It’s International Trade Week
Only a few years ago, Brexit brought one of the biggest changes UK customs has ever faced, and COVID sent shockwaves through global markets. What’s different now is that customs teams aren’t dealing with one big shift but many at once.
In the last 18 months UK importers have absorbed, amongst others, US tariffs that rewrote supply chain maths overnight, disrupted shipping through the Strait of Hormuz, renewed talk of closer ties with the EU (and louder calls to rejoin), a UK carbon border tax that starts on 1 January, and the EU Deforestation Regulation due to bite on 30 December unless Brussels moves the date again.
All of that lands on the same desk
In most businesses I visit, that desk belongs to a small customs team, sometimes one person, often reporting two or three levels below anyone who signs off the accounts.
That gap matters because every change on the list carries a price:
- Duty sits in your cost of sales.
- Import VAT and deferment guarantees tie up cash.
- HMRC can issue a post-clearance demand reaching back three years, plus interest.
In my experience customs gets a voice at board level once, usually after HMRC has written. By then the CFO is managing a liability that started life as a sourcing decision three years earlier.
Case in point: Morrisons and aluminium foil
Take Morrisons. Between 2018 and 2020 it imported household aluminium foil from Thailand. HMRC argued the foil was Chinese, made in China and annealed in a Thai factory set up to avoid anti-dumping duty. The First-tier Tribunal agreed. It noted it could barely tell the foil apart before and after the Thai processing, and dismissed the appeal (WM Morrison Supermarket Ltd v HMRC [2025] UKFTT 1145 (TC)). The bill came to £4.76m.
2018 to 2020
foil imported from Thailand
£4.76m
the final bill
A buyer in 2018 probably saw a sensible supplier. Years later the board saw a seven-figure demand.
The same origin question sits at the centre of today’s US tariffs. If your goods pass through a third country on the way to a better rate, someone in your business needs to prove where they originate, with evidence that would stand up at tribunal.
Hidden costs and new regimes
Hormuz shows how cost creeps in without anyone noticing. UK customs value includes freight and insurance to the UK border. When carriers add fuel surcharges and war-risk premiums, your duty bill rises on the same goods at the same purchase price. Few finance teams track that. Your customs lead may already have spotted it.
Then come the new regimes:
- UK CBAM needs embedded emissions data from overseas producers who may never have measured it.
- The EUDR needs geolocation data for cattle, cocoa, coffee, palm oil, rubber, soya and wood products going into the EU.
Neither dataset lives in your ERP today, and nobody can assemble either one in the week before a deadline.
For years customs sat in the corner of the business as a dark art, rarely understood and consulted after the fact. I think that era has ended. A good customs team protects margin, cash and reputation in the same afternoon, and the best ones find savings that pay for themselves, whether that’s a reclassification, a relief or a preference claim nobody made.
They seldom get thanked, because their best work is the audit that never turns into a story.
Three questions for finance
If you sit in finance, ask the business three questions before the year ends.
1
When did we last get an independent view of our customs landscape?
2
If HMRC challenged us tomorrow, could we produce the evidence quickly and with confidence?
3
Can someone show me our customs strategy, the written plan we’re actually working to?
If you get a recent date, a confident yes and a document, your customs team has things in hand, and it’s worth telling them so. If you don’t, customs is probably being handled ad hoc, and you’ve found a 2027 priority while it’s still cheap to fix.
Contact us
Barbourne Brook works with in-house customs and finance teams to reduce duty costs, protect against audit risk and reclaim overpaid duty. If you’d like a second pair of eyes on any of those three questions, we’re happy to talk. Call Adam Wood for a confidential, no-obligation conversation on 01905 975399.
Sources and notes
WM Morrison Supermarket Ltd v HMRC [2025] UKFTT 1145 (TC), The National Archives Find Case Law.
This article is general information and not legal, tax or customs advice.
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