Compliance guidance. Read on 7 November 2026 from the UK-EU Trade and Cooperation Agreement as published, GOV.UK guidance and VAT Notice 703. The EU import side, member-state VAT, Incoterms and the EU deforestation rules were not read. Rules change: confirm with a customs broker, HMRC or the EU importer. This is guidance, not customs, tax or legal advice. Nothing here says what origin, route or documents any Make Bespoke Studio order or partner workshop’s goods have: ask each partner in writing.

At a glance

Document or stepWhoWhat it doesSource read
GB EORI numberExporter, or the agent for itYou need an EORI number starting GB to export from England, Wales or Scotland.GOV.UK export guidance
Commodity codeExporterYou must find the right code for the goods. A customs agent or transporter may help.GOV.UK export guidance; see the commodity codes sheet
Commercial invoiceSellerShows the selling price; freight and export insurance included in the price are listed separately. The invoice and any licences or certificates travel with the goods.GOV.UK export guidance
Packing listSeller or packerWhat is in each package, with weights and marks, so customs and the buyer can match the goods to the invoice.Trade practice; not in the GOV.UK pages read
Export declarationExporter or agentMade on the Customs Declaration Service; the old CHIEF system has taken no declarations since July 2024. Describing goods inaccurately may bring a customs penalty.VAT Notice 703, paras 5.1, 6.5
Statement on originUK exporterPrescribed text on the invoice or another document, with the exporter’s EORI number, place and date. For exports to the EU it is valid for 12 months. Keep it and the supporting records for 4 years.GOV.UK: proving originating status
Proof of exportSellerOfficial or commercial evidence that the goods left the UK, to support a VAT zero rate. Export and evidence within 3 months of the time of supply. Keep for 6 years.VAT Notice 703, paras 3.5, 6.2, 6.3, 6.7
CITES permitExporterA permit is needed to move a specimen of a listed species, or an item made from one, into or out of Great Britain, and the other country’s authority must issue its own.GOV.UK CITES guidance
EU import declaration and VATEU importerMade in the destination country. Not covered by the GOV.UK pages read.Not read: ask the EU importer

The UK-side steps from GOV.UK guidance and VAT Notice 703, read 7 Nov 2026. The packing list row is trade practice. The EU side was not read: ask the EU importer.

Does UK-made furniture get zero duty into the EU?

Only if it qualifies. GOV.UK says goods get a reduced customs duty rate only if they are “sufficiently worked or processed” in the UK or EU, and that the importer must claim preference on the import declaration and hold proof of origin. Goods that do not claim preference pay the importing country’s ordinary tariff. The test has five steps:

StepWhat the sources sayWhere
1. CodeFind the commodity code. The origin rule is set by chapter, then by the change of heading.TCA product-specific rules (Annex 3)
2. RuleFurniture, lights (chapter 94) and wood (chapter 44): a change of heading, or non-originating materials of no more than 50% of the ex-works price. Stone articles (chapter 68): a change of heading, or no more than 70%.TCA Annex 3, chapters 94, 44, 68
3. Enough workThe work in the UK must go beyond ‘insufficient production’. The list includes simple assembly of parts into a complete article, simple painting and polishing, sorting and grading, and affixing labels. Operations are simple if neither special skills nor machines especially produced or installed are needed.TCA Article 43
4. Cumulation and giveOriginating materials from the EU count as UK in UK production, and the reverse (bilateral cumulation, Article 40). A tolerance of 10% of the ex-works price can rescue a failed change-of-heading test, but not a percentage limit that is exceeded (Article 42).TCA Articles 40, 42
5. Statement and claimThe UK exporter makes a statement on origin, holding the evidence first, or the EU importer claims preference on its own knowledge. Records are kept 4 years.GOV.UK proving originating status

The GOV.UK guide works through a wooden table (heading 9403, rule MaxNOM 50%). A desk assembled in the UK from a non-originating top and non-originating legs, where the non-originating materials are 40% of the ex-works price, meets the percentage rule but is not originating if simple assembly is the only UK processing, even if the parts came from the EU, because cumulation cannot apply. Fix the same desk with UK-originating legs and it counts as UK-originating.

Ex-works price is the price paid to the producer in whose business the last working or processing is carried out, including the value of all materials and other costs of production. The percentage is non-originating materials divided by that price. Bespoke work often passes the percentage test and fails on the work: imported kits that a workshop only assembles, finishes and polishes are the risk. Make Bespoke Studio coordinates manufacture through partner workshops, and nothing here says that any partner’s goods are originating. Ask each partner for its origin position, in writing, with its materials list.

The origin test in plain languageFour steps. One, find the commodity code. Two, check the product-specific rule for that chapter: a change of heading, or no more than 50 per cent non-originating materials for furniture and wood, 70 per cent for stone articles. Three, check that the work in the UK went beyond insufficient production such as simple assembly. Four, the exporter makes a statement on origin and the importer claims preference.1CodeFind the commoditycode for the item2RuleMeet the product-specific rule forits chapter3WorkUK work goes beyond'insufficientproduction'4ClaimStatement on originby the exporter;importer claimsChapters 94 (furniture, lights) and 44 (wood): a change of heading, OR non-originatingmaterials of no more than 50% of the ex-works price. Chapter 68 (stone articles): a changeof heading, OR no more than 70%. A 10% tolerance can rescue a failed change-of-headingtest, but not a percentage limit that is exceeded.Zero duty is a claim backed by evidence, not a feature of UK-made goods.Product-specific rules read at chapter level from Annex 3 of the TCA; a broker checks the heading.
The origin test in plain language. Product-specific rules are read at chapter level; a broker checks the heading. Original drawing by Make Bespoke Studio.

The documents that travel with the goods

The table at the top lists each document. A few points on how they fit together:

  • The invoice carries the origin statement. GOV.UK describes a statement on origin as prescribed text added to the invoice or another document that identifies the goods; it can be electronic. A UK exporter uses its EORI number as its reference. For exports to the EU the statement is valid for 12 months. The exporter must hold the evidence before issuing it, and must tell the customer at once and in writing if it later finds it was wrong.
  • An exporter can rely on the importer’s knowledge instead. The importer may claim preference from its own knowledge that the goods originate; it may need production information from the exporter.
  • Agents can do the work, not carry the responsibility. You may appoint a freight forwarder to make export declarations, but responsibility for following the rules stays with you (VAT Notice 703, para 2.5).
  • Restricted goods need more. Any licence or certificate travels with the goods (GOV.UK export guidance).
Which paper travels, and who holds itFour stages from left to right: UK seller, UK border, carrier and EU border, EU buyer. Under each, the documents: invoice with origin statement and EORI, export declaration, proof of export for the VAT zero rate, and the EU import declaration and import VAT.UK sellerCommercial invoicePacking listCommodity codesStatement on originGB EORI numberUK borderExport declaration(Customs DeclarationService)Licences, CITESpermit if listedIn transitTransport documentProof of export:keep 6 years forthe VAT zero rateEU sideImport declarationby the EU importerOrigin claimImport VAT, any dutyThe EU importer and its country's rules decide the right-hand column. The UK-side steps are in GOV.UK guidance; the EU side was not read.Northern Ireland has different rules (not covered here).
Which paper travels with the goods, and who holds it. The EU column was not read. Original drawing by Make Bespoke Studio.

VAT: the UK side, and who is the importer

UK zero rate. VAT Notice 703 says supplies of exported goods are zero-rated if its conditions are met. Goods are normally treated as supplied where they are when supplied; goods in Great Britain sent to an EU destination follow the export rules of the notice. The conditions include obtaining and keeping evidence of the supply and of export, official (an export declaration) or commercial (transport documents), and exporting the goods and getting the evidence within 3 months of the time of supply. The time of supply is normally the earlier of dispatch and full payment, and the notice deals with deposits and progress payments separately. Keep the proof of export for 6 years. If the conditions are not met the supply is not zero-rated and UK VAT is due.

Goods you install abroad. The notice says you need not account for UK VAT if you supply and export goods that you are to install outside the UK, because the supply takes place in the country where they are installed. You still keep proof of export. VAT in the destination country, which may include registration or a reverse charge there, was not read: take advice there.

Who is the importer. The EU declaration, the import VAT and any duty fall on the person named as importer in the destination country. A contract that says only “delivered” leaves it open. Name the EU importer, and say who obtains the origin evidence and who pays duty and import VAT. The Incoterms rules for allocating this are not covered here.

Timber, CITES and packaging

CITES. GOV.UK says you must apply for a permit to move a CITES specimen into or out of Great Britain, including to the EU, and that a specimen includes an item made from a listed animal or plant. You must also get the other country’s permit. A permit is needed for any species listed in Annex A, B or C. Moving listed specimens without a valid permit can lead to up to 7 years in prison, an unlimited fine or both. Check the timber species against Species+ before shipping.

Timber rules. Separate EU rules on products linked to deforestation may apply to wooden furniture, and their dates have moved. They are not covered here: ask the EU importer. On the UK side see UK Timber Regulation due diligence. Wooden crates and pallets raise packaging questions: see packaging and crating specification, and for glass lighting packing and shipping glass chandeliers.

Northern Ireland has different rules for moving goods to and from the EU and is not covered.

Specification wording

Paste into your schedule or specification and replace anything in [square brackets] with your own figures. Wording is a starting point: your specification governs.

Origin
The Supplier states, before order, whether each item is originating in the United Kingdom under the UK-EU Trade and Cooperation Agreement, with the basis [change of heading / maximum [50]% non-originating materials of the ex-works price] and a list of non-originating materials with their share of the ex-works price. Where it is, the Supplier makes out a statement on origin on the commercial invoice, holds the supporting records for [4] years and tells the Designer at once if the statement is found to be wrong.
Documents
For each shipment the Supplier provides before dispatch: commercial invoice with commodity codes and country of origin; packing list; statement on origin where claimed; [CITES permit where a listed species is used]; and, after export, the proof of export. The Supplier keeps the export evidence for [6] years. A change of material, workshop, route or importer that affects origin or the code requires written notice before shipment.
Importer and costs
The EU importer of record is [name, address, EORI or VAT number]. [The Buyer / The Supplier] is responsible for the import declaration, any duty and import VAT in [country]. Delivery terms: [ ]. Any installation in [country] is a separate supply and is [ ].

Terms used on this page

Statement on origin
A declaration, usually on the invoice, that goods qualify as originating in the UK under the UK-EU trade agreement so they can enter the EU at zero duty. It is only valid if the goods actually meet the origin rules.
Originating
Goods that qualify for the reduced or zero duty rate under the UK-EU agreement because they are wholly obtained, or sufficiently worked or processed, in the UK or the EU.

All specification and delivery terms

Standards and sources

Questions we are asked

Is UK-made furniture duty-free in the EU?

Only if the goods are originating under the UK-EU agreement and the claim is supported by a statement on origin or the importer's knowledge. For furniture the rule is a change of heading or no more than 50% non-originating materials of the ex-works price, and the UK work must be more than simple assembly.

What is a statement on origin?

Prescribed text the exporter adds to the invoice or another document, with the exporter's EORI number, a place and a date. For exports to the EU it is valid for 12 months. The exporter must hold the evidence first and keep records for 4 years.

Do I need an EORI number?

To export from England, Wales or Scotland you need an EORI number starting GB, according to GOV.UK. It is also the exporter reference on a UK statement on origin.

Do I charge UK VAT on furniture sent to the EU?

Not if the export conditions in VAT Notice 703 are met: evidence of the supply and of export, and export and evidence within 3 months of the time of supply. If they are not met, UK VAT is due. Goods you install abroad are a supply where they are installed, so check the destination country's VAT rules.

Who pays EU import VAT and duty?

The importer in the destination country. Name the importer in the contract and say who pays. We did not read the EU rules or the Incoterms: ask the EU importer.

Do protected hardwoods need a permit?

A CITES permit is needed to move a specimen of a species listed in Annex A, B or C, including items made from one, into or out of Great Britain, and the other country's permit is also needed. Check the species on Species+.

Is a UK workshop that assembles imported parts originating?

Not on assembly alone. The agreement lists simple assembly of parts into a complete article as insufficient production, and the GOV.UK guide gives a table example where simple assembly of non-originating parts is not enough.

Download the factsheet

A two-page A4 PDF with the document table, the origin-test drawing and paste-in clauses, to keep with your project file.

Factsheet TL-SPE-41 v1.0 (PDF)