EU, UK and Middle East import compliance essentials

1. Decide who the importer is

This is the starting point for every tax and document question.

2. EORI

• What it determines: whose EORI appears in the importer box decides who owns the import documents and the right to reclaim VAT.
• UK: a GB EORI is issued by HMRC and must be linked to your UK VAT number for PVA.
• EU: an EU EORI is issued by the member state of first declaration and is valid EU-wide; a Hong Kong company usually applies as a non-EU-established entity and is cleared under indirect representation.

3. UK VAT and postponed VAT accounting

• The standard rate is 20%. Importing under your own UK VAT entity, you may use PVA: import VAT is not paid at the border but declared and reclaimed on the same VAT return.
• Only the importer named on the declaration (the owner of the goods) can use PVA; cleared under a forwarder’s EORI, neither PVA nor a C79 arises in your name.
• Consignments sold to UK consumers valued at £135 or less generally have VAT charged at the point of sale (by the marketplace when sold through one) rather than at import.

4. EU VAT, IOSS and low-value consignments

• Germany’s standard rate is 19%, France’s 20%. For own-account imports some member states offer import VAT deferral or deferment accounts, each with its own conditions.
• IOSS: B2C distance sales to EU consumers valued at €150 or less per consignment can use IOSS, with VAT collected at checkout and one monthly return; marketplaces are usually the deemed supplier.
• The duty exemption and flat handling fee for low-value consignments are under reform, with rules that differ by phase; check the latest European Commission and national customs notices before shipping.

5. Product safety and markings

• GPSR: the EU General Product Safety Regulation applies to consumer products sold in the EU and requires an EU-based responsible person whose name, address and contact details appear on the product, packaging or accompanying documents; customs may suspend release where details are missing.
• CE and UKCA: products under harmonised legislation need CE marking and a declaration of conformity; the UK continues to recognise CE for most categories, with UKCA needed for some.
• Battery products: classified by packing instruction for the mode used, with a UN38.3 test summary and MSDS; labelling and registration duties under the EU Batteries Regulation apply progressively by category.

6. Extended producer responsibility

• Germany: the Packaging Act requires LUCID registration and a contract with a recovery scheme; electrical goods need WEEE registration; batteries fall under the Battery Act. Amazon checks the numbers and restricts listings without them.
• France: packaging, electrical goods, textiles and other categories each have an EPR scheme with a unique identification number.
• UK: packaging EPR mainly targets UK-established producers; overseas sellers via marketplaces follow the platform’s requirements.

7. CBAM and ICS2

• CBAM: the EU Carbon Border Adjustment Mechanism is in its definitive period, covering iron and steel, aluminium, cement, fertilisers, electricity, hydrogen and the products listed in its annex; imports under those tariff lines must be declared by an authorised CBAM declarant unless annual volumes fall below the exemption threshold. Check the tariff lines before shipping.
• ICS2: an entry summary declaration (ENS) must be lodged before goods enter the EU, with deadlines that vary by mode; descriptions must be specific and should include 6-digit HS codes and buyer and seller details. The carrier or we file within the deadline; you only need to ensure the data is accurate.

8. Middle East (Gulf states) essentials

Shipping to the UAE and Saudi Arabia follows different rules from the EU; the essentials are the tariff basis, conformity certificates and document attestation.

• Duty and VAT: most goods attract the GCC common tariff of 5%, with higher rates on some categories in Saudi Arabia; VAT is 5% in the UAE and 15% in Saudi Arabia, generally on a CIF customs value.
• Saudi SABER: regulated products need a Product Certificate of Conformity (PCoC) and each consignment a Shipment Certificate of Conformity (SCoC) before customs release; check by HS code before dispatch whether a product is regulated.
• UAE: regulated products are certified under ECAS/EQM schemes; the importer must hold a customs importer code, which under DDP is provided on our side.
• Documents: certificates of origin and commercial invoices are routinely required, with chamber or consular attestation in some countries; labels must be in Arabic, and food needs halal certification.
• Marketplaces: Amazon.ae, Amazon.sa and noon have their own inbound requirements; labels and cartons are checked against each platform.

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