Buying goods from the EU into Great Britain is now an import — England, Scotland and Wales, with Northern Ireland on a different footing that the last section covers. That single sentence contains most of what changed: the acquisition rules that used to move goods between member states without a border have gone, and a consignment arriving from Rotterdam is treated exactly as one arriving from Shanghai — customs declaration, duty where it applies, and import VAT at the UK rate.
What replaced the old system
Before, a VAT-registered business buying from an EU supplier gave its VAT number, received an invoice without VAT, and accounted for acquisition VAT on its return with a simultaneous deduction. No cash moved and no declaration was needed.
Now the same purchase requires a GB EORI number, an import declaration, a commodity code, a customs value and evidence of origin. Import VAT is charged at the rate the goods would attract domestically — so importing books or children's clothing attracts no import VAT, because they are zero rated in the UK.
The cash flow problem this creates is solved by postponed VAT accounting: instead of paying import VAT at the border and recovering it later, the business declares it as output tax and reclaims it as input tax on the same return. No application is needed — it is elected on the declaration — and the figures come from the monthly postponed import VAT statement rather than the C79. Any business importing regularly and not using it is financing HMRC for no reason.
Duty is a separate question from VAT
The UK–EU trade agreement means most goods can move at nil duty, but only where they meet the rules of origin. Origin is not where the goods were shipped from; it is where they were produced or last substantially transformed. Goods made in China, warehoused in Belgium and shipped to the UK are Chinese for origin purposes and attract the full tariff.
Claiming preference requires evidence — a statement on origin from the exporter or the importer's own knowledge — and the importer carries the liability if the claim is wrong. This is the most common post-Brexit assessment we see: preference claimed as a matter of habit on goods that never qualified, discovered on audit, and assessed for three or four years of duty with interest.
Incoterms decide who is the importer
The term agreed with the supplier determines who clears the goods and who can recover the import VAT — and getting it wrong is the most expensive administrative error in the whole process.
Under DDP (delivered duty paid) the supplier is responsible for import, which can leave the overseas supplier as importer of record. The UK customer then receives goods with no import VAT certificate in its name and no right to recover the VAT, because it was not the importer. Under DAP or ex-works terms the UK buyer imports, holds the evidence and recovers normally.
The related trap is owning the goods. Import VAT is recoverable by the owner at the time of importation. Businesses importing goods they do not own — processing them for an overseas principal, or receiving consignment stock — frequently reclaim VAT they were never entitled to.
Northern Ireland is genuinely different
Under the Windsor Framework, Northern Ireland continues to apply EU VAT rules for goods. Movements between Northern Ireland and the EU remain acquisitions and dispatches rather than imports and exports; movements between Great Britain and Northern Ireland have their own arrangements, with the UK Internal Market Scheme and the green and red lane distinction determining what checks and duties apply. Businesses trading in both directions need an XI EORI alongside their GB one.
This is the part of the system that changes most often, and any business with a Northern Ireland leg should check the current position rather than relying on how it worked at the last review.
Selling the other way, and to consumers
Exports of goods from the UK are zero rated, provided the goods physically leave and the exporter holds evidence of removal within the time limits. "We invoiced an overseas customer" is not evidence; the proof of export is.
Selling to EU consumers brings the destination country's VAT into play, generally from the first sale, with the EU's Import One Stop Shop available for consignments under €150 — a single registration covering sales across the bloc instead of registering in each member state. Below-threshold consignments still require customs formalities, and marketplaces frequently become the deemed supplier for VAT on goods they facilitate.
The practical checklist
Hold a GB EORI; classify goods deliberately and document the reasoning; test origin before claiming preference and keep the supplier statements; agree incoterms that leave you as importer of record; elect postponed VAT accounting on every declaration and reconcile the monthly statements to the return; and confirm your right to recover by reference to ownership, not delivery. Then review annually, because tariffs, origin rules and the Northern Ireland arrangements all move.
Acumon advises on cross-border VAT and the recovery position through international VAT and VAT compliance work, and covers the customs sequence in our guide to importing goods into the UK. If you are claiming tariff preference on EU purchases without holding origin statements, that is the exposure to quantify first.