Importing Medical Goods From EU to UK

Registration

All import processes require an EORI number. If you have been using an EORI number from another EU country, you will need to obtain one expressly for the UK. If you want to import into England, Wales, or Scotland, you must obtain an EORI number beginning with GB. You can import to Northern Ireland using your EU EORI number or get a new one beginning with XI.

The next step is getting a VAT certificate. Businesses that do not have VAT certificates incur higher import duties and taxes; therefore it is a good idea to get this done before you begin importing.

Product Safety and CE Markings

Imports such as PPEs and medical devices have to have the CE marking, except for pharmaceuticals. This marking indicates that:

• The manufacturer has checked that the product meets EU health, safety and environmental requirements.
• The product complies with EU legislation.
• The product can move freely within the European single market.

Before shipping medical goods from an EU country, ensure that the manufacturer or an authorised representative within the EEA has carried out a conformity assessment, drawn up the technical file, issued the EC declaration of conformity(DoC) and placed a CE mark on the product. The CE marking should be:

• In the standard recognisable form.
• Proportional to the standard version, in the case of enlarged or reduced product marking.
• At least 5mm.
• Placed onto the product, its data plate or accompanying document.

Classification Codes, Duty and VAT

Medical products are considered “difficult to classify” and fall under several tariff chapters.

Medicaments such as tablets and capsules packed in measured doses or for retail use fall under heading 3004. If the medication contains active ingredients but is not quantified, it goes under heading 3003. For example:

• 3004200000 for importing antibiotics packed in measured doses vs 3003200000 for antibiotics in bulk.
• 3004310000 to import insulin medication packed for retail use vs 3003310000 insulin medication in bulk.

Heading 3002 covers immunological products like antibodies and vaccines, for instance ;

• 3002201000 for importing vaccines against SARS-related coronaviruses.
• 3002150010 for importing diagnostic reagents for SARS-CoV virus species packed for retail use.

Find the commodity codes for medical equipment and implantable medical devices in chapter 90 e.g.:

• 9019201000 for importing (invasive) artificial respiration apparatus.
• 9021500000 for importing pacemakers.

Medical consumables and supplies go under heading 3005. For example:

• To import adhesive plaster, you will use the code 3005100000.
• For medical oxygen, code 2804400000.

Heading 3005 excludes certain products which instead fall under heading 3006 such as:

• sterile suture materials like catgut – code 3006101000.
• dental cement and filling – code 3006400000 and
• first aid kits – code 3006500000.

To import PPEs such as face masks, and sanitising products, use the codes:

• 6307909311 for FFP2 and FFP3 face masks.
• 2847000000 for hydrogen peroxide in bulk.

Medical products coming from the EU are eligible for a tariff preference (i.e. zero VAT and import duty). Still, you must submit proof of origin to get this preferential rate.

Get someone to deal with customs

For pharmaceutical deliveries headed to England, Wales, or Scotland, you must declare them to UK customs. However, HMRC will not ask for a declaration for goods travelling to Northern Ireland. Submitting an import declaration by yourself can be costly and time-consuming; therefore, it’s a good idea to let a specialist freight forwarder or courier act as your customs agent.

• If shipping medical equipment by sea, then your sea freight company will submit a declaration,
• For a pharmaceutical delivery travelling by road, the logistics company can deal with customs and
• For pharmaceutical transport by air, the air freight operator can submit a declaration for you.