarification on particular cases are encouraged to make direct enquiries for further advice.
Overview
The UK Government’s decision to defer the implementation of certain mandatory labelling changes meant that, until 30 September 2022, most foods compliant with EU food labelling rules could continue to be placed on the market in Great Britain (GB). During this period, packaging could still feature an EU address for the Food Business Operator (FBO) and were also permitted to use “EU” and “non‑EU” origin designations.
Since 1 October 2022, stricter requirements were applied. Packaging for all foods placed on the GB market must display a UK address for the FBO. Where the FBO is not established in the United Kingdom, the label must instead bear the address of the UK importer. In addition, “EU” origin references may no longer be used, and must be replaced by either “UK” or “non‑UK”, unless individual countries of origin are specified on the label.
The EU organic logo can no longer be applied to UK organic products unless the relevant control body has received EU authorisation to certify such products for export to the EU, or until such time as the EU and UK agree to mutual recognition of each other’s organic standards.
By contrast, no extension has been granted regarding EU food labelling requirements for products exported from GB to the EU and all such foods must comply fully with EU labelling legislation. Since Northern Ireland aligns with EU rules under the Protocol, food labels there may continue to show an EU or Northern Ireland address for the FBO or importer and may display the EU emblem and “EU origin” claims. However, for the avoidance of doubt, foods manufactured in GB and subsequently sold in either the EU or Northern Ireland may no longer carry EU‑specific particulars.
The key relevant labelling areas affected
The key relevant labelling areas that are subject to changes from 1st January 2021 are:
- Food Business Operator (FBO) address
- EU Health and Identification marks & use of EU emblem
- Organic products & use of logo
- Country of Origin labelling
- Protected Geographical Status Changes (GI Logos)
Country of Origin Labelling
Exporting to the EU:
Since 1 January 2021, food produced in Great Britain (GB) and placed on the EU market cannot not be labelled as having ‘EU’ origin. By contrast, food originating from Northern Ireland (NI) can bear the designation ‘origin EU’. Where EU law requires a specific Member State to be indicated on the label, food from Northern Ireland should be marked as either ‘UK(NI)’ or ‘United Kingdom (Northern Ireland)’.
Goods Sold in GB and NI:
GB: Food produced in and sold within GB can no longer be labelled as ‘origin EU’. Since 1 October 2022, this wording can no longer be used and GB products must adopt alternative origin references.
NI: Food produced and sold within NI may continue to use either ‘origin EU’ or ‘origin UK’, provided EU legislation does not require the label to identify a specific EU Member State. Where such a requirement does apply, the designation must be ‘UK(NI)’ or ‘United Kingdom (Northern Ireland)’.
NI into GB:
Food produced in Northern Ireland and sold in GB may be labelled as ‘UK(NI)’, ‘United Kingdom (Northern Ireland)’, or simply ‘UK’.
Transitional Provisions and Product‑Specific Rules:
Certain product categories are subject to specific labelling requirements in both GB and NI, including (but not limited to):
- Minced meat
- Fresh fruit and vegetables
- Particular types of honey
- Eggs
Further Guidance:
The team at CERT remains available to offer practical support and technical solutions to ensure your continued compliance. Please do not hesitate to get in touch with us.
Geographical Indication (GI) Logo
The EU protected food name scheme enables consumers to identify products with an assured regional provenance. Since 1 January 2021, EU protection rules ceased to apply to newly registered UK‑related GI products. However, all products registered under the EU’s GI schemes before the end of the transition period remain protected within the UK’s corresponding schemes.
The United Kingdom has established its own GI schemes, covering food, drink and agricultural products, spirit drinks, wine and aromatised wine.
The UK’s designated logos are – Protected Designation of Origin (PDO), Protected Geographical Indication (PGI), and Traditional Speciality Guaranteed (TSG). Use of the appropriate UK logo is mandatory for GB products.
GB GI products that have secured protection within the EU may continue, after the UK transition period, to display the relevant EU logo in the UK market in addition to the mandatory UK logo.
Overview
Certain product categories—such as cosmetic products and items bearing the CE mark—must include on their labelling the address details of an authorised representative based within the market in which the product is sold. Where products are placed on both the EU and UK markets, the name and address of the Responsible Person for each territory must be clearly indicated on the label.
If you are planning to export into either the UK or EU, it is a legal requirement to appoint an official market representative.
CERT is a registered business in both jurisdictions, with offices in London and Berlin, enabling us to act as your technical and regulatory representative across all 28 markets according to your needs.
For further information or tailored guidance, please do not hesitate to get in touch with us.
General Product Safety
The EU market operates under the General Product Safety Regulation (GPSR) 2023/988 (GPSR), which replaced the previous General Product Safety Directive (GPSD), and serves as the overarching “safety net” for all consumer products placed on the market. In addition, certain categories of products are subject to specific Directives or Regulations that impose requirements beyond those of the GPSR.
Products placed on the UK market are required to comply with the General Product Safety Regulations 2005 (GPSR). In instances where both the GPSR and product‑specific legislation apply, the requirements of the latter will normally take precedence.
Mandatory Compliance Marks
The CE marking has long been required across a wide range of product categories. It does not, in itself, confirm product safety; rather, it indicates that a product meets the relevant EU safety, health, and environmental protection requirements, thereby allowing its free movement within the European single market.
As the CE marking is an official EU conformity mark, products placed on the UK market did require the UK Conformity Assessed (UKCA) marking, but this was quickly withdrawn in August 2023 with CE marking accepted indefinitely as a compliance mark, except for certain sectors e.g. Pressure Vessel Directive with their own regulations. The UKCA mark as a quality/safety mark is still accepted on the UK market as an alternative to the CE Mark, but it is more common practice to see the CE mark now.
Formulated Products
Formulated products fall under 5 key areas with dedicated regulations:
- Biocides – Authorisation of biocidal substances and products
- CLP – Classification, labelling and packaging of substances and chemicals
- PIC – Prior informed consent
- PPP – Pesticides or Plant Protection Products
- REACH – Registration, evaluation, authorisation and restriction of chemicals
UK REACH and Formulated Products
The UK Health and Safety Executive (HSE) has transposed the EU Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) into UK law under the European Union (Withdrawal) Act 2018. This ensures that the framework of REACH is retained within the UK, however surrounding regulations such as Safety Data Sheets have been updated in the EU market which the UK has not readily adopted. So, there is a divergence in legislation requirements emerging.
Q&As Relating to UK‑Based Only Representatives
Existing REACH registrations
- Under the EU REACH Regulation, only companies established within the EU/EEA are permitted to hold a registration. Accordingly, if your business is UK‑based and has previously registered a substance under EU REACH, that registration ceased to be valid upon the UK’s withdrawal from the EU.
- The UK authorities will recognise and honour your existing registration until its expiry date; however, you should have appointed an authorised holder (Responsible Person) in the UK.
- If you trade in the EU/EEA market following the UK’s exit, you need to either:
- Appoint an Only Representative (OR) established in the EU/EEA to manage your registrations on your behalf; or
- Transfer the relevant aspects of your operations to a legal entity established within the EU.
Further Support:
If you require additional detail on any of the five key formulation areas, please contact us specifying your area of interest and we will be able to provide a comprehensive report.
The team at CERT remains available to offer practical support and technical solutions to ensure your continued compliance. Please do not hesitate to get in touch with us.
Cosmetics
Cosmetic Product Notifications Post‑Brexit
Cosmetic products placed on both the UK and EU markets must be separately notified via the UK – Submit Cosmetic Product Notifications (SCPN) – and the EU – Cosmetic Products Notification Portal (CPNP).
Product Information Files (PIFs)
Separate Product Information Files (PIFs) are required for the United Kingdom and the European Union. This may necessitate re‑labelling products currently marketed in both jurisdictions, as the responsible person (RP) and the PIF location must be clearly identified for each market.
Please note that your nominated safety assessor will need to have qualifications that are recognised in your intended market. Not all UK qualifications are recognised in the EU market.
Further Support
If you would like a more detailed report tailored to your area of interest, please contact us. The CERT team is also readily available to provide technical support and regulatory solutions to help you maintain compliance across both markets.
Electrical Products
The UK adopted the existing EU harmonised electrical standards in the short term. Over the longer term, oversight and control of UK standards will be managed by the Office for Product Safety and Standards, with legislation potentially evolving to reflect specific UK market requirements.
Please feel free to get in touch if you would like a more detailed report. Should you require specific product support or have any questions, we are here to assist.
Toys
Toys will be subject to the generic labelling changes. Any formulation aspects related to base materials or colours will primarily affect the supporting technical documentation rather than the product labelling itself.
Second-hand toys, like most second-hand products, may be sold with existing labelling, provided they comply with the General Product Safety Regulations 2005, rather than the Toys (Safety) Regulations 2011, and are confirmed to be safe.
Please feel free to contact us if you would like a more detailed report. Should you require specific product support or have any questions, our team is readily available to assist.
Textiles
Textile products are subject to the necessary generic labelling changes following Brexit. The UK adopted the current EU legislation in 2020, supported by the UK Textile Products (Labelling and Fibre Composition) Regulations 2012. These regulations require all textile products to carry a label indicating the fibre content, including any non-textile parts of animal origin such as fur or leather. The label must be durable, legible, visible, and accessible to the consumer.
Manufacturers and importers are responsible for ensuring that textile products comply with these labelling requirements.
Should you need specific product support or have any questions, please feel free to contact us. We would be happy to assist.
If there’s one positive to come from the Brexit situation, from a business perspective, it’s that it forces a rethink of international marketing strategies focused on success in Europe. Targeting markets on the continent should be part of any international marketing strategy post-Brexit. Thankfully, the digital age has revolutionised international marketing strategies. No longer is it an absolute necessity to constantly visit foreign nations, employ marketing or sales agents based overseas and establish international offices in order to raise brand awareness. Below is a list from the EU Commission of key contacts for different markets within the EU:
National contact points or websites dedicated to UK withdrawal-related information
At the same time as a business you need to understand the markets you are entering. CERT can provide the product regulatory support you need and happy to introduce you to contacts in the industry if you need help with other areas of business expansion.
Have you visited our market exploration tools?
As the two markets (EU and UK) diverge, there will be varying regulations and requirements coming into force. With this change, it is imperative that you ensure that your products are safe and compliant for the markets you intend to sell in. An example of the upcoming changes for the EU market proposed in the 2021 Work Programme addressing:
- Sustainable products policy initiative, including a revision of the Ecodesign Directive.
- Circular Electronics Initiative.
- New design requirements and consumer rights for electronics.
- Artificial Intelligence.
- Evaluation of the New Legislative Framework (“NLF”) for Products.
- Revision of Packaging and Packaging Waste Directive.
- Revision of the Machinery Directive.
- Evaluation of the EMC Directive.
A quick final checklist of points to cover:
- Undertake a regulatory assessment to understand what (if any) new labelling changes and product standards could mean for your products depending on the source and where they are being sold.
- Examine the extent to which your business transfers GDPR data from the EU to UK and where is the data being stored and processed.
- Put in place standard contractual clauses to support personal data and appropriate adequacy agreement.
- Review commercial contracts to understand and assess international market risk. Identify terms that could be affected and proposed response.
If you need any help with product and market regulatory requirements and the immediate actions needed to prepare, CERT are happy to provide advice and support.
The Agreement between the UK and EU confirms that the UK government is to have independence from the EU, in the field of environmental protection as well as elsewhere. Our objective is to ensure you are up to date with the requirements for your product area and target market. Whether it is dedicated product labelling information; import/export requirements; transition rules for selling existing products; trade requirements or product representation to ensure your export market continues. CERT is here to ensure you remain competitive in the market and we mitigate your business risk as much as possible.
If you export retail products to the UK or EU markets, you will need a locally based market representative for your product. Failing that, the importer will need to act as the market introducer, taking liability for your products and have their address on your product labelling.
CERT has a registered business in Berlin for the EU and London for the UK markets. We can bridge the gap for you by providing representation of your product if you are exporting to either market. Providing you with an appropriate contact address for your product labelling and allowing you to obtain the necessary product registrations that you require.
If you have a product and looking to break into a new market or ensure it is compliant for the current market; CERT can support getting your products to market quickly, while upholding the most stringent technical requirements. By applying our comprehensive technical, legislative, translation and industry knowledge, we can ensure your product is safe and compliant for the markets you intend to sell in.
Small enough to care, but talented enough to produce the excellence you demand.
Feel free to drop the team a message below, letting us know in the message box the particular area you are interested in. Alternatively if you want to arrange a quick online meeting or phone call, feel free to find some time in the diary.