Customs Audit Checklist: 15-Point Self-Assessment for UK Importers

17% of UK import declarations contain errors. Use this 15-point checklist to identify and correct issues before HMRC does.

Classification Checks

1. Commodity Code Accuracy

• Review your top 20 commodity codes by import value and volume.
• Cross-check each code against the UK Trade Tariff (including duty rate, VAT rate, and any measures).
• Confirm the description, material composition, and function of the goods match the selected code.
• Document who approved each code and when it was last reviewed.

2. Classification Consistency

• Compare declarations across different months, sites, and brokers.
• Confirm identical or similar products are classified under the same commodity code.
• Check for legacy or superseded codes still in use.
• Maintain a central classification database and ensure brokers use it.

3. BTI/ATaR Coverage

• Identify high-value and high-volume commodity codes.
• Confirm whether Binding Tariff Information (BTI/ATaR) decisions exist for these codes.
• Check BTI/ATaR validity dates and conditions of use.
• Ensure BTI references are correctly quoted on declarations and stored in your records.

Valuation Checks

4. Transaction Value Methodology

• Confirm the primary method used is the transaction value of the goods.
• Verify the price basis (Incoterms, currency, and invoice terms) is correctly reflected in the customs value.
• Where transaction value cannot be used, document the alternative valuation method and justification.

5. Additions and Deductions

• Check whether the following are correctly treated in the customs value:
• Assists (tooling, design, or materials supplied free or at reduced cost).
• Royalties and licence fees related to the imported goods.
• Commissions (buying vs selling commissions).
• Transport, insurance, and handling costs to the place of introduction into Great Britain.
• Confirm non-dutiable post-importation charges (e.g. inland freight, post-import installation) are excluded.

6. Related Party Transactions

• Identify imports from related companies or group entities.
• Confirm transfer pricing policies are documented and aligned with customs valuation rules.
• Check for any transfer pricing adjustments and how they are treated for customs purposes.
• Retain evidence that prices are at arm’s length (e.g. benchmarking, comparables).

Origin and Preference Checks

7. Preference Utilisation Rate

• Identify imports that could qualify for preferential duty rates under FTAs.
• Calculate the percentage of eligible imports where preference is actually claimed.
• Investigate low utilisation rates and determine whether missing documentation or process gaps are the cause.

8. Origin Documentation

• Verify that EUR.1 certificates, Statements on Origin, and REX registrations are valid and complete.
• Check that supplier declarations contain all mandatory data and are signed/dated where required.
• Confirm retention of origin evidence for the statutory period.
• Ensure documents clearly link to the relevant consignments and commodity codes.