Post-Brexit Trade: How Polish Businesses Can Navigate the UK Market Successfully

Reading time: 12 minutes

Introduction: The New Trading Landscape

Feeling overwhelmed by the post-Brexit trading environment between Poland and the UK? You’re certainly not alone. Since the UK’s departure from the European Union on January 31, 2020, and the end of the transition period on December 31, 2020, Polish businesses have faced a radically transformed trading landscape.

The UK-EU Trade and Cooperation Agreement (TCA) established the foundation for the new relationship, but translating this complex agreement into practical business operations has proven challenging for many Polish entrepreneurs and established companies alike.

Let’s face the reality: successful UK-Poland trade is no longer about frictionless transactions—it’s about strategic navigation through a complex web of regulations, customs procedures, and documentation requirements.

Consider this striking shift: Prior to Brexit, trade between Poland and the UK reached €16.6 billion in 2019, with Poland enjoying a significant trade surplus. By 2021, despite the challenges of both Brexit and the pandemic, bilateral trade had recovered to €16 billion, demonstrating resilience but requiring substantial adaptation by businesses on both sides.

This article offers a practical roadmap for Polish businesses looking to maintain or establish profitable trading relationships with the UK. We’ll transform complexity into competitive advantage, helping you navigate the post-Brexit commercial environment with confidence.

Key Regulatory Changes Affecting Polish-UK Trade

The regulatory landscape between Poland and the UK has undergone seismic shifts. Here’s what you need to understand at the foundational level:

From Single Market to Third Country Status

Perhaps the most fundamental change is the UK’s shift from EU Single Market member to “third country” status. This transformation means Polish businesses must now contend with:

• Border controls – Physical checks on certain goods
• Customs declarations – Required for all commercial shipments
• Rules of origin verification – Determining whether goods qualify for zero tariffs
• Regulatory divergence – The UK is developing its own regulatory framework

As noted by Dr. Marek Prawda, former Polish Ambassador to the EU: “The greatest challenge for Polish businesses is not just understanding the TCA, but navigating the ongoing regulatory developments as the UK establishes its own systems separate from the EU framework.“

Product Standards and Conformity Assessment

The UK has introduced its own product marking system, replacing the familiar CE mark with the UKCA (UK Conformity Assessed) mark. This transition creates significant challenges:

For products requiring third-party conformity assessment, Polish manufacturers must now:

1. Use a UK-recognized conformity assessment body for UKCA marking
2. Maintain CE marking for products sold in the EU/EEA
3. Navigate dual certification processes and costs

Quick Scenario: Consider a Polish furniture manufacturer exporting office chairs to both EU countries and the UK. Prior to Brexit, a single conformity assessment process with CE marking sufficed for all markets. Now, this company must maintain CE certification for EU sales while also pursuing UKCA marking through a UK-recognized body for their British market.

Navigating Customs Procedures and Documentation

The reintroduction of customs formalities represents one of the most immediate and tangible challenges for Polish exporters to the UK.

Essential Documentation Requirements

Polish businesses must now prepare and submit an array of customs documentation:

1. Commercial Invoice – Including detailed product descriptions, HS codes, and values
2. Customs Declaration – Using the Single Administrative Document (SAD)
3. Rules of Origin Documentation – Statement on origin or importer’s knowledge
4. Export Licenses – For controlled or restricted goods
5. Safety and Security Declarations – Entry Summary Declaration (ENS)

Pro Tip: Don’t underestimate the complexity of rules of origin documentation. Under the TCA, goods must meet specific origin criteria to qualify for zero tariffs. This often requires detailed supplier declarations and thorough understanding of cumulation provisions.

Streamlining Your Customs Approach

While customs procedures can’t be avoided, they can be optimized:

• Consider AEO status – Authorized Economic Operator certification can streamline customs processes
• Evaluate postponed VAT accounting – The UK allows import VAT to be declared and recovered on the same VAT return
• Implement digital solutions – Customs management software can reduce errors and delays
• Work with experienced partners – Customs brokers and freight forwarders with UK expertise can navigate complexities

As Tomasz Nowak, Export Director at a leading Polish food manufacturer, explains: “We initially struggled with customs delays that threatened our just-in-time delivery promises. Investing in AEO certification and specialized customs software reduced our clearance times by 62%, saving both cost and maintaining customer relationships.“

Understanding Tariffs and Trade Preferences

While the TCA provides for zero tariffs and quotas on goods meeting origin requirements, the reality is more nuanced and requires careful attention.

Rules of Origin Requirements

To benefit from zero tariffs, goods must satisfy product-specific rules of origin. These rules determine whether a product originates in the EU (including Poland) or the UK for preferential treatment purposes:

• Wholly obtained products – Entirely obtained or produced in Poland
• Substantially transformed products – Non-originating materials sufficiently processed in Poland
• Value-added thresholds – Many products must contain a minimum percentage of EU/UK content

Let’s examine the practical implications through a comparative table:

Proving Origin for Preferential Treatment

Polish exporters must substantiate origin claims through one of two methods:

1. Statement on origin – Made by the exporter on a commercial document
2. Importer’s knowledge – The UK importer possesses evidence of origin

Remember: Origin claims are subject to verification. Maintain comprehensive records for at least four years after export to support any origin claims made.

Adapting Your Supply Chain

Brexit has necessitated fundamental reconsideration of supply chain structures for Polish businesses trading with the UK.

Supply Chain Vulnerabilities and Solutions

Polish companies face several critical supply chain challenges:

• Extended lead times – Customs clearance adds 1-3 days on average
• Inventory management pressure – Buffer stocks now necessary
• Increased working capital requirements – Duties, VAT, and additional inventory
• Transport capacity constraints – Fewer carriers willing to service UK routes

Practical solutions include:

1. Establish UK distribution facilities – Consider warehousing in the UK to mitigate border delays
2. Implement consignment stock arrangements – Maintain ownership until goods are used
3. Diversify logistics partners – Don’t rely on a single transport solution
4. Review Incoterms® – Consider DDP (Delivered Duty Paid) terms to simplify customer experience

As Maria Kowalska, Supply Chain Director at a Polish electronics manufacturer, advises: “We’ve transformed our UK business model by establishing a distribution hub in Manchester. This single change reduced our delivery times to UK customers from 7-10 days to 24-48 hours, offsetting the initial investment within nine months through increased sales.“

Success Stories: Polish Businesses Thriving Post-Brexit

While challenges abound, numerous Polish companies have successfully adapted to the new trading environment. Let’s examine two contrasting approaches:

Case Study 1: Maspex Group’s Direct Distribution Strategy

Maspex Group, one of Poland’s largest food producers, faced significant disruption to its UK exports of juices, pasta, and instant products post-Brexit. Their comprehensive response included:

• Establishing a UK subsidiary with warehousing facilities
• Implementing sophisticated origin tracking systems
• Moving from distributors to direct retailer relationships
• Creating UK-specific packaging to meet new labeling requirements

The results have been remarkable. Despite initial export volume drops of 17% in Q1 2021, by Q4 2021, Maspex had exceeded pre-Brexit export levels by 7% and increased profit margins by focusing on direct distribution relationships.

Case Study 2: FAKRO’s Digital Transformation Approach

FAKRO, Poland’s leading roof window manufacturer, faced different challenges with its technical products requiring installation support. Their strategy focused on:

• Developing digital installation guides and virtual support services
• Creating a specialized customs team with UK certification expertise
• Implementing dual CE/UKCA certification for all products
• Establishing regional UK stock points with partner distributors

FAKRO not only maintained market share but increased it by 4.5% through 2021-2022, particularly by supporting small builders who valued their enhanced digital support services when in-person technical assistance became more difficult to provide cross-border.

Digital Trade and E-commerce Considerations

The digital dimension of Poland-UK trade presents both challenges and opportunities in the post-Brexit landscape.

Data Protection and Digital Services

For Polish businesses offering digital services or handling UK customer data:

• Data adequacy decision – The UK has received an adequacy decision from the EU, allowing free flow of personal data
• UK GDPR compliance – The UK’s data protection regime mirrors GDPR but may diverge over time
• Digital services registration – Digital service providers may need to register for UK VAT

Pro Tip: Polish companies should consider appointing a UK representative for data protection matters and updating privacy policies to reflect the dual regulatory environment.

E-commerce Fulfillment Strategies

Polish e-commerce businesses serving UK customers face particular challenges:

1. Low Value Consignment Relief abolished – VAT now due on all commercial imports
2. Customs declarations required – Even for low-value shipments
3. Consumer preference for domestic sellers – British buyers increasingly favor UK-based vendors

Effective strategies include:

• Utilizing fulfillment centers within the UK
• Registering for the UK’s Import One-Stop Shop (IOSS) for VAT
• Partnering with established UK marketplaces
• Clearly communicating delivery timeframes and import costs to customers

Practical Steps for Market Entry or Adaptation

Whether you’re an established exporter adapting to the new environment or considering UK market entry, these sequential steps provide a pragmatic roadmap:

Essential Preparatory Measures

1. Obtain an EORI number – Register for an Economic Operators Registration and Identification number with both EU and UK authorities
2. Determine product classification – Identify the correct commodity codes for your products
3. Assess rules of origin impact – Analyze whether your products qualify for preferential tariff treatment
4. Review regulatory requirements – Understand specific UK regulatory frameworks for your sector
5. Establish VAT processes – Register for UK VAT if necessary and implement appropriate accounting procedures

Operational Implementation Strategy

With foundations in place, focus on operational excellence:

1. Update commercial contracts – Revise terms to reflect new responsibilities for customs, VAT, and regulatory compliance
2. Train staff – Ensure team members understand new documentation and compliance requirements
3. Select qualified partners – Identify reliable customs brokers, freight forwarders, and tax advisors
4. Implement trade management software – Consider digital solutions for customs declarations and documentation
5. Monitor regulatory developments – Stay informed about evolving UK regulations and certification requirements

Well, here’s the straight talk: The path to UK market success isn’t about avoiding Brexit complexities—it’s about mastering them better than your competitors.

Conclusion: Building Resilient UK-Poland Trading Relationships

The post-Brexit trading landscape between Poland and the UK presents undeniable challenges, but also creates competitive opportunities for well-prepared Polish businesses. The fundamental commercial relationship remains strong, with the UK continuing as Poland’s third-largest export market outside the EU.

Success in this new environment requires strategic adaptation rather than mere compliance. Polish businesses that approach Brexit changes as an opportunity to reinvent their UK market approach—through supply chain optimization, regulatory expertise, and customer-focused solutions—are already demonstrating that profitable trade can continue and even thrive.

As Brexit implementation continues to evolve, maintaining flexibility and investing in UK market knowledge will remain essential. Polish companies with strong British relationships, efficient customs processes, and adaptable business models will be best positioned to navigate this complex but rewarding market.

Remember: The greatest competitive advantage often emerges from successfully navigating complexity that competitors find too challenging. The post-Brexit UK market offers precisely such an opportunity for prepared and persistent Polish businesses.

Frequently Asked Questions

What documentation do Polish exporters need for UK customs clearance?

Polish exporters must provide several key documents for UK customs clearance: a commercial invoice containing product descriptions, quantities, values, and HS codes; a customs declaration (C88/SAD); proof of preferential origin (if claiming zero tariffs); an Entry Summary Declaration; and product-specific documentation such as health certificates for food products. For controlled goods, additional licenses or permits may be required. Most significantly, exporters should maintain comprehensive evidence to support any preferential origin claims for at least four years after export.

How can Polish companies determine if their products qualify for zero tariffs under the TCA?

To determine tariff eligibility, Polish companies must analyze their products against the product-specific rules of origin in the TCA. This requires identifying the correct HS code for your product, then checking the corresponding origin rule in the agreement. You’ll need to assess whether your product meets either the “wholly obtained” criteria or undergoes “sufficient processing” of non-originating materials. This often involves calculating value percentages of EU/Polish content and obtaining supplier declarations for components. For complex products, consider consulting with a customs specialist to conduct a comprehensive origin assessment.

What are the most effective supply chain adaptations for Polish businesses selling to the UK?

The most effective supply chain adaptations include establishing UK-based distribution facilities to overcome border delays and customs complexity; implementing advanced inventory management systems that account for longer lead times; reviewing and potentially revising Incoterms in customer contracts to clearly allocate new customs responsibilities; developing relationships with specialized logistics partners experienced in UK-EU routes; and implementing digital systems for customs documentation. Companies seeing the strongest results have taken a holistic approach, combining physical infrastructure changes with process improvement and strategic partnerships rather than addressing individual Brexit challenges in isolation.