[Home](/)/[Resources](/resources)/Selling to UK from EU EU to UKPost-BrexitMarket Access # Selling to the UK from the EU After Brexit: Import, Compliance, and Market Access Brexit created a hard border between the EU and Great Britain. For EU companies selling physical products to UK customers, this means customs declarations, import VAT, UK product safety obligations, and UK-specific requirements like PSTI that have no EU equivalent. The good news: CE marking is accepted in GB, so product re-testing is rarely needed. The complexity is in the operational and administrative setup. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fuk-selling-from-eu) ## What changed after Brexit for EU sellers ### Customs duty and import VAT Before Brexit Free movement — no customs formalities for goods moving between EU and UK After Brexit Full customs declarations required. UK Global Trade Tariff rates apply (most electronics 0% under ITA). Import VAT at 20% applies — UK VAT-registered businesses can reclaim. ### Product compliance marking Before Brexit CE marking valid for both EU and UK markets as a single mark After Brexit CE marking continues to be accepted in Great Britain (indefinitely for most product categories). No urgent need to add UKCA marking for CE-marked products, but a UK Declaration of Conformity referencing UK regulations is best practice. ### UK Responsible Person (UKRP) Before Brexit EU Authorised Representative (EU AR) satisfied regulatory contact requirements for UK and EU After Brexit Non-UK manufacturers must appoint a UK Responsible Person with a UK address for regulated products (medical devices, MHRA-regulated products, certain others). EU AR does not satisfy UKRP requirement. ### UK VAT Before Brexit EU VAT rules; distance selling VAT thresholds applied After Brexit For B2C sales above £135 per shipment: customs VAT at import. For B2C below £135: UK VAT must be collected at point of sale. UK VAT registration required in many cases. ### PSTI cybersecurity (new, no EU equivalent) Before Brexit No equivalent obligation in the EU After Brexit Consumer connectable products sold to UK consumers must comply with PSTI Act minimum security requirements. Statement of Compliance required. CE marking provides no PSTI exemption — this is a UK-only obligation. ## Practical setup steps for EU sellers 01 ### Review your product's UK compliance status Determine whether your CE marking is accepted in GB (it is for most product categories). Check whether UK-specific obligations apply: UKRP appointment, PSTI, MHRA registration for medical devices, UK WEEE producer registration. 02 ### Appoint a UK Responsible Person if required For medical devices and certain other regulated products, non-UK manufacturers must appoint a UKRP with a physical UK establishment. The UKRP must register with MHRA (for medical devices) and be contactable by OPSS. 03 ### Register for UK VAT If you sell B2C direct to UK consumers above the applicable thresholds, or if you are the importer of record for goods imported into the UK for UK sale, you may need to register for UK VAT with HMRC. 04 ### Appoint a UK customs agent or freight forwarder You need a UK customs agent to file import declarations. Decide who will be the importer of record: the EU company (non-UK importer), your UK distributor, or your UK consumer (the latter is typically impractical for B2B). The importer of record is liable for customs duty and import VAT. 05 ### Issue PSTI Statement of Compliance for connected products For any consumer connectable product, issue a UK PSTI Statement of Compliance. This is a UK-specific document with no EU equivalent — it must be accessible to UK consumers and OPSS. ## Learn this properly, not just for one product In-depth courses and books that teach the process — not a one-off answer you'll need to look up again next time. [Start the course — $149](/courses/09-ukca-marking-for-electronics-products)See your free roadmap [Prefer to read? Get the book — $24.99](/books/09-ukca-marking-for-electronics-products) ## Frequently asked questions ### Can I use my EU Authorised Representative to satisfy UK Responsible Person requirements? No. The UK Responsible Person must be established in the United Kingdom — an EU-based Authorised Representative does not satisfy the UK requirement. The UK Responsible Person role is legally distinct from the EU AR role. For medical devices and other products where a UKRP is mandatory, you must appoint a separate UK entity. Some companies appoint their UK distributor as their UKRP, which requires a specific contractual arrangement covering the regulatory obligations. ### Do I need to re-test my products for the UK market if they are already CE-marked? Generally no — if your CE test reports are against standards that are also GB-designated standards (which most EN standards are), the same test reports support both CE and UKCA compliance. You do not need to repeat testing solely because of Brexit. However, you should verify that the specific standards you used for CE marking appear on the current GB-designated standards list and that there have been no standard updates since your original testing that affect compliance. ### How does UK customs work for dropshipping from an EU warehouse to UK consumers? Goods moving from an EU warehouse to UK consumers are imports into the UK and require customs declarations. For consignments below £135: the seller typically collects UK VAT at point of sale and registers for UK VAT (or uses the UK's Overseas VAT Seller scheme). For consignments above £135: import VAT and any applicable customs duty is assessed at the UK border. The consumer may be asked to pay import costs on delivery if the seller is not the importer of record. Most EU-to-UK dropship operations use a UK customs agent to handle declarations. 🇬🇧 UK roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇬🇧 UK compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/09-ukca-marking-for-electronics-products)[Prefer to read? Get the book — $24.99](/books/09-ukca-marking-for-electronics-products) Related guides * [CE to UKCA Transition GuideStep-by-step guide to transitioning from CE marking to UKCA marking for the Great Britain market: what changes, what stays the …](/guides/ce-to-ukca-transition) * [UK Approved Body vs EU Notified BodyComplete guide to UK Approved Bodies vs EU Notified Bodies: what changed after Brexit, which products require third-party asses…](/guides/uk-approved-body-vs-notified-body) * [UK Global Trade TariffComplete guide to the UK Global Trade Tariff (UKGT) for electronics and hardware: how tariff rates work, key commodity codes fo…](/guides/uk-global-trade-tariff) * [UK Rules of OriginComplete guide to UK rules of origin for claiming preferential tariff rates: how wholly obtained and sufficient processing test…](/guides/uk-rules-of-origin) * [UK Product Labeling RequirementsComplete guide to UK mandatory product labeling requirements: UKCA marking placement, UK Responsible Person address, language r…](/guides/uk-product-labeling-requirements) * [Selling EU Appliances in the GB MarketWhat changes when EU-certified electrical appliances enter the GB market: UKCA marking, BS 1363 plug requirements, the UK Responsible Person role, ecodesign and energy labelling, and how the transitional arrangements were resolved.](/guides/uk-eu-appliances-gb-market) Educational resource only. UK customs, VAT, and product compliance requirements evolve. Always verify current requirements and consult a qualified customs broker and compliance consultant for your specific product.