Guides / Used machinery UK to Poland · Updated 30 September 2026

Selling used machinery from the UK to Poland: customs, VAT and CE marking

A used machine sold from Britain to a Polish buyer needs a UK export declaration, an EU import declaration, a realistic view of its origin and, often, a check against EU machinery rules. Here is the sequence, step by step.

This guide is also available in Polish.

Why used machinery is its own customs case

Selling a used lathe, excavator, packaging line or generator from the UK to a buyer in Poland looks simple: agree a price, book a truck, load it. Since the UK left the EU, though, that machine crosses a customs border twice. It leaves Great Britain under a UK export declaration and enters the EU under a Polish import declaration, with duty, import VAT and product-safety rules applied on the EU side. Used machinery adds three complications that new goods rarely have together: uncertain origin, conformity rules that depend on whether the machine is being placed on the EU market, and sheer size.

Step 1: the UK export declaration

GOV.UK states that an export declaration must be made before the goods leave the UK, through the Customs Declaration Service (CDS). The exporter can make it, or hire a transporter or customs agent to do it. At the border you should be able to show the movement reference number from the declaration, the invoice, and any export licences or certificates the goods need.

You will also need an EORI number beginning with GB, and a correct commodity code for the machine. Most industrial machines sit in chapter 84 of the tariff, but the exact code depends on what the machine does, so check it rather than copying a code from a previous shipment.

Zero-rating the sale for UK VAT

If you are VAT-registered and selling to a Polish business, the sale can be zero-rated as an export, but only if you meet HMRC's conditions in VAT Notice 703. The notice sets a time limit of 3 months both for exporting the goods and for obtaining evidence of export in most cases. Official evidence is the CDS export declaration with confirmation that the goods departed; commercial evidence includes documents such as international consignment notes or bills of lading. Without that evidence, UK VAT may be due on the sale.

Step 2: the dual-use check before you ship

Some machinery is controlled because it could have military as well as civil uses. GOV.UK describes dual-use items as goods, software and technology that can be used for both civil and military purposes, and states that an export licence is needed to export controlled dual-use items from Great Britain. High-precision machine tools and certain industrial equipment can fall into this area, and age alone does not take a machine out of control.

• Check the machine against the UK consolidated list of strategic military and dual-use items.
• Use the government's goods checker tools, or ask for a control list classification through SPIRE if you are unsure.
• Remember that items not on a control list can still need a licence under end-use controls or sanctions.

Step 3: EU import duty depends on origin, not on where the machine was used

A common assumption is that a machine sold from Britain automatically enters the EU duty-free. It does not. Under the UK–EU Trade and Cooperation Agreement (TCA), the zero tariff applies only to goods that meet the UK–EU rules of origin, which means they were wholly obtained or sufficiently processed in the UK or EU. GOV.UK explains that goods which fail the rules pay the standard most-favoured-nation tariff instead.

For used machinery this is where things get awkward. A machine built in Japan, the USA or China and later used in a British factory does not become UK-originating simply because it was used here. A machine made in Germany or Italy may qualify, but only if you can support the claim.

GOV.UK lists two forms of proof: a statement on origin made by the exporter on the invoice or another commercial document, or the importer's knowledge backed by supporting documents. Exporters must hold evidence before issuing a statement and keep records for at least 4 years. Our guide to the statement on origin covers the wording and pitfalls. If you are the seller, do not add a statement to the invoice just to please the buyer; if you cannot prove origin, say so.

Step 4: import VAT in Poland

When the machine is released for free circulation in Poland, EU customs rules apply import duty and VAT at the same moment. The European Commission explains that the date the customs declaration is accepted is the date used to calculate the import duty and any VAT due, based on the nature, customs value and quantity of the goods. In practice, the Polish buyer (as importer) declares the machine through the Polish customs system and pays or accounts for import VAT. Agree in the contract who acts as importer, because that party carries the liability. With direct representation the importer remains liable; with indirect representation the agent is jointly liable.

Step 5: CE marking and placing on the EU market

This is the point most sellers miss. According to the European Commission, the Machinery Directive 2006/42/EC applies to products placed on the EU market for the first time, and to existing machinery that is substantially modified. It is being replaced by the Machinery Regulation (EU) 2023/1230, which becomes mandatory on 20 January 2027.

A used machine that was always in the EU before being sold on is a different case from one arriving from outside the EU. Since Great Britain is now outside the EU, a used machine entering Poland may count as being placed on the EU market for the first time, which can bring it within the EU machinery rules and CE marking. The Commission's page does not spell out every scenario for used imports, so the buyer should check the machine's documentation, nameplate and declaration of conformity before committing, and take specialist advice if the paperwork is missing or the machine has been rebuilt. A machine that carries only UKCA marking is a particular red flag.

For the other direction, where EU machinery comes into Britain, the Easy Clearance team has written about UKCA, CE and conformity for machinery exports, which is worth reading alongside our UKCA and CE marking guide.

Step 6: getting a large machine on the road

Heavy plant often exceeds normal vehicle limits. National Highways explains that loads over any of its thresholds (including a total weight above 44,000kg, a width above 2.9 metres or a rigid length above 18.65 metres, as well as axle-load limits) must be notified to the police, highway authorities and bridge or structure owners. Hauliers use ESDAL (Electronic Service Delivery for Abnormal Loads) to plan routes and send those notifications. Build that notice period into your timetable, and remember that the ferry or tunnel operator and the continental route will have their own rules. Many such moves also run under T1 transit so that EU import clearance happens in Poland rather than at the port of entry.

Documents checklist

• Commercial invoice with a full machine description, serial number and value
• Correct commodity code and GB EORI (seller) and EU EORI (buyer)
• UK export declaration reference and proof the goods left the UK
• Dual-use check result or export licence, if needed
• Proof of origin, only if origin can genuinely be shown
• EU declaration of conformity, technical file and manual, where the machinery rules apply
• Abnormal load notifications and transit documents from the haulier

Related guides

• How a Polish business imports goods from a UK supplier

• Importing furniture from Poland to the UK: a business guide

• First business shipment from the UK to Poland: a step-by-step checklist

Sources

• Make an export declaration (GOV.UK)
• Rules of origin when trading between the UK and EU (GOV.UK)
• Export controls: dual-use items (GOV.UK)
• What is importation? (European Commission)
• Machinery (European Commission)

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.