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Brexit fundamentally changed the rules of trade between Poland and the UK. What before 2021 was a simple intra-EU transaction without duties and customs formalities has now become a complex operation requiring knowledge of customs, tax and regulatory regulations. Post-Brexit trade specialists help Polish companies navigate the new trading reality smoothly. This guide explains all the key changes.

Timeline of Brexit and its impact on trade

Key dates in Brexit history:

• 23 June 2016 — Brexit referendum: 51.9% votes in favour of leaving the EU
• 31 January 2020 — UK’s official departure from the EU
• 1 February 2020 – 31 December 2020 — Transition period: UK formally outside the EU, but single market rules applied
• 24 December 2020 — Signature of the Trade and Cooperation Agreement (TCA)
• 1 January 2021 — Full Brexit entry into force: end of free movement of goods
• 1 May 2021 — Formal ratification of TCA by the European Parliament
• 2024 — UK implements full border controls for goods from the EU (BTOM)

What is the TCA and what does it guarantee?

The Trade and Cooperation Agreement (TCA) is the foundation of current EU–UK trade relations. TCA provides:

• Zero tariffs — for goods meeting rules of origin (preferential origin)
• No import quotas — no quantitative restrictions for goods meeting rules of origin
• Mutual recognition of certain standards — although in a narrower scope than in the EU

TCA does NOT provide:

• Absence of customs clearance — every shipment requires customs formalities
• Free movement of persons — EU citizens need a work visa in the UK
• Mutual recognition of professional qualifications (in full)
• Free access to the financial services market (financial passport)

The full text of the TCA is available on EUR-Lex. Customs clearance platform adapted to post-Brexit requirements handles both import and export under the TCA.

Rules of origin — the key to zero tariffs

Zero tariffs under the TCA apply only to goods that meet the rules of origin. This means the product must be sufficiently processed in the UK or EU to “acquire” preferential origin. The rules vary depending on the product category:

• Wholly obtained — e.g. agricultural products, fish caught under EU/UK flag
• Sufficiently processed — e.g. change of tariff position (CTH), value added threshold (RVC), specific manufacturing processes

Example: a telephone produced in Poland from Chinese components may NOT meet the TCA rules of origin if the tariff change is not sufficient. In such a case, when imported to the UK, it is subject to standard duty.

Evidence of preferential origin is:

• Exporter declaration on invoice (Statement on Origin) — for registered exporters (REX)
• Importer’s Knowledge statement — when the importer can document the origin himself

New customs obligations when exporting from Poland to UK

Any company exporting goods from Poland to the UK must now:

1. File an export customs declaration with the Polish customs office (AES/ECS system)
2. Obtain an EORI number (Economic Operators Registration and Identification) — identification number in the EU for entities participating in trade with third countries
3. Issue a commercial invoice with correct data (including CN codes, customs value, delivery terms)
4. Attach documents confirming origin (if applying for zero TCA tariff)
5. Comply with labelling requirements applicable in the UK

New obligations when importing from UK to Poland

When importing from the UK to Poland, the following is necessary:

1. Filing an import customs declaration — SAD/MRN with the Polish customs and tax office
2. Payment of import duty (0% if TCA rules are met or standard TARIC rates)
3. Payment of import VAT — 23% of the base (customs value + duty)
4. Possible excise duty — for excisable products (alcohol, tobacco, fuel, vehicles)
5. Compliance with regulatory requirements — CE certificates, safety standards, homologations (UK now has its own UKCA marking)

UKCA marking vs CE — change in technical requirements

One of the less well-known post-Brexit changes is the replacement of CE marking with UKCA (UK Conformity Assessed) for products sold on the UK market. UKCA has been required since 1 January 2023 for most technical products and devices. Polish companies exporting to the UK must take into account the costs of UKCA certification in their calculations.

Need help? Contact Plutos Team — licensed UK customs brokers.