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
| Question | FCA | DAP |
|---|---|---|
| Who books the main transport? | Buyer | Seller |
| Where risk passes | At the named handover point | At the named destination, ready for unloading |
| Export declaration | Seller | Seller |
| Import declaration | Buyer | Buyer |
| Import duty | Buyer | Buyer |
| UK VAT treatment of the export (typical) | Indirect export if the buyer collects and arranges the export | Direct 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:
- Direct export: you, the supplier, send the goods out of the UK and arrange the transport yourself or appoint a freight agent. A DAP sale with your own haulier fits here.
- Indirect export: an overseas customer or their agent collects the goods from you in the UK and arranges the export. An FCA sale where the buyer's carrier collects from your premises typically fits here.
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.
Which to choose for UK–EU road freight
FCA tends to suit you when:
- the EU buyer already has regular haulage and wants to control it;
- you want your risk to end at your gate or a named UK depot;
- you can secure reliable export evidence from the buyer's carrier.
DAP tends to suit you when:
- you want to sell delivered prices and control transit times;
- you prefer direct-export evidence under your own control;
- the buyer is organised enough to clear imports in time, since delays at destination still cost your haulier time.
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
- Write the full rule, the precise named place and the version, for example FCA [address] Incoterms 2020, in the contract and on the invoice.
- Confirm who files the UK export declaration and that they hold a GB EORI number.
- Under FCA, agree what export evidence the buyer's carrier will return and when.
- Under DAP, agree who pays for waiting time if import clearance at destination is late, and who unloads.
- Check that the buyer can act as importer in its country; the ICC notes Incoterms do not change tariff rates or customs procedures.
- If neither side has the in-house skills, read whether you need a customs broker.
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
Incoterms and customs: who clears goods and pays duty
Bringing a bicycle or e-bike from the UK to Poland
Sending one or two pallets from Poland to the UK
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 comparisonSources
- Customs valuation: Incoterms (GOV.UK)
- Using the Incoterms 2020 rules to manage tariff risk (ICC)
- DAP and DDP Incoterms 2020 explained (ICC Academy)
- VAT on goods exported from the UK, Notice 703 (GOV.UK)
- Making a full export declaration (GOV.UK)
General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.