Who Makes UK Importers' Customs Declarations?
Declarations from 30 UK importers, analysed in October 2026: who makes them, how long those arrangements last, and which duty routes go unused.
What the data shows.
Every one of their declarations was made by someone else, although the importer remains responsible for the declarations made in its name.
Source: Declarant EORI compared with importer EORI on every declaration, 30 importers.
Different parties made declarations in the median importer's name over the period: a main declarant and a tail of others. The range was 1 to 73.
Source: Distinct declarant EORIs per importer, 30 importers.
For the middle half of importers it was 52% to 91%. 11 of 30 relied on one declarant for 80% or more of their declarations.
Source: Largest single declarant's share of each importer's declarations, 30 importers.
Of the importers with declarations in more than one year. Six of the 13 kept it for four or five years running, as far back as our data for them goes.
Source: Main declarant per importer per calendar year, counting years with at least 50 declarations.
Straight releases, with no customs warehousing or other special procedure and no returned goods relief. 16 of 29 importers were at 95% or more. One customs-warehousing outlier is excluded.
Source: Share of each importer's lines declared under customs procedure code 4000, 29 importers.
Declarations with goods from a UK trade-agreement partner that paid full duty with no preference claimed. For a quarter of importers it was around one in five or more. Partner origin alone does not prove the goods qualified.
Source: Declarations with at least one line of trade-agreement partner origin, duty paid and no preference claimed, per importer, 30 importers.
How these figures are derived — sample size, date range and anonymisation — is set out in the methodology.
What does this data cover?
This report draws on the customs declarations of 30 UK importers that shared their HMRC declaration data with BorderAudit: about 1.56 million declarations and 2.4 million declaration lines, made between March 2021 and September 2026 and analysed in October 2026. These businesses chose to have their declarations analysed, and businesses that do so are more likely to suspect a problem, so every figure here describes the declarations we analysed, not UK imports as a whole. One importer accounts for about three-quarters of the declarations, so we report the median importer and the spread across importers, never a single pooled rate.
Who makes an importer's customs declarations?
Almost never the importer itself. 27 of the 30 importers made none of their own declarations: every one was made by a third party acting for them, such as a customs agent, freight forwarder or carrier. That is how UK importing normally works, and it is not a failing on anyone's part. But the importer remains responsible for the declarations made in its name, including the duty they declare, while the work itself sits with someone else.
How many declarants does an importer rely on?
Usually one main declarant and a tail of others. The median importer had 10 different declarants filing in its name over the period, and the main one made 61% of its declarations. For the middle half of importers the main declarant's share was between 52% and 91%; 11 of the 30 relied on one declarant for 80% or more, and two for all of them. The result is a declaration record built by several parties, none of whom sees all of it.
Do importers change declarant?
Most did not. Of the 19 importers with declarations in more than one year, 13 kept the same main declarant in every year, and six of those for four or five years running, which is as far back as our data for them goes. Continuity is often exactly what an importer wants: a declarant that knows the goods, the suppliers and the routes. The flip side is that once an arrangement is set, the way declarations are made in a business's name can go years without anyone comparing it with an alternative or a benchmark.
How often are special procedures and reliefs used?
For most importers, almost never. Leaving out one outlier whose imports run almost entirely through customs warehousing, the median importer made 99% of its import lines as straight releases, with no special procedure such as customs warehousing, inward processing or end use, and no returned goods relief. 16 of the 29 importers did so on 95% or more of their lines. Where goods and their use qualify, these routes can reduce or defer duty. Many importers' goods will not qualify, and the data cannot say which would have; it shows only that, for most importers, the routes went unused on nearly every line.
How often do goods from trade-agreement partners pay full duty?
For the median importer, 5% of declarations included goods from a country the UK has a trade agreement with that paid full duty with no preference claimed. The spread is wide: for a quarter of importers it was around one declaration in five or more, and four had none. A partner-country origin does not by itself mean the goods qualified for the lower rate: they must meet the agreement's rules of origin, and the importer must hold proof of origin. So these are declarations worth checking, not confirmed overpayments, and the figure is a lower bound, because about a third of lines record no origin at all.
What can an importer do with this?
Read back the declarations made in its name. Every UK importer can get its own declaration data from HMRC, and with it see who declared what, which procedures and preferences were used, and how its declarants compare. That is what a post-clearance audit does: BorderAudit reads the declarations made in your name from your HMRC data and checks every line for classification, valuation, origin and relief, whichever declarant made them.
Frequently Asked Questions
Written by James Holroyd, Head of Customs Operations, BorderAudit. Reviewed by the BorderAudit audit team. Data and methodology are described on the methodology page.