Trade with the United Kingdom from 1 January 2021 for EU-based companies
The United Kingdom has left the EU.
On 31 December 2020, the United Kingdom will leave the European Single Market and the Customs Union.
From 1 January 2021, the rules governing trade with the United Kingdom shall change.
What your company needs to know
For your EU-based company, you will need to find out about the new rules and prepare for changes so that trade with the UK can continue smoothly from January 2021.
This information is also available in other languages:
Purchase and sale of goods
The rules will change and trade between the EU and the United Kingdom will be subject to similar provisions. More information on the procedures at the UK border.
Contact your trading partners in the United Kingdom to agree on responsibilities. Have the right documents ready for the type of goods you import or export across the British border. Make sure that you meet the required limits.
There will be no significant changes to the movement of goods between Northern Ireland and the EU Member States, including Ireland.
From 1 January 2021, companies in Europe will have to make customs declarations when transporting goods between the UK and the EU. Goods from EU companies may only cross the border if the correct customs procedures have been carried out.
You will need to check with the customs authority of your country which customs procedures apply to transport goods from the UK to the EU and whether import duties may apply.
If you are selling agricultural products or food to the UK, your company may need to:
examine the rules governing the export of food, drink or agricultural products to the United Kingdom
check which documents, licences and certificates are required for the goods you import from the EU to the United Kingdom and how you can apply for them
make a prior registration with the UK authorities for the products you export from the EU to the UK
Export of animals and animal products
From 1 January 2021, new sanitary and phytosanitary rules will apply to exports of animals and animal products to the UK. New health certificates may be required for export and these procedures will be phased in during 2021.
Learn more about exporting animals and animal products to the UK.
Imports of animals and animal products
From 1 January 2021, new sanitary and phytosanitary legislation will apply to imports of animals and animal products from Great Britain into the EU. This includes checks on imports at an EU border inspection post.
The EU importer must inform the border inspection post of the arrival of the delivery.
Learn more about importing animals and animal products from the UK to the EU.
Export of plants and plant products
From 1 January 2021, new phytosanitary requirements shall apply to the export of plants, fruit and vegetables from the EU to the UK, including phytosanitary certificates. If you are exporting plants, fruits and vegetables to the UK, please note the following:
check with your country’s plant health authority whether a phytosanitary certificate is required
check whether laboratory tests of samples of your plants are necessary to prove that they are free of pests and diseases or inspections during the growing season
apply to the competent national plant protection organisation for a phytosanitary certificate before export
Learn more about the export of plants and plant products.
Import of plants and plant products
From 1 January 2021, new phytosanitary requirements shall apply to imports of plants, fruit and vegetables from the UK into the EU. Imports of plants and plant products covered by the scheme may be subject to controls at the EU border. If you are importing plants, fruits and vegetables from the UK, you should consider the following:
find out if a phytosanitary certificate is required by contacting the UK Plant Health Authority or a plant health inspector in your country
apply for a phytosanitary certificate from the competent plant health authority in the UK through your exporter before export
check whether laboratory tests of samples of your plants are required to prove that they are free of pests and diseases, or inspections during the growing season. Plan enough time for this
Learn more about the import of plants and plant products.
If you launch goods manufactured in the UK on or after 1 January 2021, you may be subject to a number of changes, depending on the type of goods you bring to market. You may need to:
verify their product labelling, labelling and packaging
obtain additional authorisations, certifications or registrations
appoint a legal representative based in the United Kingdom
Find out how the legal responsibilities of you or your distribution partners may change
Learn more about placing manufactured goods on the UK market.
If you place manufactured goods on the market in Northern Ireland, the relevant EU rules apply to manufactured goods. Provided that the goods already comply with EU legislation and have the relevant authorisations, they will continue to form the basis on which they can be placed on the market in Northern Ireland. Further information will be published soon.
From 1 January 2021, energy-related products placed on the UK market shall comply with the rules in force in the UK.
Compliant products placed on the market before 1 January 2021 with EU flags on the energy labels may continue to circulate after the end of the transitional period.
Products placed on the market in Northern Ireland must comply with the relevant EU regulations. These include the EU flag and the QR codes that lead to the required product information on the EPREL database.
Find out about the regulations and take precautions.
Import of goods subject to export controls
EU undertakings importing goods into the United Kingdom subject to export controls shall be required to obtain an authorisation from the competent authority as from 1 January 2021. Find out about the regulations and take precautions to ensure that you have the correct permit.
Trade in wood
From 1 January 2021, you will need to carry out a due diligence check when importing and exporting timber.
Payment of VAT/Application for VAT refund
Ensure that you are adequately informed of the new rules on the payment of import VAT on goods you send to UK customers.
You must pay import VAT on packages you send to buyers in the UK, provided you:
have their registered office outside the United Kingdom
goods valued at £135 or less than packages to be sent to buyers in the UK
If you are shipping goods in excess of £135 as packages, the UK buyer will be required to pay VAT, customs duty (and, where applicable, excise duty) and collect them through the parcel service provider.
Find out how you can apply for a VAT refund on goods and services purchased from UK suppliers as of 1 January
Transfer of personal data to the United Kingdom
Your company will, if necessary. To be able to continue to transmit personal data to companies or other organisations based in the United Kingdom. Take appropriate measures with regard to data protection and data transmission.
Contact your local data protection authority to ensure that you are prepared for data protection and transfer.
Trade in services in the United Kingdom
The changes from 1 January 2021 may also affect your company, and new regulations may apply if:
You have a branch or subsidiary in the United Kingdom
Your company belongs to the services sector in the United Kingdom
You are planning to merge with a company based in the United Kingdom
You or your employees are travelling to the United Kingdom on business
You or your employees provide services in a profession regulated in the United Kingdom
Check the UK regulations, including visa requirements, and how changes may affect your company.
Members of legal professions
Legal professionals from the United Kingdom who work in the EU – either permanently or as needed – may be subject to restrictions on the rights to exercise their activities.
Legal professionals from the United Kingdom should obtain more detailed information from the competent authority on the spot on the rules applicable to lawyers from third countries in the respective EU Member State. Learn more about the regulations from 1 January 2021 for lawyers from the United Kingdom operating in the EU.
Business activities in the United Kingdom
From 1 January 2021, the free movement of persons between the United Kingdom and the EU shall cease.
Nationals of EU and EEA Member States and Switzerland who come to the United Kingdom for professional reasons may be required to apply for a visa in accordance with the United Kingdom’s point-based immigration system. This depends on the type of visit.
For visits under 6 months, nationals of EU and EEA countries and Switzerland can enter without a visa. They may engage in business-related activities, such as attending meetings, events and conferences.
Learn more about permitted business-related activities when visiting the UK under 6 months.
If you would like nationals of EU and EEA countries or Switzerland to work in the United Kingdom for more than 6 months, you will need to know under what circumstances this is possible under UK immigration legislation.
Learn more about British immigration legislation.
If you employ or would like to employ EU and EEA nationals or Switzerland who commute to the United Kingdom in the future, you must inform yourself about the rules for cross-border commuters.
Learn more about cross-border commuters working in the UK.
The new rules do not apply to Irish citizens under the single travel area (Common Travel Area) rules.
Copyright and unregistered designs
Changes to cross-border EU copyright laws can affect your company. Make sure that you have the right authorisations from 1 January 2021.
Find out about changes to the regulations from 1 January 2021.
Unregistered designs may not be protected if you do not disclose them correctly.
Inform yourself about the rules for the protection of unregistered designs in the United Kingdom and the EU from 1 January 2021.