This article was published before we became the Chartered Institute of Export & International Trade on 10 July 2024, and this is reflected in references to our old brand and name. For more information about us becoming Chartered, visit our dedicated webpage on the change here.

woman doing paperwork

Firms importing goods from the EU have been reminded that the clock is ticking towards new paperwork and customs checks that are being introduced from 1 October, amid concern that many are still not prepared.

The government postponed the start of import controls in March for six months to give businesses more time to prepare and for border control infrastructure to be set up. 

Time to prepare

Importers have been required to keep internal records of imports since the start of the year, but may have to start providing documentation from 1 October – initially for goods subject to sanitary and phytosanitary (SPS) controls such as meat, cheese and eggs.

Full customs checks on all imports begin on 1 January 2022 with tariffs, duties and VAT deferrable until the end of the year.

Far from over

International trade experts have told the Times of the importance of importers preparing for these upcoming rule changes now.

Marco Forgione, director general of the Institute of Export & International Trade, said: “Brexit changes are far from over. Government has to act now to make sure that businesses know they have to prepare, they have to get trained up and get good advice.”

New responsibilities

As reported in IOE&IT News, HMRC has written to more than 160,000 businesses reminding them of their responsibilities.

Those who deferred customs declarations in January are having to now file supplementary declarations for their goods movements.

These declarations must be completed 175 days after the date that the goods were imported into the UK.

Non-compliant businesses could lose the right to delay future declarations and could face financial penalties.

No light touch

Elly Darkin, a senior associate at Global Counsel, said some EU importers had mistaken the ongoing easements from the government as a permanent “light touch” approach to customs checks. 

She also urged businesses to check that their partners are ready to comply.

“There is an issue among the EU supply base, to varying degrees, about the current state of play being the new normal for businesses, whereas everything we know points to the contrary,” she said.

The 2022 challenge

According to Lloyd’s Loading List freight companies view January 2022 – when full customs procedures will come into effect for all imports – as an even bigger challenge than January 2021, “because there are more new processes to master”

Robert Keen, director general of freight association BIFA, said his members were ready, but any importers that are new to the customs environment should beware.

“That’s why we are encouraging them to consider appointing a freight forwarder, if they haven’t already done so, to deal with their customs documentation, whilst they concentrate on their core business,” he said.

Further clarity needed

BIFA also pointed to gaps in the information provided by government, including clarity on which ports will be operating a pre-lodgement model as opposed to a temporary storage model for processing cargo.

Its members are also concerned about whether the necessary infrastructure will be built in time.


A total of 560 traders attended a recent Institute of Export webinar on the upcoming rule changes.

IOE&IT Academy director Kevin Shakespeare warned attendees that government easements didn’t mean they could do nothing.

“You need to prepare for this new timetable,” he said. “The clock has started ticking.”