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Guides / FCA vs DAP · Updated 19 October 2026

FCA vs DAP Incoterms: the difference for UK exporters

Under both FCA and DAP the seller clears the goods for export and the buyer clears them for import and pays the duty. The real difference between FCA and DAP is who books the transport, where risk passes and, for UK exporters, what proof of export you can get for zero-rated VAT.

This guide is also available in Polish.

FCA vs DAP Incoterms: the short answer

Under both FCA (Free Carrier) and DAP (Delivered at Place) the seller handles export clearance and the buyer handles import clearance and pays the import duty. The ICC's own guidance note on tariffs sets this out rule by rule: for FCA and DAP alike, export customs clearance sits with the seller, and import customs clearance and tariffs sit with the buyer. The only Incoterms rule that puts import duties on the seller is DDP.

So the difference between FCA and DAP is not who pays the duty. It is who books the lorry, where the goods are delivered, and how long the seller carries the risk. For a UK exporter there is a fourth difference that is easy to miss: the VAT evidence you need to zero-rate the sale.

Where delivery and risk pass

FCA: risk moves at the handover point

HMRC's summary of the rules says that under FCA the seller delivers the goods to the carrier or another person nominated by the buyer, at the seller's premises or another named place, and that risk passes to the buyer at that point. HMRC advises the parties to specify the point within the named place as precisely as possible.

ICC Academy material adds a practical detail. If the named place is your own premises, delivery is complete once you have loaded the goods onto the buyer's collecting vehicle. If it is somewhere else, such as a forwarder's depot, you deliver the goods on your own transport, ready to be unloaded. In either case the buyer arranges the onward transport.

DAP: risk stays with the seller until destination

Under DAP the seller delivers when the goods are placed at the buyer's disposal on the arriving vehicle, ready for unloading at the named place of destination, and bears all risks of getting them there. The seller contracts and pays for the transport. Unloading is for the buyer, unless the transport contract makes it the seller's cost.

One nuance matters on UK–EU road freight. The ICC notes that under DAP the buyer bears the risk of loss or damage during the import clearance process. Your haulier, though, is still on the clock if the buyer's import entry is late, so DAP sellers should agree in advance who pays if the vehicle is kept waiting.

FCA and DAP side by side

QuestionFCADAP
Who books the main transport?BuyerSeller
Where risk passesAt the named handover pointAt the named destination, ready for unloading
Export declarationSellerSeller
Import declarationBuyerBuyer
Import dutyBuyerBuyer
UK VAT treatment of the export (typical)Indirect export if the buyer collects and arranges the exportDirect export

For how other terms such as EXW, DPU and DDP split the customs jobs, see our wider guide to Incoterms and who clears customs.

The UK side: your export declaration under either term

Whichever term you pick, the goods need a UK export declaration. Gov.uk says you or your representative must submit it and get customs clearance before the goods are allowed to leave the UK. By road, the declaration must be made at least one hour before departure, and at locations that need an "arrived" declaration it must be in before the goods start their journey to the border.

Under DAP your haulier is your responsibility, so it is your job to make sure they build a goods movement reference that includes the export declaration's Declaration Unique Consignment Reference (DUCR). HMRC asks exporters to make sure hauliers do this at GVMS locations, because that is how the departure message reaches HMRC. Under FCA the buyer's haulier collects, so you need the same cooperation from a carrier you did not hire.

Why the difference between FCA and DAP matters for VAT

To zero-rate goods exported from Great Britain you need evidence that they left the UK. HMRC VAT Notice 703 distinguishes two cases:

Both must be exported, and evidence obtained, within three months of the time of supply. Official evidence is a CDS export declaration that has generated a departure confirmation; commercial evidence includes a CMR fully completed by consignor, haulier and consignee. For indirect exports HMRC says the standard of evidence is high, because the carrier works for your customer. It recommends writing the buyer's duty to provide export evidence into the sales contract, and considering a deposit equal to the VAT you would owe if the evidence never arrives. If the evidence is missing or unsatisfactory, the supplier becomes liable for the VAT.

An FCA sale feels simpler because the buyer sends the lorry, but you still file the export declaration and you carry the VAT risk if the buyer's carrier cannot prove the goods left. Agree in writing which documents the carrier will return to you before the goods are loaded.

Which to choose for UK–EU road freight

FCA tends to suit you when:

DAP tends to suit you when:

Easy Clearance also compares FCA or DAP for Poland–UK shipments, written for EU sellers sending goods into Britain.

Checklist before you agree the term

Incoterms are a contract tool: HMRC's guidance notes that they are developed and maintained by practitioners brought together by the ICC. Make sure the contract, the invoice and the declarations tell the same story.

Related guides

Weighing FCA against DAP?

Easy Clearance is a UK–EU customs clearance agency handling import and export declarations, T1/T2 transit and UK–Poland removals. Its article compares DAP and FCA on the UK–Poland trade lane.

Read the DAP vs FCA comparison

Sources

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.