Ireland–UK Customs After Brexit: A Practical Guide

A New Border for an Old Trading Relationship

When the United Kingdom left the EU Single Market and Customs Union on 1 January 2021, the Republic of Ireland and Great Britain became separate customs territories for the first time in nearly fifty years. Goods moving between Dublin/Cork/Rosslare and Holyhead/Liverpool/Pembroke now cross a full customs border — even though the UK and EU agreed zero-tariff trade under the Trade and Cooperation Agreement (TCA).

For Irish exporters and UK importers (and vice versa), this means paperwork, declarations, and — for some goods — physical checks.

The Three Routing Options

Irish exporters now have three main ways to get goods to British customers:

1. The Land Bridge (Dublin → Holyhead → GB → Continental EU)

The traditional route. Trucks board the ferry at Dublin Port, land at Holyhead, drive across Wales and England, and either deliver in GB or exit via Dover to continental Europe. Two customs movements are now required: a GB import (or transit) declaration, and — if the goods continue to the EU — an EU re-entry declaration.

2. Direct Ireland–EU Sailings (Rosslare/Dublin → Cherbourg/Dunkirk/Zeebrugge)

After Brexit, ferry operators massively expanded direct routes from Ireland to France, the Netherlands and Belgium. These bypass GB entirely and keep goods inside the EU Single Market end-to-end — no GB customs required, just normal EU intra-community movement.

3. GB-Only Imports (Ireland → GB)

For goods destined for British customers, this is a single GB import declaration via CDS. The exporter (or their agent) prepares the entry; the importer is responsible for duty, VAT and any licences.

What Documents Do You Need?

For every Ireland → GB shipment:

Commercial invoice (with EORI numbers of seller and buyer, incoterm, commodity codes, value)
Packing list
CMR waybill (road) or bill of lading (sea)
Statement on origin (REX number) — required to claim 0% TCA duty
GMR — Goods Movement Reference from GVMS, generated before the truck boards the ferry
Health/phytosanitary certificates — for agri-food goods (these are now staged through 2024–2025 under the UK BTOM rules)

The Trade and Cooperation Agreement (TCA)

The TCA gives zero tariffs on goods of UK or EU origin — but the goods must actually originate in the UK or EU under the agreement's product-specific rules. Goods that don't qualify (for example, fully manufactured outside the UK/EU and merely shipped from Ireland) are subject to the UK Global Tariff.

Many traders lose preferential rates because they don't hold the right origin documentation. A statement on origin from the exporter, referencing a valid REX number, is what HMRC will look for.

Northern Ireland Is Different

Movements from Great Britain to Northern Ireland (and from the Republic of Ireland to Northern Ireland) follow the Windsor Framework — a green-lane / red-lane system, with the Trader Support Service (TSS) handling most declarations free of charge. We cover that in a separate guide.

How We Help

Whether you are an Irish manufacturer sending pallets to a British customer, or a UK importer bringing in Irish dairy or pharma, we prepare and submit your declarations end-to-end. We hold both GB EORI access and an EU EORI registration in Ireland, so we can clear shipments in both directions without you needing two brokers.