BREXIT & CUSTOMS
UK ↔ France freight is now customs-led.
Since 2021 every UK ↔ France freight movement is a customs movement first and a road movement second. The paperwork decides whether the trailer crosses. We run the paperwork in-house. This page explains what the paperwork is, why it matters, and how the post-Brexit corridor is operating in 2026.
THE SHAPE OF IT
What changed in 2021, and where it stands now.
When the UK left the EU customs union, every UK ↔ EU goods movement became a third-country import or export. France treats UK goods as third-country and runs full DGDDI controls. The UK introduced the same on its side in phases — the final phase, the Border Target Operating Model (BTOM), has been operational since 2024 and is now the steady-state regime.
In practice: an export declaration on the consignor side, an import declaration on the consignee side, a Goods Movement Reference (GMR) on the UK side via GVMS, and a Delta-G declaration on the French side. Inspections happen at the border by exception; documentation is required for every movement, every time.
THE DOCUMENTS
The customs paperwork on a typical lane.
EORI
Economic Operator Registration and Identification number. The consignor and consignee each need their own — a GB EORI for the UK side, an EU EORI for the French side. We verify both on file at account onboarding; there is no movement without a valid pair.
EAD — Export Accompanying Document
Raised on the export side. UK exports use HMRC's Customs Declaration Service (CDS) to produce the EAD. French exports use DGDDI's Delta-G. The EAD travels with the goods; the trailer cannot legally leave the consignor without it.
GMR — Goods Movement Reference
A GMR is generated in GVMS (Goods Vehicle Movement Service) and married to the booking before the driver presents at the UK port. Without a GMR the driver does not check in at the ferry or tunnel — the carrier won't board them.
Import declaration
On arrival, the consignee's customs entry clears the goods. UK imports go through CDS; French imports go through Delta-G. Duty and VAT are calculated at this stage by commodity code, value and origin.
T1 transit
A T1 is a transit document under the Common Transit Convention. It moves goods under bond between customs offices — useful when the routing passes through France into another EU state, or when goods are moving in excise duty suspension to a bonded warehouse.
SPS certification
Animal-origin food and plant-product goods require Health Certificates / Phytosanitary Certificates. Pre-notification on IPAFFS (UK arrival) and TRACES (EU arrival) is required, and the goods are risk-tiered for physical inspection at the border under BTOM.
THE SYSTEMS
What we work with daily.
| System | Side | What it does |
|---|---|---|
| CDS — Customs Declaration Service | UK | HMRC's electronic declaration platform. UK imports and exports flow through CDS. |
| GVMS — Goods Vehicle Movement Service | UK | Generates the GMR that married to a vehicle booking lets the trailer cross the UK border. |
| IPAFFS | UK | Import notification for products of animal origin, plants and high-risk food. Required pre-arrival under BTOM. |
| Delta-G | FR | DGDDI's customs declaration platform. French exports and imports flow through Delta-G. |
| DELTA-T / NCTS | FR / EU | Transit declaration system for T1 / T2 movements under the Common Transit Convention. |
| SI Brexit / Envoi | FR | French smart-border systems integrating exit/entry data with the GVMS / DGDDI flow at the Channel. |
| TRACES | EU | EU notification system for SPS-controlled consignments arriving in the EU. |
THE UK BORDER REGIME
BTOM — what changed and what didn't.
The UK's Border Target Operating Model came into force in stages through 2024 and is now the operating regime for inbound goods. Three things to know:
Risk-tiered SPS controls
Animal-origin and plant products are classified low, medium or high risk. High-risk goods get documentary, identity and physical checks at a Border Control Post. Low-risk goods clear on documentation. The classification is published — we know it before the trailer leaves France.
Pre-notification mandatory
SPS-controlled goods must be pre-notified on IPAFFS before they arrive. The Common User Charge applies on certain consignments arriving via specified ports. We build that into the booking up front.
Safety and Security declarations
S&S declarations on EU-to-UK imports are now required as part of the standard inbound regime. Carrier-supplied data is the standard model; we file these as the freight operator on behalf of the consignor.
VAT & DUTY MECHANICS
Money flows that affect freight planning.
UK side — Postponed VAT Accounting
PVA lets a UK VAT-registered importer account for import VAT on their VAT return instead of paying at the border. This is the default mechanism for most B2B importers and removes a significant cash-flow drag. We declare PVA on the import entry where the consignee has elected it.
UK side — Deferment account
Where PVA is not available (e.g. customs duty rather than VAT, or non-VAT-registered importers), a Duty Deferment Account holds the duty payment and settles monthly. We can declare against the consignee's deferment account on instruction.
FR side — Reverse-charge VAT
French import VAT is accounted for on the consignee's VAT return ("autoliquidation") under the standard mechanism since 2022. The consignee's French VAT number must appear on the import declaration; we cannot self-declare on their behalf.
Rules of origin — UK-EU TCA
Goods that qualify as UK-origin or EU-origin under the Trade and Cooperation Agreement move tariff-free. The consignor declares origin on the commercial invoice. Misdeclared origin attracts retrospective duty assessment; get it right at booking.
SPECIAL CASES
Where the standard route doesn't apply.
- Excise goods (wine, spirits, tobacco, energy products): move in excise duty suspension under EMCS to a French Authorised Tax Warehouse or UK bonded warehouse, with T1 / T2 transit documentation. The consignor or their excise agent is the principal on the bond; we are the carrier.
- Temporary admission: goods entering the UK or France for a defined period (exhibitions, trials, demonstrations) move on ATA Carnet or temporary admission procedure. Re-export must happen within the regulated window or duty becomes payable.
- Inward / outward processing: for cyclical supply chains where goods cross the border for processing and return, IPR / OPR procedures can suspend duty payment. Application is the consignor's; we declare against an approved authorisation.
- Returns: goods returning to the consignor (failed delivery, consumer return, defective stock) move under returned-goods relief or re-importation procedure. The customs treatment is different from a standard outbound and must be declared correctly.
- Sensitive / dual-use goods: certain commodities require export licence approval before they move. The consignor applies for the licence; we cannot ship without it.
One operations team. One file ref. One customs path.
The point of running customs in-house is that the freight team and the customs team can talk to each other instantly. The booking file is open to both; the customs declaration is updated as the operational situation changes. That is the post-Brexit corridor running properly.
Talk to the customs team