On 31 December 2021, the Brexit transition period ended, and new customs and tax rules came into force in both the UK and the EU.

There is now greater awareness that UK businesses trading with the EU need an Economic Operator Registration and Identification (EORI) Number. But one question which was until recently unclear is whether businesses need both a UK and an EU EORI number.

So, does my business need both a UK and an EU EORI number?

Maybe. If your business only deals with import or export declarations in the UK, with a customer/client completing the equivalent declaration on the EU side of the border, then you only need a UK EORI number. If you are registered for UK VAT, a UK EORI number should already have been assigned to you by HMRC. Contact HMRC if you have not received details of it.

If you are not registered for UK VAT, you should register for a UK EORI number now.

However, if your business is responsible for completing both the export declaration as goods leave the UK, as well as the import declaration when the goods are imported into the EU, you will need both a UK and an EU EORI number. This will include situations where you are the importer of record in the EU as well as being the exporter from the UK, for example a UK business with a branch in the EU. It could also include UK businesses who import goods into the EU on consignment or call-off stock contracts.

The European Commission published guidance in March 2019 confirming that UK EORI numbers will not be valid in the EU post-Brexit. The Commission also invited businesses with a UK registered EORI number to apply to the relevant EU customs authority for an EU EORI number that activated upon the UK leaving the EU. In practice not all EU customs authorities actually followed this guidance, with economic operators reporting refusals from authorities, such as Germany, to issue a number until after Brexit.

Businesses can now request EU EORI numbers from the EU member state in which they are established, or from the EU member state in which they first lodge a declaration or apply for a decision.