A Maker's Guide to the EU Exit (Brexit) 2021

Products & services to EU customers 

The UK Government has created step-by-step guidance on exporting goods to the EU and importing goods from the EU, and on moving goods into, out of, or through Northern Ireland from 1 January 2021. 

You can find guidance from the Department for International Trade on processes for importing and exporting goods on a dedicated collection page. Use this collection page to find out about new tariff, check if the UK has negotiated a trade agreement with the country you trade with, and which commodity code to classify your goods under. Visit gov.uk for the complete collection and to access these tools. 

You may also need to register for an Economic Operators Registration and Identification number (EORI number), if you move goods between: 

• Great Britain (England, Scotland and Wales) or the Isle of Man and any other country (including the EU) 

• Great Britain and Northern Ireland 

• Great Britain and the Channel Islands 

• Northern Ireland and countries outside the EU  

Learn more about how to get an EORI number on gov.uk. 

The UK Government has made available a range of webinars to learn more about how to prepare your business for Brexit.  

If you have any questions about preparing for the end of the transition period and you can’t find answers at gov.uk/transition, fill out the enquiry form to get in touch directly with one of the Department for International Trade experts.  

E-Commerce and selling online 

The eCommerce Directive is no longer in place in the UK. The directive allows European Economic Area (EEA) online service providers to operate in any EEA country, while only following relevant rules in the country in which they are established.  

The UK Government advises that you review whether your services were previously in scope of the Directive, and if so, ensure that you are compliant with relevant requirements in each EEA country you operate in. Find more information about changes to the eCommerce directive on gov.uk. 

The EU’s e-commerce package has also introduced changes in respect of the movement of goods from Northern Ireland to the EU and imports of low value goods into the EU or Northern Ireland, effective from 1 July 2021.  

Goods are low value where they are in consignments with an intrinsic value not exceeding £135 (€150). The intrinsic value is the price the goods were sold at, excluding postage and packaging charges. Consignment is an arrangement in which goods are left with a third party to sell. 

There are four selling options which the EU e-commerce package changes impacts: 

• Distance selling: The current thresholds will be replaced with a single pan-European threshold of €10,000 (£8,818). This threshold will apply to the total cross-border sales by the business across the EU and not, as at present, on a country-by-country basis. To ease the administrative burden of businesses, there will be a new opt-in online One Stop Shop (OSS) quarterly VAT reporting and payment system. 

• Imports: The changes apply to goods imported into the EU and Northern Ireland in consignments not exceeding an intrinsic value of £135 (€150). From 1 July 2021, all commercial goods imported into the EU from a third country or third territory is subject to VAT, irrespective of their value. A new scheme called the “Import One Stop Shop” (IOSS) will allow businesses based in Great Britain (Wales, England and Scotland) to register with just one of the EU tax authorities and submit a quarterly IOSS VAT return.  

Great Britain businesses that are not VAT registered in the UK but are registered for IOSS will also be able to tell HMRC their IOSS registration number prior to the goods moving to Northern Ireland but will not be required to charge VAT on supplies to customers in Northern Ireland. Great Britain businesses not registered for IOSS should continue to use the existing VAT treatment for supplies of goods to Northern Ireland. 

• Online marketplaces and imports: Changes also affect online marketplaces (OMP) importing goods into the EU and Northern Ireland. An OMP that is registered for the IOSS will be liable to account for the supply VAT on imports of low value goods into the EU and Northern Ireland under the schemes rules. For imports into Northern Ireland, where the OMP has not opted to register for IOSS, import VAT will continue to be collected in the same way as it is now. 

If you are drop shipping goods through a third-party marketplace selling to the EU or Northern Ireland, check with the relevant marketplace to ensure you comply with changes to the movement of goods within the EU.  

• Online marketplaces and supplies within the EU: OMPs will be liable to account for the supply VAT on goods located within the EU or Northern Ireland when they sell these goods on behalf of overseas sellers located outside of the EU and Northern Ireland. The online marketplace liability will also apply in relation to Great Britain businesses that make sales of goods located in Northern Ireland at the point of sale for delivery to EU customers, but not customers in Northern Ireland. 

Scottish Enterprise has compiled new legislations and information about exporting and selling to the EU after Brexit in a resource hub with step-by-step guidance.  

You can also get in touch with Scottish Enterprise experts for the latest on the UK's exit from the EU, its impact on Scottish businesses, and more on how they can help you navigate the changes facing all companies. Submit an enquiry via their website or call 0300 303 0661 (Mon-Fri 8.30am to 5.30pm).

Selling/Showcasing in and out of the EU 

The UK Government has published guidance on planning business travel to the EU after Brexit, and you can access regularly updated travel advice for each country. The Trader Support Service describes the new regulations between UK and Northern Ireland from 1 January 2021. 

New rules will apply to carry goods temporarily outside of the UK. If you are planning to travel for a trade show or carry samples abroad, you can now check that you have the required documentation to take goods into the EU, a list of customs agents and transporters, and advice on appointing agents. 

Royal Mail have published a Brexit information hub on their website to help you stay up to date with the latest changes and requirements with sending items abroad and to the EU.  

Other resources and additional links 

• Financial Conduct Authority’s Brexit information hub 

• Royal Bank of Scotland: Brexit Key Information for Business  

• Deloitte IOSS VAT for e-commerce sellers 

• UKFT’s brexit toolkit (for members only)  

• Crafts Council: How to make changes to your craft business as UK leaves EU 

• Moneycorp & Elizabeth Anderson: Beyond Brexit whitepaper 

• Article: Shipping goods into EU after 1 July 2021: VAT will not make it easier by Aleksandra Bal, Indirect Tax Technology & Operations Lead at Stripe, on LinkedIn 

In December 2020, Craft Scotland held a COMPASS webinar on the EU-UK transition period with Kevin Shakespeare, Director of Stakeholder Engagement at the Institute of Export & International Trade. The presentation slides are still available, email us at hello@craftscotland.org.