Introduction

As the CBD market matures in 2026, regulatory and tax changes demand clear operational practices from retailers. Recent expansions to Making Tax Digital (MTD) and clarified marketplace responsibilities following Brexit mean that VAT, import accounting and customs duties are no longer back‑office details to be deferred — they directly affect cashflow and compliance. This guide explains the practical steps CBD retailers should take when charging VAT at checkout, reclaiming import VAT using the monthly C79 certificate or Postponed Import VAT Accounting (PIVA), handling marketplace invoicing, and managing import duties for hemp‑derived goods.

Key concepts every CBD retailer must understand

C79 certificate — the formal proof to reclaim import VAT

HMRC issues a monthly C79 certificate which is the only formal proof importers can use to reclaim import VAT on goods brought into the UK. Verify that the C79 details (importer name, commodity codes, values and VAT amounts) match your shipments and retain each C79 as part of your VAT records. Without a correct C79 you may be prevented from reclaiming import VAT.

Postponed Import VAT Accounting (PIVA)

PIVA allows VAT‑registered importers to declare and recover import VAT on their VAT return rather than paying at the border. Used correctly, PIVA improves cashflow because inward import VAT is both declared in box 1 and reclaimed in box 4 of the same return (subject to your right to reclaim). Ensure your customs declarations are made under PIVA and that your accounting systems capture the postponed VAT entries for reconciliation.

£135 consignments and marketplace responsibilities

Consignments with a shipment value of £135 or less are typically subject to VAT at the point of sale rather than at the border. Online Marketplaces (OMPs) are frequently treated as the ‘deemed supplier’ and therefore responsible for charging and remitting VAT at checkout. Retailers selling through marketplaces must check whether the marketplace charges VAT on their sales or if the seller is treated as the supplier — this affects who issues VAT invoices and who can reclaim input VAT.

Import duties vs VAT

Import duties are charged to the importer of record and are a non‑recoverable cost for VAT purposes (unlike import VAT when reclaimable). Correct commodity classification (HS code) and customs valuation are essential to avoid unexpected duties, penalties or clearance delays.

Practical details and steps for CBD retailers

1. Confirm product legality before any tax steps

Before you address VAT or customs, confirm a product is lawful to import and sell in the UK. Ingestible CBD products require valid FSA novel‑food compliance and finished products must meet THC rules (hemp plant ≤0.2% THC; finished product ≤1mg THC per container). Non‑compliant stock risks enforcement, seizures and removal from sale — make sure Certificates of Analysis (COAs) are current and filed.

For example, ingestible lines such as Wylde Natural Cold‑Pressed Drops 1000mg CBD Oil 10ml, Wylde CBD Gummy Bears 30x (10mg per bear) or high‑strength tinctures such as CBD Living Tincture 30ml 4500mg (0% THC) demand close regulatory checks; topical items like the Full Spectrum CBD Healing Balm and vaping liquids such as Canavape Blue Dream Complete CBD E‑Liquid 1800mg have distinct regulatory and customs treatments.

2. Choose the right import accounting route

• PIVA — use this if you are VAT‑registered and want to avoid paying import VAT at the frontier. Make sure your customs agent declares postponed VAT and your accounting records capture the postponed VAT reference.
• Pay at border and reclaim with C79 — if you or your freight forwarder pay import VAT at the time of entry, HMRC will provide a monthly C79. Check it, match it to your import invoices and keep it as evidence when reclaiming on your VAT return.
• Low‑value consignments (£135 or less) — confirm whether the marketplace or the seller charged VAT at point of sale. If the marketplace is the deemed supplier, you may not be the importer of record for VAT purposes.

3. Invoicing, marketplaces and reclaiming input VAT

Who issues the VAT invoice matters. If an OMP is the deemed supplier, the marketplace usually charges VAT and issues receipts; third‑party sellers must verify the invoicing flow to ensure they can reclaim input VAT where eligible. Foreign sellers shipping directly to UK consumers generally need to register for UK VAT unless the marketplace handles VAT collection and reporting on their behalf.

4. Account for import duties and classification

Import duties are a cost to the importer of record and cannot be reclaimed as VAT. Accurate commodity codes and customs valuation must be used to calculate duty rates. Engage a customs broker if you are uncertain — incorrect classification or under‑valuation can lead to penalties and delayed clearances.

5. Partial exemption and mixed supplies

If your business makes both taxable (including zero‑rated) and exempt supplies, you must apply partial exemption rules and only reclaim the portion of input VAT attributable to taxable activities. Keep robust records and apply a consistent apportionment method supported by evidence.

Action checklist — immediate steps for 2026

• Confirm legal status and hold COAs for every SKU; review novel‑food compliance for ingestibles.
• Decide between PIVA or pay‑and‑reclaim; ensure customs agent declarations align with your choice.
• Collect and verify monthly C79s; retain them as VAT records.
• Review marketplace contracts to confirm who is the deemed supplier and who issues VAT invoices.
• Register for UK VAT if selling directly into the UK; check implications for non‑UK sellers.
• Validate commodity codes, customs valuation and duty exposure; budget duty as a non‑recoverable cost.
• Review partial exemption calculations if you have mixed taxable and exempt supplies.
• Update accounting software and MTD‑compliant processes to capture PIVA and import entries correctly.

Conclusion

2026 brings clearer expectations for CBD retailers: accurate import accounting, correct marketplace invoicing flows and documented C79s are essential to protect cashflow and remain compliant. Treat import duties as a real cost, confirm legal product status before sale, and decide whether PIVA or C79‑based reclaim suits your business model. Where complexity exists, working with a customs broker and an accounting adviser familiar with CBD product nuances will pay dividends — preventing surprises and keeping your operation confident and compliant in a fast‑evolving market.