
Rules and ethics
Ecommerce platform comparison criteria for GB, EU and NI
Compare ecommerce platform support for GB, EU and Northern Ireland sales with a route-by-route matrix covering customs, EORI, VAT, product marking and returns.
What to take away
- An ecommerce platform does not have one post-Brexit settingit has three, one each for GB, EU and Northern Ireland destinations.
- GB to EU sales need export declarations, an EU import declaration and EU import VAT, usually handled by the buyer or a marketplace.
- GB to Northern Ireland movements use the Windsor Framework green lane or UK internal market scheme, not a full EU customs entry.
- Northern Ireland to EU sales are distance sales, with VAT reported and paid through the One Stop Shop non-Union scheme.
- EORI numbers, the Customs Declaration Service and product marking are configured per route, not once for the whole shop.
- Platform checklists should cover seller identity, checkout, data, shipping rules and returns before launch.
Route requirements to compare across GB, EU and Northern Ireland
A single checkout can look uniform to the shopper and still need three different back ends. The destination decides which declaration, VAT rule and product marking applies. Treat GB, the EU and Northern Ireland as separate routes when comparing ecommerce platform settings, and check what each platform can support for each destination.
Three Post-Brexit Sales Routes
GB
- Customs position
- UK customs territory
- VAT rule
- UK VAT
- Product marking
- UKCA
- Evidence trail
- HMRC export evidence
EU
- Customs position
- EU customs union
- VAT rule
- Import VAT or OSS
- Product marking
- CE
- Evidence trail
- EU import VAT accounted
Northern Ireland
- Customs position
- UK customs, EU goods rules
- VAT rule
- UK VAT as domestic
- Product marking
- CE under EU rules
- Evidence trail
- Lane and UKIMS reference
Great Britain and Northern Ireland together form the United Kingdom, but they sit in different customs positions. Great Britain means England, Scotland and Wales. Northern Ireland is part of the UK customs territory yet stays aligned with EU goods rules under the Windsor Framework.
That split is why a Belfast seller and a Manchester seller can ship to the same Dublin address under different paperwork.
For platform configuration, the route is set by the delivery address, not by the seller's registered office. A London merchant selling to Belfast is moving goods into Northern Ireland. A Belfast merchant selling to Dublin is making a distance sale into the EU. A Glasgow merchant selling to Paris is exporting from GB and importing into the EU.
Each route carries its own evidence trail. HMRC wants export evidence for zero-rated GB exports. EU tax authorities want import VAT accounted for at the border or through the importer's own return. Northern Ireland movements need the correct lane and, where used, a UK internal market scheme reference.
Most platform problems start when a seller applies one rule to all three. A single shipping zone called "Europe" will hide the difference between an EU destination and Northern Ireland, and the wrong VAT or declaration will follow.
When you judge channel options, weigh direct, marketplace and partner routes on equal evidence, because marketplaces often absorb customs and VAT handling that a direct store must build itself.
Compare customs declarations, duties and tariffs by destination
Customs declarations, duties and tariffs are the first capability area to compare, and they differ by direction. The GOV.UK guidance on customs declarations, duties and tariffs sets out the declaration, duty and tariff rules that apply to imports and exports, including the data a platform or agent must collect before a shipment moves.
Customs Declarations by Direction
- GB to EU: export declaration then EU import declaration
- EU to GB: UK import declaration and import VAT
- GB to NI: green lane or red lane under Windsor Framework
- EU importer pays EU import VAT and duty
- GB importer pays UK import VAT and duty
Sellers in Great Britain and Northern Ireland trade inside one UK customs territory, yet Northern Ireland also applies EU goods rules at its ports, so the same parcel can need two treatments on a single movement.
For GB to EU sales, the goods leave Great Britain under an export declaration and enter the EU under an import declaration. The EU importer, which may be the buyer, pays EU import VAT and any duty. Many platforms offer a delivered duty paid option, where the seller or marketplace becomes the importer of record.
For EU to GB sales, the reverse applies. The GB importer pays UK import VAT and duty, and the seller needs a commercial invoice that supports the declaration. Low-value consignments have their own relief rules, so check the current threshold rather than assuming a blanket exemption.
For GB to Northern Ireland, the Windsor Framework creates a green lane for goods staying in Northern Ireland and a red lane for goods at risk of moving into the EU. Qualifying traders use the UK internal market scheme to move goods as if they were staying in the UK internal market.
For Northern Ireland to GB, goods move within the UK customs territory, but some controlled goods and parcels still need declarations. Food, plants and some animals face additional checks under the Northern Ireland retail movement scheme and similar arrangements.
Tariff codes matter on every route. A wrong commodity code changes the duty rate and can trigger a customs query. Platforms that store a single HS code per product will fail when the same item attracts different treatment by destination.
Build a shipping matrix that records, per destination: declaration type, importer of record, duty payer, VAT payer and returns route. That matrix is the real customs configuration, not the carrier label.
EORI, the Customs Declaration Service and export steps to compare
An EORI number is the identifier customs systems use to recognise a trader. GOV.UK explains who needs an EORI number, and the answer for most cross-border sellers is that they need one for the country where they lodge declarations.
Export Sequence for Platforms
- Confirm destination route and declaration type
- Validate seller and importer EORI numbers
- Capture commodity codes, values, weights, origin
- Generate commercial invoice for declaration
- Map order data to Customs Declaration Service dataset
A GB seller needs a GB EORI to export from Great Britain. An EU EORI is needed to act as importer in an EU member state, or to recover EU import VAT. Northern Ireland traders may hold an XI EORI, which starts with XI rather than GB, to move goods under the Windsor Framework arrangements.
Without a valid EORI, a declaration cannot be lodged and the shipment stalls at the border. Platforms should validate the format, store it against the seller record, and surface it at checkout or in the fulfilment step where the carrier needs it.
The Customs Declaration Service is HMRC's system for lodging customs declarations. It replaced the older CHIEF system for imports and exports, and software or a customs agent must be compatible with it. A platform that exports order data to a freight system should map fields to the Customs Declaration Service dataset.
A workable export sequence looks like this:
EORI and Customs Declaration Service
- Confirm the destination route and the correct declaration type.
- Validate the seller's EORI and, where relevant, the importer's EORI.
- Capture commodity codes, values, weights and country of origin per line.
- Generate a commercial invoice and packing list that match the declaration.
- Lodge the declaration through the Customs Declaration Service, directly or via an agent.
- Keep the movement reference number and export evidence for HMRC records.
- Reconcile the declaration against the order and the carrier tracking.
Steps four to seven are where most manual errors appear. A platform that cannot export line-level data forces rekeying, and rekeying creates mismatches between the invoice and the declaration.
If you are weighing build versus buy, put every option through the same whole-life register, because customs software, agent fees and declaration volumes are running costs, not one-off setup fees.
Compare VAT treatment on GB, EU and NI sales, including distance sales from Northern Ireland
VAT is the second configuration layer and the one most likely to be wrong at launch. The treatment depends on where the goods are, where the customer is and who is the supplier of record.
VAT Treatment by Route
GB to EU
- UK VAT
- Zero-rated with evidence
- Import VAT
- EU import VAT
- Who reports
- Importer or DDP seller
EU to GB
- UK VAT
- Import VAT applies
- Import VAT
- UK import VAT
- Who reports
- Importer or deemed supplier
GB to NI
- UK VAT
- UK VAT charged
- Import VAT
- None
- Who reports
- Seller as domestic
NI to EU
- UK VAT
- Distance sale rules
- Import VAT
- EU destination rules
- Who reports
- Seller via OSS non-Union
For goods, Great Britain and Northern Ireland sit inside the same UK VAT area, which is why a GB seller charges UK VAT to a Belfast customer instead of zero-rating the sale as an export.
For GB to EU sales, the export is generally zero-rated in the UK when valid export evidence is held. The EU import is subject to import VAT, paid by the importer or under a delivered duty paid arrangement.
Since the EU's ecommerce VAT package, most business-to-consumer imports are taxed at the point of sale, which pushes the obligation onto the seller or marketplace.
For EU to GB sales, UK import VAT applies. Where the seller is a non-established taxable person, the platform or marketplace may be the deemed supplier for VAT purposes, depending on the business model. That rule changes who reports the VAT, so it belongs in the platform's tax logic, not in a spreadsheet.
For GB to Northern Ireland sales, UK VAT applies as it would for a domestic sale. The Windsor Framework keeps Northern Ireland inside the UK VAT area for goods, so a GB seller charges UK VAT and does not zero-rate the sale as an export.
For Northern Ireland to EU sales, the position is different again. These are distance sales from Northern Ireland to the EU, and GOV.UK explains how to report and pay VAT on those sales, including the One Stop Shop non-Union scheme.
The seller registers in an EU member state and files one return covering all EU destinations.
Northern Ireland to GB sales are domestic UK supplies for VAT, so UK VAT applies and no export zero-rating is available. The customs position may still require a declaration for certain goods, but the VAT line is straightforward.
Platforms need VAT rules that read the delivery address, the seller's establishment and the goods value. A single VAT rate per country will misprice Northern Ireland, because it is not an EU destination for UK VAT and not a plain domestic destination for customs.
Keep the audit trail. HMRC expects export evidence for zero-rated sales, and EU tax authorities expect import records. A platform that stores order, invoice and declaration data together makes both checks survivable.
Compare platform handling of Windsor Framework routes
The Windsor Framework governs how goods move in and out of Northern Ireland after Brexit. GOV.UK's guidance on trading and moving goods in and out of Northern Ireland explains the green lane, the UK internal market scheme and the parcels arrangements.
Green Lane or Red Lane?
Are the goods staying in Northern Ireland?
green lane, minimal checks
red lane, full EU customs procedures
These arrangements apply to Belfast and other NI merchants selling to GB and the EU.
The central idea is a dual lane. Goods staying in Northern Ireland use the green lane and face minimal checks. Goods at risk of entering the EU use the red lane and face full EU customs procedures. The risk assessment is based on the trader's status and the nature of the goods.
To use the green lane, a trader generally needs to be authorised under the UK internal market scheme. That authorisation requires a GB or XI EORI, a record of the goods and a commitment to keep them in Northern Ireland or move them under the correct procedure.
For parcels, the framework introduced a new model. Parcels from Great Britain to Northern Ireland are treated differently depending on whether they are business-to-business or business-to-consumer, and whether the recipient is a business or a consumer. Platforms that ship parcels need to capture the right data at checkout, including the recipient type.
Goods moving from Northern Ireland to GB face fewer formalities, but agri-food and some other categories still need specific handling. The Northern Ireland retail movement scheme allows qualifying goods to move to GB with simplified requirements.
For a Belfast merchant selling to Dublin, the sale is a distance sale into the EU, so EU VAT and EU product rules apply. For a Belfast merchant selling to Manchester, the sale is a UK domestic sale, so UK VAT applies. The platform must not treat both as the same export.
Configuration points for the Windsor Framework route:
- Record the trader's UK internal market scheme authorisation number.
- Tag products that are at risk of moving into the EU.
- Capture recipient type for parcels, business or consumer.
- Apply UK VAT for GB-bound sales and EU VAT rules for EU-bound sales.
- Keep green lane and red lane evidence separate in the order record.
- Review controlled goods and agri-food rules before enabling the route.
Compare product-marking requirements for cross-border own-brand goods
Product marking is the third configuration layer, and it applies to own-brand goods rather than to resold third-party stock. GB product marking means the UKCA marking regime for most manufactured goods placed on the GB market, as set out in GOV.UK's guidance on placing manufactured products on the market in Great Britain.
Product Marking by Destination
GB
- Default mark
- UKCA
- Responsible person
- UK-based
- CE accepted?
- Limited period
- UKCA accepted?
- Yes
EU
- Default mark
- CE
- Responsible person
- EU-established
- CE accepted?
- Yes
- UKCA accepted?
- No
Northern Ireland
- Default mark
- CE
- Responsible person
- EU rules apply
- CE accepted?
- Yes
- UKCA accepted?
- Not default
For GB, the UKCA marking is the default conformity mark for many product categories. Some EU CE markings continue to be accepted for a limited period in specific areas, so check the current position by product type rather than assuming a permanent extension.
For the EU, the CE marking remains the mark for goods placed on the EU market. A product sold into Dublin needs CE marking and an EU responsible person where the rules require one. That responsible person is usually an EU-established business, and their details must appear on the product or packaging.
For Northern Ireland, goods follow EU rules under the Windsor Framework. That means CE marking for most regulated products, and the UKCA marking is not the default there. A single product line can therefore need different marking depending on whether it ships to GB, the EU or Northern Ireland.
Own-brand sellers should map each product against the destination market's conformity route. The Office for Product Safety and Standards enforces many of these rules in GB, and the Competition and Markets Authority and Advertising Standards Authority also police claims made at the point of sale.
Platforms can help by storing marking data per product and per destination. A field for UKCA, CE and responsible person details prevents the wrong label being printed for the wrong market. It also supports the product safety information that marketplaces increasingly require.
Returns are part of the same picture. A returned own-brand item may need to be re-declared on re-import, and the marking must still match the market it re-enters. Build the returns path into the same matrix as the outbound route.
Before launch, run a platform entry checklist covering seller identity, checkout, data, accessibility and exit, because conformity and customs records are only useful if the shop can produce them on demand.
Use a GB, EU and NI setup matrix to compare ecommerce platforms
To compare shortlisted platforms, run the same destination and order scenarios through each one. Record whether each requirement is handled in its settings, by an integration or manually, and keep evidence; the table gives the route requirements to test, not vendor results. It is a starting point, not legal advice, and the exact treatment depends on the goods and the business model.
Platform Setup Matrix
GB destination
- Customs declaration
- None domestic; import if outside
- EORI
- GB EORI for importing
- VAT
- UK VAT
- Product marking
- UKCA
- Returns
- Domestic return
EU destination
- Customs declaration
- Export plus EU import
- EORI
- GB export, EU import
- VAT
- Zero-rated export; EU import VAT
- Product marking
- CE and EU responsible person
- Returns
- Re-import and duty relief
Northern Ireland destination
- Customs declaration
- Green or red lane
- EORI
- GB or XI plus UKIMS
- VAT
- UK VAT as domestic
- Product marking
- CE under EU rules
- Returns
- Return under correct lane
Ecommerce platform setup matrix
GB destination
- Customs declaration
- None for domestic; import declaration for goods arriving from outside GB
- EORI
- GB EORI for importing
- VAT
- UK VAT
- Product marking
- UKCA for many goods
- Returns
- Domestic return
EU destination
- Customs declaration
- Export from GB plus EU import declaration
- EORI
- GB EORI to export; EU EORI to import
- VAT
- UK zero-rating on export with evidence; EU import VAT or OSS
- Product marking
- CE marking and EU responsible person
- Returns
- Re-import declaration and possible duty relief
Northern Ireland destination
- Customs declaration
- Green lane or red lane under the Windsor Framework
- EORI
- GB or XI EORI, plus UK internal market scheme authorisation for green lane
- VAT
- UK VAT, as a domestic supply
- Product marking
- CE marking under EU rules
- Returns
- Return under the correct lane
For sales from Northern Ireland to the EU, the matrix changes: the seller uses the One Stop Shop non-Union scheme and reports distance sales VAT in one EU return. For sales from Northern Ireland to GB, the sale is domestic for VAT and uses UK rules.
A worked example makes the differences concrete. A Leeds seller of own-brand lamps ships one order to Belfast, one to Dublin and one to Manchester.
Ecommerce platform setup matrix
- The Belfast order is a GB to Northern Ireland movement. It uses the green lane if the seller is authorised, charges UK VAT and carries CE marking for the Northern Ireland market.
- The Dublin order is a GB export and an EU import. It is zero-rated in the UK with export evidence, and the EU import VAT is paid by the importer or under a delivered duty paid arrangement. The lamp needs CE marking and an EU responsible person.
- The Manchester order is a domestic UK sale. It charges UK VAT and uses UKCA marking for the GB market.
One product, three setups. A platform that cannot store destination-specific marking, VAT and declaration data will force manual workarounds, and manual workarounds are where compliance fails.
Review the matrix each time the rules change, and keep the evidence with the order. HMRC, EU tax authorities and market surveillance bodies all ask for records after the sale, not before it.



