Do US brands need a UK or EU company? A simple decision guide

It is the first question almost every US brand asks us, and the honest answer is: it depends on four things. Here is how to work out which side you are on.

Question 1: Where will your stock sit?

In the US, shipping parcels to customers. You do not need a local company. You do need to handle VAT and product compliance:

• UK: if you sell goods worth £135 or less per consignment directly to UK consumers, you register for UK VAT and charge it at checkout. If you sell through a marketplace, the marketplace usually collects it. Above £135, VAT and any duty are paid at import.
• EU: for parcels under €150, you can collect VAT at checkout through the Import One-Stop Shop. A business outside the EU needs an EU-established intermediary to use it. Since July 2026, these parcels also carry a €3 customs duty per item.

In a UK or EU warehouse. A local company is the clean route. Someone must import your goods, and customs in both the UK and the EU expect the importer to be established locally. Without a local company, you need a customs agent who acts as your indirect representative and shares liability for duties, and few agents accept that for a non-resident brand. You will also register for VAT in each country where stock is held, from the first sale.

Question 2: How do you sell?

Question 3: What do you sell?

The product, not the company, decides your compliance obligations, and they apply even when you ship from the US.

• Most consumer products sold in the EU need an economic operator established in the EU who is responsible for the product under the General Product Safety Regulation. Their name and contact details go on the product or its packaging and in your online listings.
• Cosmetics need a Responsible Person established in the UK for the UK market and one in the EU for the EU market, who notifies each product before it goes on sale.
• Food supplements follow food law: notifications, label rules and permitted ingredients differ by country.

None of these require your own company. They require a representative who is established locally and willing to take responsibility.

Question 4: Will you pay people locally?

If you pay local distributors, employees or contractors, a local company makes payments, tax reporting and contracts far simpler. For network marketing companies paying commissions across the UK and the EU, it is usually the only practical structure: local bank account, local currency, local invoicing.

The quick answer

A common mistake

Brands often start with the cheapest path and grow into the wrong structure: stock in a European warehouse under a US entity, VAT registered in one country, a customs broker who will not take liability, and nobody responsible for product compliance. Fixing it later costs more than setting it up properly once.

Sources

• HMRC VAT Registration Manual: overseas sellers and online marketplaces
• Avalara: what US sellers need to know about EU IOSS intermediaries
• Avalara: EU customs and import VAT representative
• Strong & Herd: UK importers, declarants and liability
• EU General Product Safety Regulation 2023/988
• GOV.UK: submit a cosmetic product notification
• Council of the EU: customs duty on small parcels