UK Clothing Manufacturing After Brexit: Tariffs & Rules of Origin (2026) | NovaSupplier
Clothing Manufacturing for UK Brands After Brexit: What Actually Changed
Matias Santos, Founder·
Some UK brands sourcing genuinely EU-made clothing are still paying the 12% tariff, not because the law requires it, but because their paperwork doesn't prove what should be provable. This covers what the Trade and Cooperation Agreement actually requires, why so many brands miss the zero-tariff rate they're entitled to, and what changes when your production is Portuguese rather than Asian.
The tariff isn't automatic, in either direction
Since 1 January 2021, goods moving between the UK and the EU are no longer internal trade, they're international trade governed by the Trade and Cooperation Agreement (TCA). The TCA provides for zero tariffs and zero quotas on UK-EU trade, but only for goods that meet the agreement's rules of origin and carry the paperwork to prove it. Without that, the UK's standard Global Tariff rate applies to clothing entering Great Britain: 12%.
That 12% isn't a penalty for sourcing outside the UK. It's the default rate that applies to any goods that don't qualify as UK or EU origin under the TCA, or that qualify but can't prove it. Which means the tariff outcome for a UK brand sourcing in Portugal depends less on where the goods were made than on whether the paperwork behind them can actually demonstrate it.
Why so many UK brands are paying a tariff they don't have to
Research cited by the UK's own trade policy analysts found that in 2022, only somewhere between 10% and 53% of UK exports in the textiles and clothing sector actually claimed the zero-tariff rate they were entitled to under the TCA, depending on the specific product category. The comparable dynamic runs in the other direction too: businesses importing genuinely EU-origin goods into the UK who don't have the correct proof of origin documentation end up paying the 12% Global Tariff rate on goods that would have qualified for zero duty with the right paperwork in hand.
This isn't a compliance failure so much as an awareness gap. Rules of origin are product-specific, genuinely technical, and the administrative burden of getting the documentation right can feel disproportionate to a founder focused on getting a first collection made. But for a UK brand sourcing production in Portugal specifically, that gap is directly worth closing, because Portuguese-manufactured clothing is a strong candidate for qualifying as EU origin in the first place.
What actually qualifies as EU origin, and what proves it
A product qualifies for the TCA's zero tariff when it meets the Product Specific Rule (PSR) for its category, the specific test, based on where manufacturing actually happened and how much non-originating material was used, that determines whether a garment counts as genuinely EU-made rather than merely EU-assembled from imported components. For textiles and clothing specifically, the TCA's tolerance rule allows up to 15% of the ex-works price to come from non-originating materials without failing the origin test, a higher allowance than the general 10% tolerance that applies to most other product categories.
Proving it requires a statement on origin, typically provided by the manufacturer, included on the commercial invoice or an equivalent document. For shipments valued over €6,000, that statement needs to reference the exporter's REX (Registered Exporter) number. This is documentation a genuine, established Portuguese manufacturer should be able to provide as a matter of course, it's routine paperwork for a factory with real export experience, not a special request.
The practical implication for a UK brand: ask your Portuguese manufacturer directly whether they can provide a statement on origin referencing their REX number before your first shipment, not after HMRC asks for one during an audit. Getting this wrong doesn't just mean paying 12% you didn't have to. Research shows HMRC has been actively scrutinising origin claims, and an incorrect claim can mean backdated duty, interest, and penalties that exceed whatever the tariff would have cost in the first place.
Why this matters more for UK brands specifically, right now
A UK brand previously sourcing from China faces the full case for moving production to Europe that applies to any brand, shorter lead times, no ocean freight uncertainty, direct factory relationships. But the UK-specific layer on top of that case is the tariff math: Chinese-origin clothing entering the UK faces the same 12% Global Tariff rate as any non-originating goods, with none of the TCA's zero-tariff path available, because that path only exists for UK and EU origin goods. Genuinely Portuguese-made clothing, correctly documented, can move into the UK at zero duty. Chinese-made clothing cannot, regardless of documentation.
That's a real, structural cost difference that compounds on every shipment, not a one-time saving. A brand moving production from China to Portugal and getting the origin paperwork right isn't just gaining the quality and lead-time benefits covered elsewhere on this site. It's potentially removing a 12% cost that was previously unavoidable.
What to actually do about it
Ask your Portuguese manufacturer, before your first order ships, whether they can provide a statement on origin and confirm their REX number for shipments over €6,000. An established manufacturer with real EU export experience should answer this without hesitation. Hesitation or confusion about the question is itself a useful signal about how experienced the factory actually is with EU-UK trade specifically, separate from their general manufacturing capability.
If you're already sourcing from Portugal and haven't had this conversation, it's worth having retroactively. If your existing shipments should have qualified for zero duty and didn't because the documentation wasn't in place, that's worth understanding for future orders even if past duty isn't recoverable.
Frequently asked questions
Not necessarily. Genuinely Portuguese-made clothing, correctly documented with a statement on origin proving it meets the TCA's rules of origin, can enter the UK at zero duty. Without that documentation, or if the product doesn't meet the origin rules, the standard UK Global Tariff rate of 12% applies to clothing.
The UK Global Tariff rate for clothing is 12%. This applies to goods that don't qualify as UK or EU origin under the Trade and Cooperation Agreement, or that qualify but lack the correct proof-of-origin documentation.
A statement on origin, typically provided by the manufacturer, included on the commercial invoice or an equivalent document. For shipments valued over €6,000, the statement must reference the exporter's REX (Registered Exporter) number. An established Portuguese manufacturer with real export experience should be able to provide this as standard practice.
For textiles and clothing specifically, the TCA allows up to 15% of the ex-works price to come from non-originating materials without failing the origin test, higher than the general 10% tolerance that applies to most other product categories.
Research on UK exports found that only an estimated 10% to 53% of UK textile and clothing exports actually claimed the zero-tariff rate they were entitled to under the TCA in 2022, reflecting either missing documentation or the administrative burden of proving origin. A comparable documentation gap affects imports into the UK as well.
NovaSupplier connects UK brands directly with vetted Portuguese manufacturers who have real EU export experience, the kind of factory that can answer a rules-of-origin question without hesitation. Completely free for brands. The commission is capped at 3.5%, charged to the manufacturer.