Brexit changed the legal route for goods leaving France for England, Scotland or Wales. A French company no longer treats that shipment as an ordinary intra-European Union movement: it is an export from the European Union and an import into Great Britain. The practical consequences reach beyond a customs form. The seller must establish who is the exporter, identify the customs representative, use the correct Economic Operators Registration and Identification (EORI) number, preserve proof that the goods left the European Union, and decide who will act as importer in the United Kingdom.

The commercial contract must also deal with preferential origin, import value-added tax (VAT), customs duty, licences, returns and delivery terms. A price that looks profitable under Delivered at Place (DAP) can become loss-making under Delivered Duty Paid (DDP) if the French seller has silently accepted the United Kingdom import obligations. Northern Ireland follows a different goods regime from Great Britain, so the destination and route must be checked before the invoice is issued.

This article gives a working framework for a French company selling goods to a British business or distributor. It separates French export compliance from United Kingdom import compliance, explains the evidence that the French tax administration can request, and identifies the contract decisions that should be made before the first truck, parcel or container leaves France. It is a legal working guide, not a substitute for a product-specific customs classification or advice on a regulated shipment.

I. Can a French company export goods to the United Kingdom after Brexit?

A. What changes when the United Kingdom becomes a third country for French customs?

For customs purposes, England, Scotland and Wales form the Great Britain (GB) destination in the usual France–United Kingdom goods route. Great Britain is outside the customs territory of the European Union (EU). The shipment therefore has two sides: French export formalities and United Kingdom import formalities. The seller may have one commercial customer, but the customs authorities see an exit from one customs territory and an entry into another. That distinction matters even when the buyer is a long-standing group company, the goods are sold in euros, or the carrier crosses the Channel every day.

Northern Ireland (NI) cannot simply be placed in the same box. Goods moving directly from France to Northern Ireland require an analysis of the route, the parties and the goods regime applicable to Northern Ireland. Goods moving from Great Britain to Northern Ireland involve another layer of United Kingdom rules. A French exporter should state the actual destination on the order and transport instructions rather than using “UK” as the only geographical description.

The Union Customs Code (UCC), the main EU customs regulation, provides the starting point. Article 158 states that All goods intended to be placed under a customs procedure must be covered by an appropriate customs declaration, subject to the regulation’s exceptions. The full provision is available in the official English text of Article 158 UCC. Article 269 governs goods leaving the EU customs territory under the export procedure; the official consolidated UCC text should be checked for the version applying to the transaction.

In practical terms, the export declaration identifies the goods, their classification, value, origin, destination and procedure. The customs declaration is not a replacement for the sales invoice, packing list or transport contract. It is the legal data set that allows French customs to supervise the goods and, after exit, allows the exporter to connect the shipment to an exit result. A carrier’s tracking page can show that a parcel moved; it does not automatically prove that the goods were properly exported for every French VAT purpose.

French customs law has also been recodified in 2026. Article L512-7 of the Code des douanes addresses goods leaving the customs territory without the required declaration and defines an export without declaration as Constitue une exportation sans déclaration. Read the current Article L512-7 of the French Customs Code on Légifrance with the applicable European procedure. The point for a company is straightforward: an informal commercial dispatch, an incomplete courier booking or a broker’s assumption cannot replace the export process that the goods require.

The EORI number is the customs identifier used to identify an economic operator in customs transactions. EORI does not mean “company registration”, does not replace the French company’s legal identifiers, and does not by itself prove that the company owns the goods. A French company will also encounter the SIREN, the nine-digit identifier for the legal entity, and the SIRET, the identifier for a particular establishment. The French one-stop business portal, operated by the National Institute of Industrial Property (INPI), handles the Registre national des entreprises (RNE, the national register of businesses) formalities; its official explanation of the Guichet unique and RNE is separate from EORI registration.

The French exporter must identify whether it is established in France, whether another group company is the seller, and whether an agent is completing the declaration. An overseas founder may own the French company without being the exporter personally. The legal entity named on the invoice, the party with the power to dispose of the goods, the party instructing the customs declaration and the party carrying the commercial risk should be aligned. If those roles are different, the written contract and customs mandate should say so expressly.

Product classification is another dividing line. The Harmonized System (HS) is the international classification framework; the Combined Nomenclature (CN) is the EU classification layer used for many EU customs purposes. A product description such as “machine parts” or “consumer goods” is usually too broad. The exporter should identify the code, check measures and restrictions, and retain the reasoning and technical documents behind the classification. An apparently small classification error can alter the duty rate, origin rule, licence requirement and import treatment in Great Britain.

The export analysis also changes when the goods are not ordinary merchandise. Food, animal products, plants, medicines, chemicals, waste, dual-use products, cultural goods, batteries and products subject to sanctions may require authorisations or documentary controls. A customs declaration can be accepted while another regulatory condition remains unsatisfied. The sales team should therefore send the product description to the compliance and logistics teams before promising a delivery date.

B. Who is responsible for the French declaration, the carrier and the United Kingdom import?

A French exporter can lodge its own declaration or appoint a customs representative. Article L221-4 of the French Customs Code says that toute personne a la possibilité de se faire représenter. That right does not mean that the exporter can stop asking questions. The company should know whether the representative acts in direct representation, in the name and on behalf of the exporter, or in indirect representation, in its own name but on behalf of the exporter. The mandate should identify the customs procedures, the goods, the data supplied, the party responsible for classification and the process for correcting an error.

Article L221-5 provides that toute personne qui agit en qualité de représentant en douane est préalablement enregistrée. The official Article L221-5 text is a useful check when a company is presented with a new broker or freight-forwarding arrangement. Ask for the representative’s legal identity, registration status, contact details for customs queries, and the precise service included in the price. A freight forwarder may arrange transport without accepting the role of customs declarant; those are different functions.

The French Customs Code also allocates responsibility for declarations. Article L522-1 states that the person who made one of the declarations is responsible for les omissions, inexactitudes et irrégularités in the information supplied, subject to the legal framework. The official Article L522-1 page should be read with Article L522-2, which addresses the responsibility of the representative in the relevant circumstances; see the official Article L522-2 text. A broker’s involvement is not a licence to send an unverified commercial description and assume that the broker will invent the missing facts.

The company should establish a responsibility matrix before the first shipment. It can be short, but it should answer at least these questions:

• Who is named as exporter of record in France, and who can prove the company’s authority to dispose of the goods?
• Who supplies the HS or CN code, customs value, preferential origin analysis and licences?
• Who submits the French export declaration and who receives the Export Accompanying Document (EAD), the document carrying the declaration reference for the movement?
• Who gives the carrier the Movement Reference Number (MRN), the customs movement reference, and who completes any ferry or tunnel pre-notification?
• Who is the United Kingdom importer of record, who holds the United Kingdom EORI, and who pays import VAT and customs duty?
• Who keeps the exit message, transport evidence, invoice, packing list, origin statement and broker correspondence?
• Who handles a rejected declaration, a customs inspection, a damaged shipment, a return or a request from the French tax administration?

Delivery terms should match the matrix. Under DAP, the seller generally brings the goods to the agreed place while the buyer handles import clearance and import charges, subject to the contract and the exact Incoterms rule. Under DDP, the seller generally accepts the broadest delivery responsibility, including import clearance and duties in the destination country. DDP may therefore require the French seller to arrange a United Kingdom customs identity, tax treatment, local representation and a workable import process. The Incoterms rule allocates commercial cost, risk and delivery tasks; it does not by itself answer every VAT registration or customs representation question.

For a business-to-business sale, the order should also say whether the British buyer is the importer, whether the buyer authorises a broker, and whether the seller may stop dispatch if a required number or licence is missing. For a business-to-consumer sale, the seller should add the product safety, consumer information, distance-selling, returns and United Kingdom VAT analysis. A single template for both models is likely to hide the party that bears the import burden.

The contract should address data quality. The customs broker will often rely on the seller’s invoice and product file. If the seller later changes the product, bundle, packaging, manufacturing location or price, the customs instructions should be updated rather than copied forward. A record showing who approved the classification and why can be more valuable than a vague statement that “the carrier handled everything”.

Finally, the French company should distinguish an export sale from a movement of its own stock. If the company sends goods to a United Kingdom warehouse without transferring ownership, it may face a different importer, valuation, VAT and stock-reporting analysis. A consignment, repair, temporary admission, sample, replacement or return shipment should not be forced into an ordinary sale workflow. The commercial purpose and customs procedure must correspond.

II. How should a French company handle EORI, customs declarations, VAT proof and origin?

A. How do EORI, customs declarations and proof of VAT-exempt export work?

The first operational step is to check the French operator’s EORI status before the declaration is prepared. French Customs has announced a transition affecting EORI identifiers built from the SIRET. Its current EORI guidance explains that EORI numbers based on SIRET are being disabled during the second half of 2026 and that an operator established in France may have an identifier based on FR plus SIREN, alongside the relevant transition arrangements. A company should verify the identifier shown in the customs system at the time of filing; it should not copy an old number from a prior shipment without checking the current status.

The French exporter should also verify its French VAT number and the name and address attached to its customs record. EORI and VAT identifiers answer different questions. The EORI identifies the operator for customs. The VAT number connects the taxable person to VAT reporting. A broker may ask for both, and a mismatch between the invoice entity, EORI holder and VAT entity can delay clearance or weaken the audit trail.

Export declarations are filed through the French customs clearance service. The current DELTA IE export and exit-monitoring guidance describes the export component of DELTA IE, the French electronic customs system. DELTA IE does not make a poor product file reliable. Before filing, the exporter should have the legal name and address of the parties, invoice number and date, currency, price, quantity, net and gross weight, packages, transport information, destination, HS or CN code, origin, Incoterm and any authorisation reference.

The customs value must be coherent with the transaction and the chosen delivery term. The company should identify whether freight, insurance, commissions, tooling, assists or related-party pricing affects the value under the applicable customs rules. A transfer between a French subsidiary and a foreign parent may require a different analysis from a sale to an independent distributor. The invoice price is a starting point, not an automatic answer to every customs valuation question.

The physical border process needs its own checklist. For a roll-on/roll-off route, the carrier may need the MRN or a logistics envelope reference before the vehicle arrives at the port. For a groupage shipment, the exporter should know how the individual consignment is linked to the master transport movement. The French Customs explanation of the Smart Border process for exports to the United Kingdom describes preparation, declaration, the EAD, carrier transmission and the matching of the customs declaration to the transport. A driver having a commercial invoice is not the same as the carrier having the customs reference required for the route.

French export VAT treatment is a separate question from customs acceptance. Article 262 of the French General Tax Code (CGI, Code général des impôts) begins the relevant exemption list with Sont exonérées de la taxe sur la valeur ajoutée. The official Article 262 CGI text covers qualifying goods dispatched or transported outside the European Union. The French seller must record the export sale using the correct VAT treatment and invoice wording for its circumstances; it must also be able to prove the goods actually left the EU customs territory.

The proof requirement is not satisfied by selecting “export” in accounting software. Article 74 of Annex III to the CGI describes evidence for exported goods. It refers to export deliveries as Les livraisons réalisées par les assujettis et portant sur des objets ou marchandises exportés. The official Article 74 of Annex III page sets out the documentary conditions. In practice, preserve the export declaration reference, the exit result or exit message, the invoice, the transport document, the packing list and the correspondence that connects the goods and shipment to the customer order.

An EAD is useful evidence of the export movement, but it is not automatically proof that the goods exited the EU. The company needs the customs exit result or equivalent evidence from the procedure, and it should investigate a movement that remains open. If a carrier says that the goods arrived in Great Britain but the French export movement has no exit confirmation, the accounting team should not simply close the file as fully evidenced. Ask the broker or carrier to trace the MRN, the transport event and the reason for the missing exit result.

The French tax administration can also accept alternative evidence in the circumstances provided by the legislation. Depending on the case, this can include a destination import declaration, a transport document, a customs document, a carrier statement or other reliable evidence. The correct evidence depends on the transaction and the legal conditions; a screenshot without the shipment reference is weak evidence. The records should be readable, authentic and retrievable by invoice number, MRN and customer order.

Article L221-1 of the French Customs Code requires customs documents to be preserved in their original form in the relevant circumstances. It uses the expression les personnes … les conservent sous la forme originale. The official Article L221-1 text should be included in the company’s retention procedure. Article L221-3 adds requirements for the authenticity of origin, integrity of content and readability of electronic records; its wording can be checked in the official customs-code section on Légifrance. A PDF generated after the event should not silently replace the original broker message or system record.

Invoicing is part of the evidence chain. Article 289 CGI provides that Tout assujetti est tenu de s’assurer qu’une facture est émise. See the official Article 289 CGI page. The invoice should identify the seller and buyer, describe the goods precisely, show the price and currency, state the agreed delivery term, identify the customs information needed by the broker, and carry the relevant export VAT wording. If the invoice is issued in English, the company should retain the original and be able to provide a French translation when requested by the administration.

Input VAT recovery also needs to be reconciled with the export file. Article 271 CGI lists qualifying transactions that open a right to deduction, including operations exempted under Article 262 in the relevant conditions. The official Article 271 CGI text is the reference for the deduction analysis. The French tax administration’s official Brexit information is a further source for the tax effects of the United Kingdom’s change of status. The finance team should reconcile the sales ledger, export evidence, VAT return and customs data rather than treating the absence of French VAT on the invoice as proof that the transaction was correctly reported.

There is a serious reason to avoid manufactured or careless evidence. In a decision of the Cour de cassation, criminal chamber, 12 January 2005, no. 03-86.150, the court stated that il appartient de démontrer qu’au moment où il a appliqué l’exonération de TVA, il détenait la preuve que les marchandises en cause avaient quitté le territoire national. The exact judgment is available on Légifrance, Cour de cassation, criminal chamber, 12 January 2005, appeal no. 03-86.150. The lesson is evidential: the file must support the exemption when it is applied, not only after an audit starts.

A second published decision, Cour de cassation, criminal chamber, 4 May 2016, no. 15-80.215, concerned falsified export documents and the offence described as exportation sans déclaration de marchandises prohibées. The official record is available on Légifrance, Cour de cassation, criminal chamber, 4 May 2016, appeal no. 15-80.215. It is a practical warning for a company that receives a replacement customs document from a broker: ask the customs office to confirm the underlying movement rather than accepting a document whose stamp, reference or exit result cannot be verified.

Article L512-8 of the French Customs Code also refers to a false declaration or manoeuvre intended to obtain a financial advantage attached to VAT, including in the wording une fausse déclaration ou manœuvre. Consult the official Article L512-8 text. This does not mean that every clerical mistake is a criminal offence. It does mean that a company should correct errors promptly, preserve the correction trail and never create an exit document, transport proof or origin statement that does not describe the actual movement.

A useful internal file has four stages. Before filing, the broker and exporter approve the product and transaction data. At dispatch, the carrier receives the correct customs reference and documents. After the border, the company retrieves the exit result and matches it to the invoice. At month-end, finance reconciles the file to the VAT return and escalates open or contradictory records. This simple sequence prevents the common error of treating a customs declaration as the end of the process when the French VAT exemption depends on what happened at exit.

B. How do origin, United Kingdom import VAT, Incoterms and returns change the cost?

Customs origin is not the same as the country from which the truck departs. The EU–United Kingdom Trade and Cooperation Agreement (TCA) can provide preferential treatment for qualifying goods, but the seller must show that the goods satisfy the applicable product-specific origin rule. Goods made in France may qualify as EU-originating; goods merely purchased, stored, repacked or dispatched from France may not. The company should examine production steps, non-EU materials, supplier statements, processing records and the product’s commodity code before promising “zero duty” to the buyer.

The French Customs Brexit guidance explains the statement on origin and the exporter threshold. For consignments within the stated value limit, an EU exporter that is not required to use a Registered Exporter (REX) number can make the statement in the required form. Above the threshold, an exporter must use the relevant registration and statement process. The current French Customs Brexit questions and answers should be checked for the goods, value and date at issue. The exporter should not copy a statement from an earlier order when the manufacturing or supplier facts have changed.

The French Customs Brexit guidance explains the relevant checklists and agreement material. Under the TCA, the relevant preference is tied to EU origin rather than simply to the location of the seller. The origin statement belongs on the invoice or another commercial document in the form required by the agreement. A certificate of incorporation, a French EORI or a French departure port does not substitute for a product-origin analysis. The exporter should compare the current guidance with the official customs questions and answers before using a preference claim.

For a manufacturer, the evidence should be assembled product by product. Keep bills of materials, supplier declarations, production records, purchase invoices and calculations showing the proportion and status of non-originating materials. For a distributor, ask the supplier for a usable origin statement and confirm that it covers the goods and period supplied. For a group manufacturing chain, identify the entity performing the qualifying processing and make sure the commercial invoice and customs origin data are consistent.

The British importer then faces a separate customs calculation. The United Kingdom import process normally requires the importer or its agent to identify the commodity code, customs value, origin, licences and any applicable duty or relief. The official United Kingdom step-by-step guide to importing goods explains the need to prepare the import, appoint an agent where appropriate, classify the goods and check restrictions. The French exporter should ask the British buyer for the importer’s legal name, United Kingdom EORI and broker instructions before choosing DDP.

Under DAP, the buyer will often act as importer and pay United Kingdom import VAT and customs duty, while the French seller delivers to the agreed place under the rule’s terms. Under DDP, the French seller may have to arrange the import entry, pay the charges, obtain the necessary British identity or appoint a capable agent, and absorb costs that were not in the quotation. The difference is not merely a freight surcharge. It can affect the seller’s registration, tax recovery, product compliance, returns process and customer support.

Consider a French manufacturer selling a machine for €40,000. The French export invoice may be issued without French VAT when the Article 262 conditions and proof requirements are met. The British import calculation can nevertheless include the customs value, transport and other legally relevant elements, followed by United Kingdom import VAT and any duty. The rate depends on classification, origin, reliefs and current British rules. A commercial price or a zero-rate French invoice does not make the British import VAT disappear.

If the French seller keeps stock in Great Britain, sells goods after import, operates a local fulfilment arrangement or makes certain direct-to-consumer consignments, a separate United Kingdom VAT analysis is needed. A seller should not infer from one B2B shipment that every later sale has the same treatment. The importer of record, ownership at import, storage location, customer status, shipment value and sales model can all change the result. The British tax and customs rules should be checked for the actual flow.

Returns are another import event, not a free administrative reversal. Article 291 CGI states that Les importations de biens sont soumises à la taxe sur la valeur ajoutée. The official Article 291 CGI text is the starting point for goods coming back into France. Article 293 A CGI defines an import declaration as La déclaration d’importation s’entend de la déclaration en douane; see the official Article 293 A page. Returned-goods relief under the UCC may be available only when its conditions are met, so the exporter should preserve the original export record, identity of the goods and reason for return.

A repair, replacement, warranty return and refused delivery should be described accurately. If the goods are altered abroad, sold to another buyer, combined with other goods or returned after a long period, the original export facts may no longer fit a simple returned-goods treatment. Tell the broker that the goods are returning and give it the original MRN, export invoice, transport documents and proof of identity. Avoid a new invoice that hides the history of the goods.

Northern Ireland requires a separate route check. The United Kingdom’s official guidance explains how VAT applies to goods moving between Great Britain and Northern Ireland and how goods move from the EU to Northern Ireland. Read the Great Britain–Northern Ireland VAT guidance and the EU-to-Northern Ireland guidance for the current transaction. A French exporter should give the carrier the precise Northern Irish destination and should not apply the Great Britain workflow merely because the customer’s group is headquartered in London.

Product controls can be decisive. A food consignment may need sanitary or phytosanitary documentation; an animal product may need health certification; a chemical may trigger registration or safety requirements; a dual-use item may require an export authorisation. The applicable rule may depend on the product’s technical characteristics, not its commercial name. The exporter should consult the relevant French and British authorities and place the licence number in the customs file where required. The official Service-Public procedure for simplified customs formalities can help identify the French customs channel, but it does not replace a product-specific licence check. Delivery dates should contain a compliance condition when an authority’s approval is not yet obtained.

The cost model should be written in two columns. The French column contains export brokerage, classification work, packaging, transport to the border, French VAT evidence and possible inspection costs. The United Kingdom column contains import brokerage, duty, import VAT, port or handling fees, domestic delivery, storage, British compliance and return costs. Then apply the chosen Incoterm and state which party pays each line. This exposes a DDP quotation that is commercially impossible before the order is accepted.

The following checklist is suitable for a first shipment:

1. Before accepting the order: identify GB or NI, the buyer, the goods, the legal seller, the importer of record, the Incoterm and any regulated-product issue.
2. Before preparing the declaration: verify the French EORI, VAT number, HS or CN code, customs value, origin evidence, licences, invoice data and broker mandate.
3. Before the truck or parcel leaves: obtain the export declaration reference, send the EAD or required data to the carrier, give the carrier the MRN or route reference, and check the loading and packaging data.
4. At the border: monitor the declaration and carrier matching, respond to an inspection, and do not treat a missed ferry or a rejected movement as an ordinary delivery delay.
5. After exit: retrieve the exit result, match it to the invoice and transport, resolve an open movement, and store the original records in a searchable file.
6. At accounting close: reconcile the export VAT treatment to Article 262 evidence, retain the invoice and customs file, and flag returns or stock movements for a fresh analysis.

Foreign founders can use the same controls even when they do not live in France. The company’s director’s residence does not replace the French company’s customs identity or determine who is importer in Great Britain. A founder who wants a broader overview of French incorporation and early compliance can read the firm’s guide on setting up a business in France as a foreign founder. For the specific French EORI point, the related guide on a French EORI number for a foreign company importing into France is useful, but an export to Great Britain still requires the outbound and United Kingdom steps described here.

Conclusion

A French company can export goods to Great Britain after Brexit, but the shipment must be designed as a two-border operation. In France, confirm the exporter, EORI, classification, declaration, broker mandate, exit evidence and VAT file. In the United Kingdom, confirm the importer, EORI, classification, origin claim, import VAT, customs duty, licences and delivery route. Then make DAP or DDP a deliberate commercial choice rather than a default term copied from an old EU shipment.

The safest first-shipment file connects the order, invoice, product records, origin evidence, export declaration, MRN, carrier movement, exit result and accounting entry. It also explains what happens if the goods are returned, refused, repaired or sent to Northern Ireland. If the broker, carrier, seller and buyer cannot answer the same responsibility questions, pause the dispatch long enough to fix the contract and customs instructions. That short delay is usually cheaper than an open export movement, an unsupported French VAT exemption or an unexpected British import bill.

The rules depend on the product, route, value, transaction chain and date. Check the current official customs and tax pages before filing, and obtain transaction-specific advice when the goods are regulated, the seller is importing under DDP, the parties are related, or stock is held in Great Britain.

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