A New Trade Relationship

Since the UK’s withdrawal from the European Union, trade between the UK and EU countries, including the Netherlands, has been governed by the EU–UK Trade and Cooperation Agreement (TCA). Signed on 24 December 2020 and provisionally in force since May 2021, the TCA ensures zero tariffs and zero quotas on goods traded between the two markets, provided they meet the agreed rules of origin (RoO).

While tariffs have been avoided, Brexit has created a new customs border. Businesses on both sides must now comply with additional customs formalities, declarations, and product-specific rules, which can affect logistics, costs, and paperwork.

Customs Formalities and Rules of Origin

The TCA’s zero-tariff provisions only apply if goods comply with rules of origin. This means:

• Goods must either be wholly obtained in the EU or UK, or
• Be substantially transformed in one of the two markets.

Goods imported from third countries into the UK and then re-exported to the EU without sufficient processing may still face tariffs. Rules of origin are product-specific and can be complex. For instance, in the textiles and clothing sector, only 10–53% of UK exports to the EU used zero tariffs in 2022 due to compliance challenges.

For Dutch companies importing from or exporting to the UK, this means careful documentation of supply chains, classification of goods, and correct use of commodity codes.

Customs Procedures Between the UK and the Netherlands

For customs purposes, the UK is treated as a non-EU country. This means:

• Customs declarations are required for all imports and exports.
• Safety and security data may need to be filed in addition to declarations.
• Licences are required for certain categories of goods (e.g. hazardous chemicals, GMOs, or waste).
• Excise goods (alcohol, tobacco, fuel) require additional paperwork.
• Different VAT rules apply compared to intra-EU trade.

Goods moving through Great Britain (England, Scotland, Wales) must comply fully with UK customs checks. However, under the Northern Ireland Protocol, EU rules continue to apply to goods entering and leaving Northern Ireland.

Online Shopping and Consumer Purchases

For Dutch consumers buying from UK online retailers, the UK is treated like any other non-EU country:

• VAT, customs duties, and handling fees may apply.
• Sellers must clearly state the total cost, including taxes and fees.
• Additional charges can still occur upon delivery if not calculated in advance.

UK Border Controls and the BTOM

Since Brexit, both the EU and UK have introduced full customs controls, though the UK has phased them in gradually. The Border Target Operating Model (BTOM), published in 2023, established a risk-based approach to UK imports.

Key features include:

• Health certification and SPS (sanitary and phytosanitary) checks on agricultural and food products.
• Identity and physical checks on animals, plants, and high-risk goods at designated Border Control Posts.
• A future Single Trade Window, designed to digitise customs processes (though currently delayed).

From January 2024, businesses must pre-notify imports of animals, plants, and high-risk foods, with phased rollouts of checks continuing through 2027.

Towards a UK–EU SPS Agreement

In May 2025, the UK and EU agreed to establish a Sanitary and Phytosanitary (SPS) Area, which will eventually:

• Remove most border checks and certification requirements on agri-food products.
• Simplify trade in previously restricted goods, such as chilled meats, shellfish, and seed potatoes.
• Reduce costs and delays for businesses trading in agricultural and food products between the UK and EU.

Key Takeaways for Dutch Businesses

• Customs declarations are mandatory for all goods moving between the Netherlands and the UK.
• Rules of origin must be carefully documented to benefit from zero tariffs.
• Licensing and certification may apply for agrifood, chemicals, excise goods, and other sensitive categories.
• VAT procedures differ significantly from intra-EU trade.
• Businesses must stay updated as UK border controls evolve and SPS negotiations progress.

Conclusion

Brexit has reshaped the trading relationship between the Netherlands and the UK. While the TCA preserves tariff-free trade, businesses face new administrative requirements and regulatory hurdles. Compliance with customs formalities, rules of origin, and evolving border controls is now essential for smooth trade.

Looking ahead, the planned SPS agreement could significantly ease the movement of agricultural and food products, reducing friction at the border and creating new opportunities for Dutch–UK trade.

References

European Commission. (2022). EU-UK: A new relationship. Retrieved from European Commission: https://taxation-customs.ec.europa.eu/customs/international-affairs/united-kingdom_en

Jozepa, I. (2025, July 31). Customs rules for trade with the EU. Retrieved from UK Parliament – House of Commons Library: https://commonslibrary.parliament.uk/new-customs-rules-for-trade-with-the-eu/

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