EU Fulfilment for UK Companies After Brexit

Since 1 January 2021, every movement of goods between Great Britain and the European Union is an export on one side and an import on the other. For a UK company selling into Europe that means a customs declaration per consignment, duty exposure, import VAT and a delivery time that depends on a border. The response that most UK companies arrive at is to move stock into the EU once, hold it at a Dutch third party logistics provider and ship to European customers from inside the single market. This page covers what changed at the border, what the rules require of a company with no EU establishment, and what EU fulfilment for UK companies looks like in practice when the Netherlands is the entry point.

What changed at the border

Before Brexit, goods moved between the UK and the rest of the EU without customs formalities. Since the end of the transition period, each consignment needs an export declaration on the British side and an import declaration on the EU side. Both require an EORI number, and a GB EORI is not valid in the EU, so a second EU EORI is needed. Each declaration carries a commodity code, a declared customs value, a country of origin and, where a preference is claimed, a statement on origin.

The important point for anyone selling small orders is that most of this cost is fixed per consignment rather than proportional to the value of the goods. A declaration for a pallet of stock costs roughly what a declaration for a single parcel costs. Shipping one hundred orders individually from Great Britain therefore means one hundred clearances. Shipping one pallet into a Dutch warehouse and sending one hundred domestic parcels from there means one clearance.

Delivery terms decide who absorbs that. Under DAP the carrier presents the duty and import VAT to the consumer on the doorstep, which drives refusals and returns. Under DDP the seller carries it and needs a way to pay it. The Incoterms guide, the HS code guide and the guide to import duties and taxes cover the mechanics.

Rules of origin and when zero tariff does not apply

The Trade and Cooperation Agreement removes tariffs between the UK and the EU only for goods that meet the product specific rules of origin. Origin is not the same as the place the goods were shipped from. Goods manufactured in the UK from qualifying materials, or sufficiently processed there, are UK originating and enter the EU at zero duty against a statement on origin. Goods that a UK business bought in from outside the UK and passes on unchanged do not acquire UK origin by sitting in a British warehouse.

This is the single most common surprise for UK distributors and resellers. A company importing finished goods from Asia into Felixstowe, paying UK duty, then shipping to EU customers pays EU duty again on the same goods, because the consignment is a non-preferential import into the EU. Where that applies, holding the stock in the UK is the expensive step. The alternatives are to route the goods into the EU directly, to move them under transit so that duty is paid once at the EU destination, or to hold them in a customs warehouse until they are sold. Bonded warehousing and inward processing in the Netherlands covers the last of those.

The 150 euro threshold and the parcel duty from 1 July 2026

Two reliefs that made direct posting from Great Britain workable have been withdrawn.

The first went on 1 July 2021, when the EU abolished the import VAT exemption for consignments up to 22 euro. Import VAT has been due on every consignment entering the EU since that date, whatever it is worth.

The second went on 1 July 2026. Council Regulation (EU) 2026/382 of 11 February 2026 abolished the customs duty relief for consignments of negligible value and replaced it, until 1 July 2028, with a flat customs duty of 3 euro. The charge applies per item, which means per distinct tariff classification on the declaration, so a parcel holding five identical shirts pays 3 euro and a parcel holding a shirt and a watch pays 6 euro. It applies to all business to consumer distance sales of imported goods in consignments up to 150 euro, whatever VAT scheme is used, so Import One Stop Shop, the special arrangements and standard import VAT are all caught. The declarant owes it. Earlier reporting that described the charge as applying first to Import One Stop Shop flows reflected the Council position of 12 December 2025 and was overtaken by the adopted text.

A second charge follows. The Council approved the wider customs reform on 3 September 2026, which introduces an EU wide handling fee on small parcels for member states to apply by 1 November 2026. The Commission has not set the amount. Several member states already levy national handling fees alongside it, among them Italy at 2 euro per parcel and France at 2 euro per HS6 heading per parcel.

For a UK company posting orders individually into the EU, the per parcel cost now consists of a clearance charge, import VAT, and from July 2026 a duty that no longer disappears below a threshold. For the same company holding stock in the Netherlands, none of those apply to the outbound order, because the parcel never crosses a customs border.

Who can act as importer in the EU

A company established only in Great Britain cannot simply declare its own goods into free circulation in the EU. Article 170(2) of the Union Customs Code states that the declarant shall be established in the customs territory of the Union. Article 170(3) sets out the exceptions and they are narrow: declarations for transit or temporary admission, a person who lodges a declaration only occasionally where the customs authorities consider that justified, and persons established in a country adjacent to the customs territory that grants reciprocal treatment. None of those covers a regular flow of stock from Great Britain, so there are two workable routes around the rule.

The first is indirect representation. A customs agent lodges the declaration in its own name and becomes jointly liable with the seller for the duty and import VAT. Agents price that liability, and most ask for a guarantee, a deposit or both, so this route is cheap to start and carries a running cost that scales with import value.

The second is an EU establishment. A Dutch BV can act as declarant in its own name, hold its own EORI and its own licences, and remove the guarantee question from the arrangement. It is the normal answer once import volume is steady rather than occasional.

One distinction is worth stating plainly, because it causes trouble. A non-resident VAT registration in the Netherlands is not an establishment. It lets a foreign company report Dutch VAT. It does not make that company eligible to act as declarant, and it does not on its own give access to the import VAT deferment described below.

Import VAT and the Article 23 licence

Dutch import VAT at the standard rate of 21 percent is due when goods are released into free circulation. Under an Article 23 licence the amount is not paid at the border at all. It is reported on the periodic Dutch VAT return and deducted on the same return, so for a business with full recovery the net cash effect is zero. On a container of goods this is the difference between financing five figures of VAT for a quarter and financing nothing.

A company without a Dutch establishment cannot hold the licence directly and obtains the same treatment through a general fiscal representative, who holds an Article 23 licence and applies it to the represented company's imports. The full comparison of the two routes, including the requirements and what fiscal representatives charge, is in Article 23 and fiscal representation.

VAT on sales inside the EU

Once stock is held in the Netherlands, the customs question ends and a VAT question begins. A sale to a consumer in Germany is now an intra-EU distance sale rather than an import. Above the EU wide threshold of 10,000 euro in annual cross border B2C sales, VAT is due at the rate of the customer's country, and it is reported through the One Stop Shop on a single quarterly return instead of a registration in each member state. Sales to VAT registered business customers in other member states are zero rated intra-Community supplies.

The Import One Stop Shop stays relevant only for goods sent to EU consumers from outside the EU in consignments up to 150 euro, which is the model this whole exercise is designed to leave behind.

Holding stock in the Netherlands

The Netherlands is the default entry point for this pattern for reasons that are structural rather than promotional. Rotterdam is the largest seaport in Europe by cargo throughput and Schiphol carries a large share of European air cargo, so inbound options are wide and sailing and flight frequencies are high. Road connections put Germany, Belgium and northern France inside a day. The concentration of third party logistics providers is high enough that a mid sized brand can find several credible candidates for the same brief. Commercial English is standard in the sector, which matters when the operating contact sits in the UK.

A Dutch 3PL contract normally covers inbound receiving and put away, storage by pallet or by square metre, pick and pack, carrier selection and rate access, returns handling, and in many cases customs work through an in house or affiliated broker. Current rate ranges are in warehousing in the Netherlands, the operational detail is in the guide to e-commerce fulfilment in the Netherlands, and outbound rates are in transport costs in the Netherlands. For the shape of the supplier landscape, see the Dutch 3PL market overview.

Returns

Returns are the cost line that gets left out of the business case and then dominates it. A German consumer returning an item to a UK address creates an export from the EU and an import into Great Britain, with a declaration on each side. Returned Goods Relief can remove duty and import VAT where the goods come back in the same state within three years and the paperwork ties the return to the original export, and assembling that evidence per parcel is not realistic at consumer volumes.

A Dutch return address removes the problem rather than managing it. The item stays inside the EU, is inspected and restocked at the same warehouse that shipped it, and is available for resale immediately. On categories with return rates above 20 percent, this alone can justify the move.

Amazon and marketplace stock

Amazon stopped moving FBA inventory between the United Kingdom and the European Union on 1 January 2021. The European Fulfilment Network and Pan-European FBA operate on each side of the border but do not bridge it, so a UK seller with EU demand needs separate EU side inventory. The same applies in practice on the other large marketplaces.

The usual arrangement is a bulk import into the Netherlands, a buffer of stock at a 3PL, FBA replenishment shipments sent from that stock into the Amazon network, and own channel orders picked from the same pool. That keeps one EU inventory instead of one per channel, and it puts the customs event on the bulk movement rather than on the replenishment.

What it costs

The comparison that matters is the total cost of the direct model against the total cost of the EU stock model at your order volume. The lines are these.

The crossover point depends on order value and order count rather than on turnover. Low value, high frequency orders cross into the EU stock model early, because the fixed per consignment cost dominates. High value, low frequency B2B shipments can stay direct for a long time. For what real Dutch quotes contain and how far they differ on the same brief, see comparing 3PL quotes in the Netherlands.

Netherlands, Belgium, Germany or Ireland

The Netherlands is not the only option and is not right in every case.

Belgium is the closest substitute. Antwerp is a major port, the road network is the same network, and the ET 14000 licence performs the same function as Article 23. The Dutch advantage over Belgium is depth of supply in third party logistics rather than any regulatory difference.

Germany makes sense when Germany is the demand. It is the largest single consumer market in the EU, and placing stock there removes a leg for the majority of orders. Import VAT deferment is less favourable than the Dutch arrangement, so the customs saving moves in the other direction. See warehousing in Germany.

Ireland suits companies that value a shared language and time zone, and companies shipping goods that would otherwise cross the UK land bridge. The trade off is that onward distribution to continental Europe adds a sea leg and time. See warehousing in Ireland.

The wider comparison across European locations, including cost per square metre and labour availability, is in the best warehousing locations in Europe and the guide to European e-commerce fulfilment.

Setting it up

The sequence that works, in order, is this. Apply for an EU EORI number. Decide between indirect representation and a Dutch entity, on expected import value rather than on turnover. Appoint a general fiscal representative and put the Article 23 arrangement in place, since the 3PL cannot do this and will assume it is handled. Register for the One Stop Shop for B2C sales. Select the 3PL and agree the rate card, the systems integration and the returns process. Agree Incoterms with the suppliers who will now deliver into the Netherlands instead of into the UK. Then run the first import, with a small shipment rather than a full container, and confirm that the declaration, the deferment and the warehouse receipt all behave as expected before the volume follows.

Lead time from decision to first outbound order is usually six to ten weeks, and the fiscal representation and Article 23 steps are the ones that set the pace.

Request quotes

Describe the goods, the volumes and the destinations and Zendeq puts the brief in front of Dutch providers that handle this work. Quotes come back from several parties on the same brief, so they can be compared line by line.