EU Brand Selling in UK After Brexit

Updated September 2026

An EU brand selling in the UK after Brexit needs a UK VAT registration, a GB EORI number, a UK Importer of Record, product compliance documentation, and either a UK entity or a Merchant of Record to act as the legal seller. Without these five pieces, you cannot list products on TikTok Shop UK or any other UK marketplace. The fastest route is through a licensed MoR, which bundles all five requirements into a single onboarding that takes 7 to 10 business days.

TL;DR

• Since 1 January 2021, Great Britain is a third country for VAT and customs. EU brands must treat UK sales as exports.

• TikTok Shop UK requires a UK-registered entity, UK VAT number, and UK warehouse address to list products (TikTok Shop Seller Registration Policy, September 2026).

• UK VAT at 20% applies from the first sale for non-established businesses. There is no £90,000 threshold for overseas sellers (HMRC VAT Notice 700/1, 2026).

• A GB EORI number is required for every customs declaration. Applications take approximately 5 to 10 working days via HMRC (GOV.UK EORI guidance).

• A Merchant of Record like CRSSBRDR handles entity, VAT, EORI, IoR and product compliance in one go. Live in days, not months.

CRSSBRDR™ is the only MoR built by a licensed accountant and a founding TikTok Shop Partner agency. We get US and EU brands live on TikTok Shop UK in 7 to 10 business days. £100M+ in ecommerce sales driven. Compliance built in, growth switched on.

What changed for EU brands selling into the UK after Brexit?

Before 1 January 2021, selling from Germany or France to a UK customer worked exactly like selling to any other EU member state. Reverse charge, VIES checks, EC Sales Lists. No customs declarations, no import duty, no separate VAT registration.

All of that ended for Great Britain. The UK is now a third country for goods. Every shipment requires an EU export declaration and a UK import declaration. There is no reverse charge on goods. EC Sales Lists do not apply. VIES does not cover GB VAT numbers (EuTaxFlow, September 2026).

Northern Ireland is the exception. Goods moving between the EU and Northern Ireland still follow EU VAT rules under the Windsor Framework, using the XI prefix for VAT and EORI purposes.

The practical impact: an EU brand that could previously sell to UK consumers with zero additional compliance now faces five separate requirements before making a single sale.

What are the five requirements for EU brands selling in the UK?

1. UK VAT registration

Non-established businesses (any company without a UK establishment) must register for UK VAT before making their first taxable supply in the UK. The standard £90,000 domestic threshold does not apply to overseas sellers (HMRC VAT Notice 700/1). UK VAT is 20%.

For consignments valued at £135 or less sold directly to UK consumers, the EU seller must charge UK VAT at the point of sale. For consignments above £135, import VAT and any applicable duty are handled at the UK border.

Postponed VAT Accounting (PVA) is available for VAT-registered importers, allowing you to account for import VAT on your UK VAT return rather than paying it in cash at the border. This is critical for EU brands shipping stock to UK warehouses or Fulfilled by TikTok (FBT) centres.

2. GB EORI number

An Economic Operators Registration and Identification (EORI) number starting with GB is required for all customs declarations involving Great Britain. You also need your existing EU EORI for the export side.

Apply through HMRC's online service. Processing typically takes 5 to 10 working days, though non-established businesses sometimes experience longer waits (GOV.UK EORI registration). Do not book freight before your GB EORI is confirmed. A missing EORI is the most common reason parcels stall at the border.

3. UK Importer of Record

Every shipment entering the UK needs a named Importer of Record (IoR) on the customs declaration. The IoR is legally responsible for the goods at the point of import: duty, VAT, product safety, and documentation.

An EU brand can act as its own IoR if it has a UK VAT registration and GB EORI. Alternatively, a licensed IoR or MoR can take on this responsibility. Using an unlicensed third party as IoR creates liability risk; if the IoR is not properly authorised, HMRC can hold goods at the border or issue penalties.

CRSSBRDR operates as a licensed Importer of Record in the UK, backed by AAT-licensed accountancy infrastructure.

4. Product compliance and marking

The UK continues to recognise CE marking for most product categories under The Product Safety and Metrology (Amendment) Regulations 2024 (GOV.UK, September 2026). This is good news for EU brands: your existing CE documentation is likely sufficient for Great Britain.

However, you still need:

• A UK-based responsible person for cosmetics (CPNP equivalent is the SCPN in the UK).

• UK-specific labelling for food, supplements, and certain regulated categories.

• Product safety documentation accessible to UK Trading Standards on request.

• Compliance with the General Product Safety Regulations 2005 (UK version).

QuickComply™, CRSSBRDR's AI compliance tool, runs SKU-level checks against UK product requirements before listing.

5. UK entity or Merchant of Record

TikTok Shop UK requires sellers to provide a UK-registered company, UK business address, and UK bank account during registration (TikTok Shop UK Seller Registration Policy, September 2026). An EU brand without a UK entity cannot register directly.

You have two options:

• Set up a UK subsidiary. Register a UK limited company at Companies House, open a UK bank account, appoint a UK-resident director. Timeline: 8 to 12 weeks including bank account opening and VAT registration.

• Use a Merchant of Record. The MoR provides the UK entity, VAT number, EORI, IoR, and bank account. Your brand sells through the MoR's infrastructure. Timeline with CRSSBRDR: 7 to 10 business days.

How does the £135 rule work for EU sellers?

The £135 consignment rule is the single most important VAT mechanism for EU brands selling directly to UK consumers.

For B2C consignments where the intrinsic goods value (excluding transport, insurance, and VAT) is £135 or less, UK VAT at 20% must be charged at the point of sale. The customer pays nothing at the border.

For consignments above £135, you zero-rate the export. Import VAT and any customs duty are paid at the UK border, either by the buyer or by whoever is named as IoR on the customs declaration.

If you sell through a marketplace like TikTok Shop, the platform is typically the deemed supplier for sub-£135 consignments and handles VAT collection. Check the platform's specific terms to avoid double-charging (EuTaxFlow, September 2026).

What is the fastest way for an EU brand to start selling on TikTok Shop UK?

The DIY route takes 8 to 12 weeks minimum:

Figure 1: DIY vs MoR timeline comparison for EU brands entering TikTok Shop UK (September 2026). CRSSBRDR is the only MoR offering this timeline backed by a licensed UK entity.

The difference is structural. CRSSBRDR already has the UK entity, VAT registration, EORI, IoR licence, and bank account in place. Your brand plugs into existing infrastructure rather than building from scratch.

What about TikTok Shop's Sell Across Europe programme?

TikTok Shop launched its Sell Across Europe programme on 19 October 2026, enabling UK-based sellers to list products across Germany, Italy, France, Spain, Poland, the Netherlands, Belgium, the Czech Republic, Austria, Greece, Portugal, and Hungary (ChannelX, September 2026).

This programme works in one direction: UK to EU. It does not solve the EU-to-UK problem. An EU brand wanting to sell on TikTok Shop UK still needs UK compliance infrastructure first.

However, once an EU brand is live on TikTok Shop UK through a MoR like CRSSBRDR, Sell Across Europe opens a reverse channel back into EU markets through TikTok's platform. The compliance requirements differ (EU VAT, CE marking, local consumer protection), but the commercial opportunity is bidirectional.

What mistakes do EU brands make when entering the UK market?

1. Assuming EU compliance covers the UK. It does not. Since Brexit, the UK has a separate regulatory framework. CE marking is still recognised for most products, but VAT, customs, IoR, and labelling rules are entirely separate.

2. Waiting for the £90,000 threshold. Non-established sellers have no threshold. You must register for UK VAT before the first sale.

3. Using an unlicensed IoR. An unlicensed intermediary acting as IoR exposes you to customs holds and penalties. Use a licensed Importer of Record.

4. Opening a UK bank account before registering the entity. UK banks require a registered company first. The bank account is typically the longest single step at 4 to 8 weeks.

5. Ignoring Northern Ireland. If you ship to NI addresses, EU VAT rules apply for goods. Mixing GB and NI treatments on the same invoice creates compliance issues.

6. Treating the MoR as optional. Without a UK entity, you cannot register on TikTok Shop UK. A MoR is not a shortcut; for most EU brands, it is the only viable route to market in under three months.

FAQ

Do EU brands need a UK entity to sell on TikTok Shop? Yes. TikTok Shop UK requires a UK-registered company, UK address, and UK bank account. An EU brand can either incorporate a UK subsidiary or use a Merchant of Record that provides these.

Is there a VAT threshold for EU brands selling to UK consumers? No. Non-established businesses must register for UK VAT before making their first taxable supply in the UK. The £90,000 threshold only applies to UK-established businesses.

Can I use my EU CE marking in the UK? For most product categories, yes. The UK continues to recognise CE marking under The Product Safety and Metrology (Amendment) Regulations 2024. Some categories may require additional UK-specific compliance.

How long does UK VAT registration take for an EU company? HMRC typically processes non-established trader VAT registrations in 2 to 4 weeks, though it can take longer during peak periods.

What is the difference between a Merchant of Record and an Importer of Record? An IoR is responsible for goods at the point of customs entry. A MoR is the legal seller of the goods, handling entity, VAT, payments, and returns. A MoR typically includes IoR services. CRSSBRDR provides both.

Does Postponed VAT Accounting work for EU businesses? Yes. Any business with a UK VAT registration and GB EORI can use PVA to account for import VAT on their VAT return rather than paying cash at the border.

Can an EU brand sell to Northern Ireland without UK compliance? For goods, EU VAT rules apply to Northern Ireland under the Windsor Framework. For services, UK rules apply. Goods shipped from the EU to NI do not require a GB EORI or UK VAT registration, but you must still comply with EU export and NI import procedures.

What is the fastest way to get live on TikTok Shop UK from the EU? Use a Merchant of Record. CRSSBRDR gets EU brands live in 7 to 10 business days, compared to 8 to 12 weeks for the DIY entity setup route.