The Single Administrative Document (SAD) is the primary customs declaration form used across the EU and UK for goods moving across international borders. It’s a standardised eight-part form containing all the information about imports, exports and goods in transit that customs authorities need.
If you’ve ever shipped an order to Europe, you’ll have encountered a Single Administrative Document before. It captures details about what you’re shipping, including the:
It’s a long form (it has 54 boxes to fill out!) but completing it carefully is important. An accurate SAD will help prevent your shipment from being delayed at customs.
Single Administrative Documents were first introduced on the 1st of January 1988. Prior to then, every country in Europe had its own customs paperwork. It required a lot of admin to regularly ship things internationally.
The introduction of SADs made it a lot simpler. Dozens of national entry forms were consolidated into a single, 54-box form with a standardised layout. For the form to work, other parts of international trade had to change. Commodity codes (HS Codes), Customs Procedure Codes (CPCs) and Incoterms where all harmonised. That gave Europe one form to fill out, and one trading language with which to do it.
It’s rare to hand over a paper SAD at a border these days, but we’re still using their data structure. It’s the framework on which digital customs submissions are filed across Europe.
When the UK left the EU in 2021, it became a distinct customs territory. Although built on the principles introduced in 1988, the UK’s customs framework began to diverge from the EUs. As a result, the UK stopped using SADs, instead using its own version: a C88 form.
C88s and CHEIF (Customs Handling of Import and Export Freight), the digital customs system were phased out in 2024. They've been replaced by the Customs Declaration Service (CDS), which like SADs, uses the framework established by the paper C88 form.
Shipping goods from Great Britain into the EU now requires two separate declarations. A UK export declaration (formerly C88) out of GB and a full EU SAD import declaration upon entry into the EU single market.
You'll need to complete a Single Administrative Document whenever you ship goods in or out of the EU or the UK. That applies to both imports and exports, whether you're sending individual orders or shipping inventory to an FBA warehouse.
It’s common for non-EU businesses to store inventory in the EU. It makes it quicker to fulfil orders from European customers when the stock is already close to them. The single market and its free movement of goods is in part, responsible for that speed. You can warehouse your stock in on EU country and fulfil to customers in others without have deal with customs procedures every time an order crosses a border. In this scenario, you fill out the SAD once – when your goods enter the EU.
There are three cases in which you might need to fill in another SAD, or an alternate form:
Most of the time, you won’t be filling out the Single Administrative Document yourself. Instead, you’ll be working with a customs broker. They’ll help you compile the necessary documents and information. The broker will have access to national level customs systems (like the CDS) and will submit the SAD for you.
Customs authorities use the information in the SAD to work out duties, verify your compliance status and gather trade statistics. To fill it out, you’ll need information about what you’re shipping, your businesses and the transaction. Here’s a non-exhaustive list of information you (and your customs broker) will need:
As you can see, SADs need a lot of data. If you plan to regularly ship goods cross-border, think about investing in systems that can help you manage it all. Knowing where all the information you need for a SAD is will save you time. However, the greater return on your investment is avoiding shipment delays, penalties, or even the seizure of your goods.
There are four areas that businesses commonly get wrong when it comes to Single Administrative Documents:
Accurate commodity codes are a must. They determine the rate of duty and tell customs if there’s any regulatory requirements applicable to your shipment. They’re also the part of this process that cause folks the most problems. There are thousands of codes representing subtle distinctions between similar products. Repeatedly getting your codes wrong can trigger customs audits which in turn lead to retrospective duty assessments. Customs brokers (like the team at SimplyVAT) can make it easier by helping you work out which codes you need for your products.
The country of origin is another tricky part of exporting and importing. Where the goods are from determines whether you’re eligible for preferential duty rates under a trade agreement or have to face a tariff. In some cases, it’s obvious where the country of origin is. However, most of the time, you’ll need to consider what your product is made of, where those materials are from, and where the manufacturing takes place.
Customs rules require you to declare the transaction value, including specific cost components. How this works varies a lot based on:
Getting it wrong will likely cost you money. Overvaluation means you’re likely to overpay duties and VAT, whilst undervaluing can lead to penalties.
The most common reason shipments get delayed at customs is document issues. The SAD needs to match supporting documents like commercial invoices or transport documents. If they don’t, customs authorities can hold a shipment whilst they verify your information.
The Fulfilment House Due Diligence Scheme (FHDDS) is a UK legal framework designed to tackle VAT fraud. Businesses have to register for the scheme if they store goods that are:
Fulfilment centres – or third-party logistics (3PL) hubs – can only work with customers that are registered for UK VAT. They are legally required to check a potential customer’s VAT number. That means you can’t use a 3PL or Amazon FBA warehouse in the UK unless you’re registered for VAT.
When a 3PL in the UK wants to work with international customers with imported goods, they register for FHDDS. The scheme doesn’t apply to companies whose main work is transport, as storing goods in these cases is usually temporary.
HMRC will check their application against their records, and then investigate the key people in the business to make sure:
Once registered for the Fulfilment House Due Diligence Scheme, a 3PL has compliance and record keeping obligations. They need to keep records of:
They have to keep these records for 6 years and will be fined £500 for every failure to comply.
Once registered for the Fulfilment House Due Diligence scheme, 3PLs have to check their customers details. You’ll need to provide them with your UK VAT or VAT exemption number, which they’ll validate with HMRC. Within 30 days of the start of working with your UK 3PL, you’ll get a “Notice of UK Obligations”. This is an official letter that outlines:
Put simply: you cannot use a 3PL or Amazon FBA warehouse in the UK without being registered for UK VAT. Fulfilment centres won’t work with you otherwise because of the risk. Fines range from £500 to £3000 for not checking numbers or not giving notice. Ultimately, they can lose their licence for working with businesses that aren’t VAT compliant.
The risk isn’t limited to the fulfilment company. For your business, the risk would be:
This is made easier for HMRC as FHDDS-registered companies have to notify them if they think you’re not meeting your VAT obligations. However, they are obliged to help you with VAT compliance and can be fined £3000 for failing to do so. They usually do this by referring you to a partner like SimplyVAT - we can help you get registered for UK VAT and the ongoing VAT returns.
By law, fulfilment houses must check your VAT status so you have to register for UK VAT if you want to use one in the UK. If you don't register, Amazon will prevent you from using the FBA program. Intentional non-compliance may even lead Amazon to suspend your account.
Non-UK sellers can’t avoid UK VAT if they want to sell to UK customers. You could store your inventory in another European county, but you’ll likely have to register there instead. There’s also no registration threshold for non-UK businesses selling to UK customers.
Holding your stock elsewhere also means you’ll miss out on:
Ultimately, you will end up dealing with VAT in some capacity. The trick is working out the most efficient way to handle it, which is made easier with advice from an expert, like the VAT consultants at SimplyVAT.
Because of the Fulfilment House Due Diligence scheme, 3PLs and fulfilment centres won’t onboard you until after you’re registered. If you want to use one in the UK, you will have to be registered. Depending on the incoterms you use to ship to UK customers, you may have to register for VAT anyway.
A big part of international ecommerce is choosing how you ship your orders. Beyond the kind of packaging you’ll use, or the courier you hire, is the incoterm you’ll ship under.
Incoterms are internationally recognised legal frameworks published by the International Chamber of Commerce (ICC). A lot of people and businesses are involved in moving goods across the world. Just one of your orders will change hands multiple times on its way to your customer. Incoterms make things simpler by determining who’s legally responsible for different aspects of shipping something. They define the costs and risks for customers and sellers.
Incoterms are three-letter codes. The most common are DAP (Delivered at Place) and DDP (Delivery Duty Paid). Which you use determines who pays the import VAT and customs duties when you ship an order to your customer!
First, I need to explain the term “Importer of Record”. The Importer of Record is the person or business legally responsible for goods as they’re imported into a country. The importer of record (IOR) is accountable for customs clearance, which includes paying any import VAT and duties.
When you ship an order to a customer in another country, you’ll have to decide who you want to be the IOR. For B2C ecommerce, you do this by deciding which Incoterm you ship your orders under – DAP or DDP.
The consignee is the person or business that you’re shipping your order to. They can be the importer of record, but it’s not automatically the case. The main difference is that the term Consignee is used to identify the owner of the goods upon delivery. Importer of Record is used to ascribe legal responsibility for customs clearance.
If you ship the order DAP, the Consignee will be the importer of record.
When you ship Delivered at Place (DAP), you're saying you’re responsible for arranging delivery, but the customer handles the import VAT, duties and customs. Shipping DAP means you’re legally accountable for delivering the order and all the associated costs and risks.
DAP tells customs that your customer is responsible for import customs clearance, duties and taxes. Your customer is the importer of record for VAT purposes.
Delivery Duty Paid (DDP) is the incoterm you use when you want to assume full responsibility for a shipment. That means you’re legally accountable for:
When you ship DDP, you assume a lot of the risk involved in getting your customer’s order to them. The buyer’s only real responsibility in a DDP shipment is receiving the goods.
When you ship DDP, you, the seller, are the importer of record. You can also involve a third party to do this for you, like a freight forwarder or a customs broker. You might decide to do this if you can’t be the IOR or you want to be sure everything goes smoothly.
Which Incoterms should you be using? DDP or DAP? The answer depends on what your business is and your goals. For the average B2C ecommerce seller, though, we recommend you choose DDP as your standard shipping method.
DAP shipping adds friction at the point where a potential buyer could convert into a customer. International consumers will hesitate at checkout because:
It costs a lot of time and money to win a sale, so it doesn’t make sense to add barriers like this at checkout. This is the main reason we recommend using DDP, and it’s not just us. Using DDP has been shown to decrease cart abandonment.
Given the cost of winning a new customer, repeat buyers are important. DDP provides a better customer shipping experience, making it more likely that your customers come back to make another purchase.
Whether you send your parcels DAP or DDP, you first need to make sure your customer knows which is being used. It’s not just your customers, though; every party involved in a consignment reaching your customer needs to know how it’s being handled. So, once you’ve decided how you’re shipping your orders, you need to communicate it clearly in your shipping documentation. Make sure it’s included in things like:
You can also include it in your Packing List if you want to be extra clear.
If you decide to ship DAP, you don’t need to do much other than agree on the delivery destination with your customer. You’re probably already doing this via a delivery address form at checkout.
Shipping DDP is slightly more complicated, as you’ll have to handle the tax and duties at customs. You’ll need to plan ahead before you start shipping this way. If your customer is in the UK or an EU country, you’ll have to be registered for either VAT or IOSS. Some countries will require you to be registered before your first DDP sale and may require a fiscal representative as part of the process.
Getting registered isn’t just extra paperwork. If you register for VAT in a single country (instead of IOSS) you’ll be able to reclaim import VAT on goods you ship there.
