Doing business with the UK
- Marco van Hagen
- The basis
- 3 Feb 2020
- Edited 11 Oct 2023
- 10 min
- Managing and growing
The British are proud of products from their own country. But they also have an eye for innovative and high-quality Dutch products and services. Since the UK's departure from the EU, different rules apply to doing business with the UK. For example, there are more customs obligations. Good preparation prevents delays at the border. Find out what this means for you.
Importers and exporters doing business with the UK are subject to customs obligations such as import and export declarations, inspections, export certificates, and export documents. In this article, you can read more about the business opportunities that the UK has to offer, and how to comply with regulations when importing and exporting goods and services.
The current situation when doing business with the UK
New UK customs rules
In August 2023, the British government presented a new version of the Border Target Operating Model (BTOM). This set of rules include checks on goods entering the United Kingdom. The model will be implemented in multiple stages. These rules also apply to Dutch exporters.
Starting 31 January 2024, exporters will be required to obtain health certificates for the shipment of animal, plant, and plant-based products. Your clients need these from you to import into the UK. This law only applies to products that are known to have a medium to high risk for the health of humans, animals, and nature. Examples of relevant products:
- Fresh, cooled, or frozen meat or meat products.
- Animal food that contains animal products.
- Sea animals and fish products.
- Other goods that contain animal products.
This website of the British lists which animals and animal products have a medium or high risk. The UK Department for Environment Food & Rural (DEFRA) has an overview of plants and plant products and their risk level.
The next stage will start on 30 April 2024. From then on, British customs will also physically check the products. To do so, the British government will install so-called Border Control Posts (BCP). You can find the locations of these BCPs in ‘Annex F’ of the BTOM.
The final stage will start on 31 October 2024. From then on, a declaration to UK customs will apply to all import shipments from the EU. This is called a Safety and Security declaration. Your carrier will take care of this declaration for you. But they will need information from you to do so. For instance, a copy of the health certificate. This can be a scan in the form of a PDF file.
Northern Ireland and UK border
On 27 February 2023, the European Commission and the UK reached an agreement on a new version of the Northern Ireland Protocol. This agreement is called the Windsor . Not much changes for Dutch importers and exporters. Northern Ireland still follows EU rules. And you still do not have to make a customs declaration for trade with Northern Ireland.
There is a change for the delivery of goods between Northern Ireland and the rest of the UK. There will be a so-called 'green lane' for this. Goods from Northern Ireland to the UK are not subject to a customs declaration. Nor vice versa, if documents clearly show that the (final) destination of the goods is Northern Ireland. For example, food supplies going from the UK to supermarkets in Northern Ireland. Are UK goods destined for countries outside Northern Ireland, such as the Republic of Ireland? If so, an import declaration in Northern Ireland does apply.
Trade and opportunities
The United Kingdom is in the top 5 Dutch export destinations. In the UK – which consists of England, Scotland, Wales and Northern Ireland – opportunities lie mainly in renewable energy, high-tech systems and materials, sustainable mobility, life sciences & health, and agri-food. RVO tells you more about promising industries (in Dutch).
Dutch goods exports to the UK rose to €49 billion in 2022. An increase of 23.7%, EU figures . In addition, Dutch importers sourced over €42 billion worth of goods from the UK in 2022. An increase of 67% compared to 2021
The RVO scheme Support International Business reimburses part of the costs you incur if you want to start doing business with a new export country. Think of participating in trade missions or trade fairs and using an external coach.
Brits are naturally cautious. So take the time to build and maintain your network. It is easier to do business when you hire a UK salesperson. Or appoint a commercial agent or distributor. Commercial agents have a protected position in the UK. The British trade association MAA has data from British commercial agents. MMA charges a fee for this and you need an account if you want to search.
Finding the right buyers or suppliers takes time. A visit to a local trade fair provides quick insight into the market. There you can make your first contacts and build a network. In addition to physical participation in a trade fair, there are alternatives, such as digital trade missions. RVO offers more information about trade missions (in Dutch). An overview of trade fairs and exhibitions in the UK can be found at Exhibitions.co.uk and AUMA Trade Fair-database.
Various organisations help you search for possible business partners. Sometimes you pay a fee for this service.
- RVO’s Zakenpartnersupport Op Maat (in Dutch) helps you find reliable foreign business partners. RVO helps you with an initial introduction.
- Enterprise Europe Network (EEN) is a professional network of 600 organisations in more than 60 countries, including the UK. The digital database of EEN contains profiles of companies from the UK that are looking for cooperation partners.
- NL Business Hubs offers Dutch companies operational support when entering a foreign market and opening up a business and social network of local contacts. Read how the NBCC NL Business Hub helped the Dutch company Tony's Chocolonely get started on the British market.
There are often hierarchical layers in British business. Brits may have a hard time admitting it but need permission from 'higher up' for everything. The boss decides. Brits take their time before concluding a business agreement.
Just like the Dutch, no Brit is the same. But British people are generally known for being formal and polite. Think of a queue of Brits waiting at a bus stop.
Most Brits are neat and punctual. Especially at the first appointment. Familiarise yourself with the local road and public transport network, as travelling in the UK takes time. And let them know if you will arrive later than the agreed time.
Speak the language
Even when you think you have a good command of the English language, it is easy to make mistakes. Have a native speaker write or check all correspondence, marketing communications, and content on your website. Read more do's and don'ts (in Dutch) of doing business with the UK.
Prepayment offers the most security. Your business partner will agree with this. If not, there are also alternative payment methods. Ask your bank which payment method and currency (in Dutch) best suits the transaction. Also, ask what to pay attention to when it comes to payment habits and payment behaviour in the UK.
The article securing financing for working capital informs you about borrowing money to keep your day-to-day business running smoothly.
Record contracts in writing
The British do not have a Commercial Code that can be referred to. They therefore put everything in contracts. In the UK, for example, they do not have terms such as 'good faith' and 'reasonableness and fairness'. Because all agreements are in the contract, British contracts are often longer than Dutch contracts. The British court is based on the concluded agreement. Only when you can explain a part of the contract in more ways than one, do the British courts sometimes take circumstances into account.
Agree on an Incoterm® and include it in your quote or contract. Then you know who is responsible for transporting the goods and the associated costs. Incoterms® also regulate who is at risk if goods are damaged or lost during transport. Get legal help when drafting or checking an agreement.
Export to the UK
The order is closed and you are exporting your product to the UK. In addition to an invoice, transport document, export declaration, and packing list, you sometimes need additional export documents. British customs do not levy import duties on goods of preferential origin from the EU. This means that goods are manufactured or have undergone a certain amount of processing in the EU. If you supply products of preferential origin to your customer, put an invoice statement, or Certificate of Origin, on your sales invoice.
Because the goods leave the EU, you submit an export declaration to Dutch Customs. An import declaration is made at British customs. Your customer is usually responsible for this import declaration. If you agree on Incoterm® DDP with your customer, you must arrange this in the UK.
- Request an EORI number and include this number in your customs declaration for export outside the EU.
- Choose if you will do the customs declaration yourself or outsource this to a Dutch forwarder or carrier.
- You can use a customs agent or parcel operator for declarations to British customs.
For exports of products of animal origin, you announce this in advance in the UK government’s IPAFFS system. These are products such as meat, dairy, and fish. Prior notification also applies to plants and cut flowers. IPAFFS stands for the import of products, animals, foods and feed system.
The UK has one of the most developed e-commerce markets in the world. Do you want to deliver products to British individuals from your webshop or via platforms such as Etsy, Amazon or eBay? In the article e-commerce in the United Kingdom, you can read how to approach this and which rules apply.
VAT on export
With export, you invoice 0% Dutch VAT to your UK customer. You must demonstrate in your records that the goods have left the EU. For example via an export declaration, transport documents, and payment receipts.
Exports to Northern Ireland
Northern Ireland has a separate status within the UK. Shipments to Northern Ireland are subject to the European VAT system. Customs declaration is not necessary.
Import from the UK
For goods that you import from the UK into the Netherlands, you submit an import declaration to Dutch Customs. After this, you pay VAT and import duties on the value of the goods, the customs value. The EU and the UK have a trade agreement. Despite this trade agreement, you still pay import duties for some goods.
The UK is not an EU country. If you import goods, you also pay handling costs in addition to any import duties. This includes costs for making the import declaration, inspections on goods of animal origin and plant products, longer storage, and administrative actions. This also includes the costs of pre-notification of the import shipment in Portbase by the forwarder, importer or carrier. A large number of terminals make this pre-registration mandatory.
Your carrier may work with a 'Brexit surcharge'. Customs clearance and handling costs incurred by your carrier or parcel deliverer are charged to you. These costs differ per carrier. Compare different quotes from carriers and save costs. Who pays the costs for customs clearance and handling depends on the Incoterm® that you agree with your UK supplier.
Imports from Northern Ireland
Northern Ireland has a separate status within the UK. For shipments from Northern Ireland, the European VAT system applies. An import declaration to Dutch Customs is not necessary if you import goods directly from Northern Ireland.
Pre-register via Portbase
If you transport via ferry or shortsea terminals, then submit a digital pre-notification of the customs documents via Portbase. Agree who will do this: you, your UK business partner, freight forwarder, customs agent or the carrier. Without a pre-notification, a carrier will not be allowed access to the terminal. You take out a subscription with Portbase for the following services: Import pre-notify, Pre-notify export, and Track & Trace Export.
Check both the UK and European legislation when you export or import. Perhaps a product in the UK has to comply with different regulations than in the EU. A sales ban may apply to products that do not comply with the regulations.
When exporting a product to the UK, your product must meet the product requirements. Sometimes you need a health certificate or export licence. National norms or standards ensure that products in a country meet, for example, requirements for safety. In the UK, product safety is governed by the Consumer Protection Act. RVO provides information (in Dutch) about product groups, associated product requirements and the correct certificate. Make sure you know who is liable if a product turns out to be unsafe. You risk high claims if damage occurs and product liability rests with you.
UK Conformity Assessed
UK Conformity Assessed (UKCA) applies to certain products. The rules are similar to the European CE marking. It applies to products such as toys, machinery, and safety glasses. From 1 January 2025, you will be required to apply the UKCA marking to these types of products if you export them to the UK. Until then, a CE marking will suffice.
When you import, you as an importer are responsible for the safety and quality of a product. An imported product from the UK must meet European and Dutch product requirements.
Working in the UK
Are you temporarily working in the UK or starting a business in the UK? Then check the rules, because the UK is not an EU country. Entrepreneurs performing temporary work in the UK do not have free market access in the UK. For example, when you start working as a self-employed professional in the UK. Or when your employees are going to install or maintain a machine in the UK. Specific rules apply when you go to the UK with goods in your (in Dutch).
Open your own location in the UK
If you get a large part of your total turnover from the UK, consider if having your own branch in the UK is interesting. The UK government has a roadmap for setting up a business in the UK.
When you start a private limited company, you register with Companies House. If you start as a sole trader or general partnership, you do not need to register. You register with 'Her Majesty's Revenue and Customs' (HMRC) and you must comply with rules about the use of a company name.
The UK has an advantageous and at the same time complex tax system. There are many rates and deductions. The World Bank has an overview of UK tax rates. Ask your accountant or a tax advisor for information.