UK Customs Declaration: How to Make an Import or Export Declaration

A UK customs declaration is the formal notification to HMRC of what goods you are moving, what they are worth and which customs procedure they are to be cleared under. For imports into and exports from Great Britain it is made on the Customs Declaration Service (CDS), usually through customs software or an agent, and before you start you need a GB EORI number, a commodity code, the customs value and a complete set of commercial documents.

What a UK customs declaration is

A customs declaration is the act by which a person, in the prescribed form and manner, indicates a wish to place goods under a given customs procedure (for example, release for free circulation). That is the definition in the Union Customs Code (Article 5(12) of Regulation 952/2013), which applies on the EU side – where Polish exporters send their goods from. In the UK, the rules on making declarations come from the Taxation (Cross-border Trade) Act 2018, Schedule 1 and HMRC guidance.

In practice this means that:

• a person may make a declaration if they are able to present the goods to Customs on import, or to secure that the goods are presented (Schedule 1, paragraph 2),
• a declaration can be made in advance, but it is treated as withdrawn if the goods are not presented within 30 days, unless HMRC sets a different period by public notice (paragraph 3),
• you can amend or withdraw a declaration until HMRC indicates it intends to verify it, begins to verify it or accepts it (paragraph 15).

A customs declaration is not the same as an entry summary declaration (ENS), the safety and security notification made before goods arrive. That is a separate obligation, which the carrier is responsible for, described in GOV.UK guidance on making an entry summary declaration. For the wider process, see What is customs clearance and Customs clearance when importing goods into the UK – step by step.

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Import and export declarations – when to make them

Both are made on CDS, but the timing and consequences differ. The summary below follows HMRC guidance (import, export).

Importing into the UK

• Locations using the Goods Vehicle Movement Service (GVMS), and some ports that require a declaration before departure: the full import declaration must be made before the goods board the vessel or train.
• In advance: you may be able to declare up to 30 days before the goods arrive, but the declaration is only formally accepted once the goods have arrived and been presented to customs.
• After temporary storage: where a temporary storage declaration has been made, the full import declaration must be made within 90 days of the goods being presented to customs.
• Other locations without temporary storage facilities: the timescale is set by the operator of that location.

Exporting from the UK

You or your representative must make the export declaration and get clearance before the goods leave the UK. The minimum lead times depend on the last mode of transport:

After you declare, HMRC must also be told the goods have left (a departure message). At GVMS locations this depends on the haulier creating a goods movement reference (GMR) that includes all the DUCRs. Without a departure message the declaration cannot be used as official evidence of export (exporters can instead use commercial evidence, as set out in VAT Notice 703, to zero-rate the goods for VAT). See also Exporting to the UK – who is responsible for clearance.

Who makes the customs declaration

The importer or exporter makes the declaration, or a representative they appoint. HMRC says you can use a freight forwarder, customs agent or broker, or express operator (who must be established in the UK for customs), and most importers use a transporter or customs agent. HMRC publishes a register of customs agents and express operators.

• Direct representation: the representative acts in the name of the person they represent.
• Indirect representation: the representative acts in their own name but on behalf of the principal. The agent and the principal are then jointly and severally liable for any customs debt, and HMRC may seek payment from either (Customs debt liability).

The terms of the representation should be confirmed in writing and must show whether the representative acts directly or indirectly (GOV.UK guidance). Either way, due diligence for your declarations remains your responsibility (due diligence guidance). The differences are covered in Direct and indirect customs representative.

What you need before you start

In practice most mistakes come from inconsistent documents. The invoice, packing list, transport document and the declaration data must all say the same thing about the goods, their value, weight and the parties. It helps to name one person who checks the full set before it is sent.

How to make the declaration step by step

1. Settle the roles. Who is the importer or exporter, whose EORI number goes on the declaration, and is a representative acting (direct or indirect)?
2. Arrange access. Subscribe to CDS or make sure your representative does. Decide whose account will be used for payment.
3. Gather the documents. Commercial invoice, transport document, packing list, and any licences or certificates the goods need.
4. Confirm the commodity code, value and origin before preparing the declaration, not after it.
5. Complete the declaration on CDS following HMRC’s instructions (the data elements are set out in Customs declaration completion requirements for Great Britain) and submit it within the deadline for your route.
6. Watch the CDS messages. Once accepted, HMRC tells you how much you owe, and may ask for supporting documents for a check. You receive a message when the goods are cleared.
7. Pay or account for the charges and keep your records (see below).

Simplified declarations and entry in the declarant’s records (EIDR)

Businesses that clear goods regularly can apply to HMRC for authorisation to use simplified declarations, which requires written procedures and HMRC approval (Using simplified declarations for imports). There are two routes: a simplified frontier declaration, or entry in the declarant’s records (EIDR). Both are followed by a supplementary declaration; for entry in your records, it is due by the 10th calendar day of the month after the month in which you entered the goods in your records (Making an import declaration in your records). Authorisation requires, among other things, UK establishment, a good compliance record and a duty deferment account, so it is not an option for a one-off import. See Simplified import procedure.

Payment: duty, VAT and deferment

When the declaration is accepted, HMRC tells you what you owe. Duty must be paid before the goods can be released, and on CDS there are several ways to pay (How to pay duties and VAT on imports):

• Duty deferment account: one Direct Debit payment a month instead of paying for each consignment. For declarations made on CDS, duties and import VAT deferred during a calendar month are paid on the 16th of the next month (or the next working day), an average of about 30 days’ credit. You cannot defer if you have exceeded your guarantee or account limit (How to use your duty deferment account). See How a UK deferment account works.
• Cash account – paying from your balance when you declare – or a general guarantee account, which may be needed, for example, for temporary admission or where the duty is disputed or unknown.
• Immediate payment where you need to settle the amount at once.
• Postponed VAT accounting (PVA): you declare and recover import VAT on your VAT Return instead of paying it at the border. It requires UK VAT registration and no HMRC approval; a business without a UK establishment must act through a representative who selects the option on the declaration (Check when you can account for import VAT on your VAT Return). More detail: Postponed VAT accounting in the UK.

If you hire someone to deal with customs, you can authorise them to use your deferment, cash or guarantee account. The costs of using an agency are covered in How much does UK customs clearance cost.

Errors and corrections

What you can do depends on how far the declaration has progressed (Amend or cancel a CDS import declaration):

• Before clearance: you can amend an import in your CDS software if the declaration has not cleared and you have not received the final tax calculation message. If you cannot amend it, you can cancel and resubmit. For exports, you can amend the declaration before it has been cleared by customs.
• After clearance: you cannot amend or cancel in your software, and must contact HMRC. You have up to 3 years to amend and 90 days to cancel, counted from when the declaration is accepted or a control is applied to the goods, whichever is earlier.
• Underpaid duty or VAT: report it through a voluntary disclosure (form C2001). Overpayment: claim a repayment (C285).
• Importer details can only be changed after clearance if they are incorrect, and only by contacting HMRC with supporting evidence.

For exports, the statistical record can be amended up to 3 years after clearance (Making a full export declaration). Remember that you may be liable for a wrong declaration even when a representative made it.

Common mistakes before you declare

1. Declaring in a hurry before anyone has closed out the input data.
2. Unclear who is declaring and whose EORI number is used.
3. Mismatches between the invoice, the packing list and the declaration data.
4. Checking the commodity code or customs value only after submission.
5. No named person responsible for the final check.

Keeping records

HMRC expects records of traded goods you declare to be kept for 4 years, and in the event of a criminal investigation records dating back 10 years may be used (Archiving your trade documents). In the EU the minimum is 3 years (Article 51 of the Union Customs Code). Keep an electronic copy of the declaration and the accompanying commercial documents.

Also see this video

A short explanation of the logic behind a UK customs declaration.

If you would like to check what is missing from your data and documents before you declare, get in touch with us. For the clearance process itself, see step by step; for the registration number, how to get an EORI number in the UK.

Frequently asked questions