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Who arranges and pays for customs in transport to the United Kingdom is decided by the Incoterms rule written into the sales contract. Under EXW almost everything falls on the buyer, under FCA the seller answers for export, under DAP the buyer answers for import, and under DDP the seller takes on the whole chain, including UK clearance.
What Incoterms settle
Incoterms rules are neither customs law nor a contract of carriage. They are an agreed commercial language which, within the sales contract, divides duties, costs and risk between the seller and the buyer: who arranges transport, who answers for export and import clearance, who pays for what and at which point risk passes to the other side. After Brexit this three-letter note on the invoice gained weight, because two customs clearances appeared between Poland and the United Kingdom and each must have its owner.
The four rules most common in road transport to the UK
- EXW (Ex Works): the seller makes the goods available at its own premises. The buyer arranges transport, export clearance from Poland and import in the United Kingdom.
- FCA (Free Carrier): the seller loads the goods and answers for export clearance, the buyer arranges transport and the GB import. The cleanest split for shipments out of Poland.
- DAP (Delivered at Place): the seller arranges export and transport all the way to the named address, the buyer answers for import clearance in the United Kingdom.
- DDP (Delivered Duty Paid): the seller takes on everything: export, transport, GB import and the customs and tax charges. The most convenient for the consignee, the most demanding for the sender.
| Rule | Export clearance PL | Transport and crossing | Import clearance GB | UK duty and VAT |
|---|---|---|---|---|
| EXW | Buyer | Buyer | Buyer | Buyer |
| FCA | Seller | Buyer | Buyer | Buyer |
| DAP | Seller | Seller | Buyer | Buyer |
| DDP | Seller | Seller | Seller | Seller |
Trap one: EXW and export from Poland
On paper EXW takes everything off the seller. In practice the export declaration is lodged in Poland and requires the Polish company data, its EORI (Economic Operators Registration and Identification) number and the sales documents, so it will not happen without the seller taking part. A buyer from the United Kingdom rarely has a way to run clearance in the Polish system on its own. The result: responsibility formally sits on one side while the other side does the work, with no clear agreement on who answers for what when something goes wrong. It is safer to choose FCA, where this reality is written down openly.
Trap two: DDP and the British side of the settlement
DDP sounds like the best customer service: the consignee receives the goods at the door with no formalities at all. Except the seller then answers for import clearance in the United Kingdom and the charges there, which usually requires the British side of the settlement to be prepared in advance, including VAT matters and representation. The consignment value matters here: according to GOV.UK, for a consignment of GBP 135 or less sold directly to a customer in GB, VAT is charged at the point of sale as domestic supply VAT, while above that threshold an import settlement applies. It is doable, but it cannot be improvised on loading day. DDP is agreed ahead of time or swapped for DAP, where the import stays with the consignee.
What does this mean for the transport order?
For a forwarder the Incoterms rule is concrete information: who orders and pays for export clearance, carriage with the crossing and import clearance. That is why we ask about it at quoting stage and compare it with what the parties actually agreed, because a gap between the invoice and the arrangements usually surfaces only at the border. We have collected the basic terms in the customs terminology glossary, we explain why customs and carriage belong in one order in choosing a customs agency matters, and you will find a wider checklist in how to choose a forwarder for UK transport.
Not sure which rule sits in your contracts and what it means for a shipment to the UK? Describe the situation in the contact form and we will set up customs and transport to match it.
Step by step
- Selecting the Incoterms rule. You agree with your trade partner on the division of customs and transport duties in the sales contract.
- Preparing commercial documents. You issue the commercial invoice and consignment note clearly indicating the chosen rule.
- Export clearance filing. The party responsible for export submits the declaration to the customs office.
- Arranging international transit. The carrier collects the cargo and manages ferry or tunnel crossing to the UK.
- Import customs clearance. The designated party settles duties and taxes to complete border clearance.
Definitions
- EXW (Ex Works): A rule where the buyer arranges all transport and handles both export and import customs clearance.
- FCA (Free Carrier): A rule where the seller handles export clearance and loading, while the buyer takes responsibility for main carriage and import clearance.
- DAP (Delivered at Place): A rule where the seller handles delivery to the destination, but the buyer remains responsible for import clearance.
- DDP (Delivered Duty Paid): A rule where the seller assumes full responsibility, including UK import clearance and payment of duties.
When does this rule not apply?
The standard division of duties under Incoterms does not apply if the sales contract contains custom clauses that modify who covers import taxes or customs clearance costs.
The OTSL role
OTSL coordinates cargo movements between Poland and Great Britain through reliable road transport options and warehousing support. To avoid misunderstandings between buyers and sellers, read about the Incoterms mismatch DAP versus DDP: who really pays customs duty and import VAT before finalizing contracts.
