General Overview

In the immediate term there are many new rules relating to custom procedures product requirements, free trade, travel and working permits etc. It is important that your company look into what rules apply to you.

In the longer term, limitations following the UK's new regulatory independence may pose problems for companies. For instance, we risk seeing changes in jurisdiction on intellectual property, GDPR, competition law, disputes and arbitration as well as potential non-tariff barriers due to diverging regulation and requirements of multiple different standards (CE-mark, etc.)

Custom procedures and Tariffs

Importers are now subject to additional administrative requirements, including obtaining import registrations and submitting customs declarations every time goods come in and out of the EU, to and from the UK.

The Free Trade Agreement does not create a customs union, product might still be subject to import duties to the EU or UK. You as an exporter must be able to prove that the product has preferential origin EU, not to be confused with the origin “Made in Sweden” or such.

Just as required when trading with any other country outside of the EU, Swedish companies must have an EORI-numbers in order to export goods to the UK. This can be applied for at the Swedish customs.

If you do not wish to handle the new requirements for export and import declarations you can arrange with your freight forwarder, transport company or with a specific customs broker about submitting the declarations on your behalf to avoid extra administration. To hire a customs broker are many times advisable since it can be an administrative burden for a company to do.

How Brexit will impact your relationship with your distributor is difficult to say. Apart from needing to decide on who will act as an importer of goods as well as decide on trade terms, we suggest you speak directly to them.

If you wish to act as an importer on behalf of your distributors, you need to apply for a UK EORI-number (done through the HMRC). Further, your company needs to be VAT-registered with the HMRC to be able to deduct VAT. You can both apply for a UK EORI-number as well as become VAT-registered as a Swedish registered company, hence you do not need to set up a UK branch or company for this purpose.

Note that acting as an importer can come with further responsibilities. For example it is up to the importer to fulfill all import requirements and having all applicable registrations and possible import licenses.

Since January 1st 2021 companies need an importer for their goods to the UK. This however can be either a UK subsidiary of your company or a third party (e.g. a wholesaler or distributor you currently sell to).

Note that the importer is responsible to fulfill all import requirements and having all applicable registrations and possible import licenses.Please find more information on the UK government’s website here and here.

UK have set up their own table of tariffs and the main rule is that tariffs will apply on imports. Having that said, the tariffs differ from product to product. While high tariffs apply to some goods, tariffs have been lowered compared to the EU tariffs and some tariffs have been set to zero.

EU - UK Trade and Cooperation agreement

The Free Trade Agreement covers a broad range of areas, such as investments, competition and data protection. But also trade in goods and services. For further inquires regarding the free trade agreement please contact Business Sweden.

The free trade agreement is available to all companies and applies to all products – but the tariff reductions are not unconditional. In order to apply the free trade agreement to your consignment you need to be able to prove that your product qualifies as EU origin. To prove this there are specific rules of origin for all product which require a detailed calculation that your product is either wholly obtained or sufficiently transformed within the EU. If your product does not fulfill the rules of origin the regular tariffs will apply.

For questions regarding the free trade agreement, please contact Business Sweden.

In principle no - the main pro is that goods can be tariff free if they fulfill the rules of origin. Same import requirements and custom procedures applies with or without applying the agreement.

There are a number of documentary requirements which you need to be mindful of in order for you to be able to prove the EU origin.

You will furthermore need to put a specific declaration on your invoice, which will require a REX registration with the Swedish Customs Agency. For more information on REX, click here.

For questions regarding the free trade agreement, please contact Business Sweden.

Yes. You should make sure you still meet the requirements of other free trade agreements with countries you may export to. Leaving the EU implies that all goods from the UK, previously having preferential origin in the EU, will lose that status. Hence, your product will also lose its preferential status if it is dependent upon goods from the UK having EU origin status in order to fulfil the rules of origin. This can be applicable in trade with other countries to which you might sell today.

Product requirements and regulatory independence

The CE-mark is a EU common compliance mark, which validity will cease to exist in the UK. UKCA (UK Conformity Assessed) marking is a new UK product marking used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.

The technical requirements (‘essential requirements’) you must meet – and the conformity assessment processes and standards that can be used to demonstrate conformity – are still largely the same as they were before the end of the transition period.

The UKCA marking can be used since 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2022 in most cases.

Please find more information on the UK government’s website here

Since 1 January 2021, a wholesale dealer in Great Britain (England, Wales and Scotland) may only import Qualified Person (QP) certified medicines from the European Economic Area (EEA) if certain checks are made by the ‘Responsible Person (import) (RPi)’.

The RPi is responsible for implementing a system to confirm for products that have been imported into Great Britain from countries on an approved country for import list (initially, this will be countries in the EEA).

Please find more information on the UK government’s website here

Travelling and staffing

You can read more about traveling and working in the UK after Brexit on the UK authorities' website here. The link also contains a guide that can be used to see if you need a work visa.

If your employees are to bring tools for their work, they should consider whether they can use an ATA carnet, so that they can take the tools in duty-free and avoid import declaration. Your nearest Chamber of Commerce can support you in issuing an ATA Carnet.

EU citizens who are residing in the UK before the 31st of December 2020 will be allowed to stay in the country provided that they apply for the new permanent residence permit, so-called settled or pre-settled status until 30th of June 2021.

The rules for work travel has changed. How your work travel will be impacted by the UK’s decision to leave the EU will depend on your specific circumstances. Please see more information here.

The UK government's future skills-based immigration system white paper sets out the government's plans to introduce a new single immigration system, ending free movement. The new system includes:

  • A skilled workers route open to all nationalities
  • Lowering of the skills threshold on the skilled workers route to include medium-skilled workers
  • No cap on numbers on the skilled workers route, meaning that business will be able to hire any suitable qualified migrant
  • The abolition of the resident labour market test
  • A new time limited route for temporary short-term workers of all skill levels, including seasonal low-skilled workers
  • An extension to the post-study period for international students

You can find the white paper here.


Though the FTA signed by the UK and the EU contains some information on services, a lot of the details remain to be worked out (for instance recognition of certain qualifications).

Leaving EU, UK is no longer bound by mutual recognition of services which is the basis of the free movement of services. Meaning that a service that is legally carried out in Sweden is not automatically accepted in the UK. The same applies for certain professions requiring specific certifications. Further, free movement of labour between the UK and the EU has now ended and new rules apply for EU citizens looking to work in the UK.

VAT on services sold to the UK will be handled in accordance with the rules governing export of services to a third country. We recommend companies to contact the Swedish Tax Agency and its counterpart in the UK regarding specific questions. The Swedish Tax Agency has set up a website with information relating to VAT and Brexit here.


The rules outlined in question ”What effects can a no-deal Brexit have on taxation related to sales of services?” apply to online sales as well.

For online sales, there are also other trends to consider. For instance, 17% of UK consumers see same day delivery as the most important consideration and 14% see fast delivery as the most important (ranking second and third in total). Similarly, slower than expected delivery is perceived as the most common problem among consumers, experienced by 29% of adults who bought online in 2016. Potentially longer lead times due to customs clearance could impact companies exporting from Sweden to the UK.

E-commerce companies should be vary of the special rules for consignments which value does not exceed 135 GBP. The rule implies that the Swedish company need to collect VAT from the British customer and pay the VAT to the UK HMRC.This procedure requires the Swedish company to get a VAT registration in UK.

For more information on e-commerce in the UK, please see our e-commerce guide here


Did you not find the answer to your question? Contact us.

Robin Bängs - Brexit
Johan Ottosson

Senior Project Manager, London


Project Manager,
+44 7572 60 98 81

Gustaf Bergström

Trade & Invest Commissioner UK & Ireland


Market Area Director,
UK & Ireland
+44 20 7258 5134

Business Sweden can be your feet on the ground in extraordinary times. Our global team has a unique, government-backed mandate to provide support services that help you plan for contingency action, avoid disruption and engage with customers around the clock – wherever they are located. Jan Larsson, President & CEO, Business Sweden