Ireland – UK Trade Consumer Rights post Brexit

As of 1 January 2021, the EU and the UK form two separate markets and distinct regulatory and legal spaces [i] albeit with preferential arrangements in areas such as trade in goods and in services on-line and off that will ensure that rights of consumers are respected [ii].

The European Consumer Centre Ireland continues to assist Irish consumers with complaints against UK traders after 1 January 2021.

In the following we look at the new regulatory changes for EU-UK trade, including consumer transactions, as well as the governing consumer rights and available redress options for Irish consumers who shop with UK traders in person and online going forward.



With respect to EU-UK trade, as a general rule, no tariffs apply to goods exported out of the UK, certified to be of UK origin, and accompanied by a customs declaration or goods exported to the UK from the EU which are certified to be of EU origin. The new rules apply provisionally until 28 February 2021 and will change further from 1 July 2021. [iii] Read the Irish Government’s Brexit guidance for consumers here.

From 1 January 2021, if you shop directly from the UK (excluding Northern Ireland) and your order is shipped from the UK, additional costs will apply. [iv] EU rules will continue to apply to cross-border transactions that started before 1 January 2021. If you shop from Ireland on UK websites/brands that have a registered base in Ireland, and you buy from that Irish company or your purchase is delivered from a base elsewhere in the European Union, no additional costs will apply to purchases.


When buying goods and services anywhere in the EU Irish consumers have clear rights when it comes to: contract information, pricing and paymentsVAT – Value Added Tax, shipping and delivery, guarantees and returns. These consumers rights will remain unchanged when a purchase is made in/from a UK shop/brand which has a registered presence in Ireland.

The BREXIT deal commits the UK and the EU to maintaining existing EU-type consumer protections on a mutual basis. As a general rule, EU consumer rules cover goods and services that have been bought in the EU, including when you have purchased from a non-EU (now including UK) online trader who has specifically targeted EU consumers. From 1 January 2021, however, if you shop directly from the UK (excluding Northern Ireland) the applicable consumer rights will be set down in UK law, which is similar to and based on EU law.[v]


consumer complaint

If you make a purchase from a UK trader with a registered presence in Ireland, your redress options and any request for repair, replacement, or refund remain unchanged. Complaints against UK brands with a retail presence in Ireland should be forwarded to Competition and Consumer Protection Commission here. If you return a purchase to the seller in the UK, Revenue has detailed how you can claim back the taxes here.

Consumers based in the Republic of Ireland who have a purchase dispute with a trader based in the United Kingdom (including Northern Ireland) can seek assistance from the European Consumer Centre Ireland, which in 2021 works in collaboration with the Consumer Centre UK to facilitate resolution for disputes ongoing at 31 December 2020 and new complaints arising until the end of 2021.

If the trader based in the UK or outside the EU/EEA marketed goods in the country where you live and your transaction with them resulted in a dispute, initiating legal action through the Irish court system is also a possibility.In practice, however, asserting your consumer rights with a trader who is based outside the EU may prove difficult. We advise consumers to seek legal advice before commencing any cross-border proceedings against a trader established outside the EU.

The most convenient redress option in cases of non-delivery of a non-EU/UK purchase remains a request for chargeback through your bank. Redress options no longer available to EU consumers in respect to UK traders are: the European Smalls Claims Court and the Online Dispute Resolution procedure and platform.


car rental damage

In the field of transport, the EU-UK cooperation agreement provides for continued and sustainable air, road, rail and maritime connectivity and calls for measures to protect basic passenger rights, such as access to information, special measures for disability and reduced mobility, reimbursement and compensation, and handling of complaints.


As of 1 January 2021, when the UK became a third (non-EU) country, EU air passenger rights will continue to apply to:

    • flights operated from the UK to the EU by an EU airline, and

    • flights operated from the EU to the UK

    • flights departing from non-EU countries that arrive on EU airports and are operated by EU-licensed carriers

The right to assistance by air carriers (meals, refreshments, accommodation) continues to apply to air passengers departing from an UK airport and arriving into an EU airport, if the flight is operated by an EU airline.

EU air passenger rights will no longer apply to UK-operated flights from the UK to the EU, unless the operating UK aircarrier of the flight concerned has an operating licence granted by an EU Member State.

EU law granting specific rights for disabled persons and persons with reduced mobility will no longer apply to commercial passenger air services that depart from / transit through / arrive at an airport in the United Kingdom.



From 1 January 2021, EU law on ship passenger rights continues to apply where the port of embarkation is in the EU or in the United Kingdom, provided that the port of disembarkation is in the EU and the service is operated by a carrier established within the territory of a Member State or offering passenger transport services to or from an EU Member State.

EU law on bus/coach passenger rights continues to apply to passengers travelling with regular services of 250km+ to/from the United Kingdom where the boarding or the alighting point is in the EU.

EU law on rail passengers’ rights continues to apply to services within the European Union, provided that the railway operator is licensed in the EU.

Ireland-UK updates on rail, maritime and coach/bus rights with respect to travel to/from/within the UK will be updated by the National Transport Authority, when finalised, here.



travel consumer rights


EU consumer protections apply to a package holiday bought from / booked with a UK-based travel agency / tour operator only if that particular package was marketed to consumers in Ireland. All other packages are governed by UK law, which can be accessed here.


Independent holiday individual services purchased from operators outside the EU will continue to be governed by the Terms & Conditions specified in the contracts, which also details the applicable jurisdiction law.


EU mobile data and calls roaming rules will change in the UK and further updates will available from the Commission for Communications Regulation here. Nevertheless, mobile operators may not apply additional charges – check your mobile service provider’s updates.


Read the entire Brexit FAQ here:

2021 Brexit Top 50 Faq


The European Consumer Centre Ireland will continue to assist Irish consumers with complaints against UK traders for a period of at least one year post Brexit, from January 2021.
Nevertheless, we advise that when entering into a transaction with traders based outside Ireland and the EU/EEA, directly in person or online, or via a marketplace/shopping platform, Irish consumers should exert due diligence and take steps to protect themselves by reading the all the applicable terms and conditions, informing themselves on the trader’s returns and cancellation policies, and using a secure method of payment that facilitates redress if something goes wrong.
Consumers who have tried to resolve the matter directly with the trader to no avail, and require assistance on how to proceed further can contact us here.

[i] The United Kingdom left the European Union following the conclusion of the Withdrawal Agreement, and the subsequent signing of the EU-UK Trade and Cooperation Agreement and the Protocol on Ireland and Northern Ireland which apply provisionally until 28 February 2021.
[ii] . While Brexit creates new barriers to trade in goods and services between the EU and the UK, the free trade agreements and its associated Horizontal Agreement on Governance, becomes the new regulatory instrument for cross-border trade detailing the enforcement and dispute settlement mechanisms.
[iii] The trade rules above will change from 1 July 2021. Learn more about taxes and charges when shopping from a non-European Union country here.
[iv] Goods entering Northern Ireland from Great Britain will constitute “imports”, which will be subject to customs formalities and other regulatory checks and controls for safety, health and other public policy purposes. The ‘proof of origin’ rule applies to all products coming into Ireland from the UK, and that made in the UK. Find out about the tariffs, taxes, customs procedures and rules of origin for products imported from UK into Ireland here. Goods originating in the EU, imported into the UK, and then exported from the UK into Ireland will be subject to import duty. Learn more about the new customs, taxes, import, VAT and handling charges when shopping from the UK, as detailed on the Irish Revenue and Customs website here.
[v] Read about UK consumer legislation here and the rights of EU consumers when shopping outside the EU, including the UK, here.
_______________ ECC Ireland is part of the European Consumer Centres Network, which covers 30 countries (all EU countries plus Norway and Iceland), and offers a free and confidential information and advice service to the public on their rights as consumers, assisting consumers with cross-border disputes. ECC Ireland is co-financed by the European Commission and the Competition and Consumer Protection Commission. This press release is funded by the European Union’s Consumers Programme (2014-2020). The content of this product represents the views of the author only and it is his/her sole responsibility; it cannot be considered to reflect the views of the European Commission and/or the Consumers, Health, Agriculture and Food Executive Agency or any other body of the European Union. The European Commission and the Agency do not accept any responsibility for use that may be made of the information it contains.
ECC Ireland welcomes the re-use of the content provided in this press release for the purposes of research and media articles. This re-use may include copying, re-publishing and broadcasting the contents of this press release which must be attributed and referenced to the “European Consumer Centre Ireland”. Publishers may use our official logos and other branded materials, without prior approval, only if adequately referenced. The content is provided for information purposes only and may not be used for commercial/for-profit purposes. Information in this press release must not be put into a context that would lead readers to believe that ECC Ireland endorses or otherwise supports the content or objectives of the website, publication or organisation that re-publishes our content. All content must be reproduced accurately, must not be used out of context or in a misleading way. ECC Ireland is not liable for any loss, damage or liability associated with the re-use of information contained in this press release.
The European Consumer Centre is jointly funded by the European Commission and the Competition and Consumer Protection Commission in Ireland. Disclaimer: Whilst every effort is made to ensure accuracy, the European Consumer Centre cannot be held responsible for matters arising from any errors or omissions contained in this publication. The information provided is intended as a guide only and not as a legal interpretation.
© 2020, European Consumer Centre (Ireland) Ltd, 367035 / CHY14708