Documentary vs Physical Checks: What Differs and How to Prepare

How the authority decides what to check

Customs authorities check declarations on the basis of risk analysis (Article 46 of the Union Customs Code). A declaration is verified by the system and may then be released without further action or referred for checking. The selection criteria are not public, and checks can also be random (Article 46(2) UCC), so you cannot assume a well-prepared consignment will always pass unchecked. In Great Britain CDS declarations are verified by HMRC, and goods may be examined by Border Force.

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Documentary check

A documentary check means examining the declaration and the accompanying documents without opening the consignment. The authority may request the invoice, waybill, proof of origin, permits, the sales contract or proof of payment to verify the customs value, classification and origin. In the EU the basis is Article 188 UCC, which lets the authorities examine the declaration and documents and require additional documents. Typical reasons for a query are an overly generic description of goods, value discrepancies between documents and missing proof of origin – the same mistakes are covered in 3 PL-UK customs document mistakes.

Physical check

A physical check means examining the goods themselves: checking quantity, markings, packaging and whether they match the declared description, and where needed weighing them or taking samples for testing. It requires access to the goods, so it usually extends clearance time and can cause extra transport or storage costs. The EU basis is also Article 188 UCC; in practice a physical check is usually preceded by an analysis of the documents. What an inspection at the border looks like is described in What does a customs inspection look like.

What to do if your goods are held

• check in the declaration system or with your agent exactly what the authority is asking for,
• provide missing documents or explanations as quickly as possible, because until the matter is resolved the goods are usually not released,
• for a physical check, provide access to the goods and the transport documents,
• if the declaration contains an error, use the correction procedure (how to amend a declaration).

Also helpful are What to do if customs control holds your goods and the 15-minute checklist for carriers and forwarders.

How to prepare for a check

Before lodging the declaration, make sure the invoice, packing list, transport document and policy are consistent, that the description is precise with the right HS code, and that you hold proof of origin if you claim a preferential rate. Document the customs value so that it can be defended (customs value of goods). It is also worth agreeing with your agent who is responsible for which data, and keeping correspondence and the history of tariff queries.

Checks after release

Authorities can also check a declaration after the goods have been released. In the UK import and export declarations must be kept for at least 4 years and VAT records for at least 6 years (gov.uk – Archiving your trade documents); in the EU customs documents for at least 3 years (Article 51 UCC). Post-clearance checks are described in Customs audits after clearance. When you use an agent, remember that under indirect representation the agency is jointly liable with the client, while under direct representation it is not, as a rule.

Easy Clearance specialises in clearances to and from the UK – if you need help, get in touch with us.

Frequently asked questions