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The place for customs people

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16 December 25

1. DSV acquires DB Schenker — c. €14.3 billion This was by far the largest logistics transaction of 2025 and one of the biggest in industry history. Danish logistics group DSV completed its acquisition of DB Schenker from Deutsche Bahn for approximately €14.3bn. While Schenker is headquartered in Germany, the business has extensive UK operations across air freight, sea freight, road logistics and contract logistics. The deal dramatically reshapes the UK freight forwarding market, creating a dominant player with significant pricing power, network density and customs capability following years of post-Brexit complexity. 2. CMA CGM acquires Freightliner Group (UK) — c. £500–600 million (estimated) French shipping and logistics giant CMA CGM agreed to acquire Freightliner, the UK’s largest rail freight operator, from Genesee & Wyoming. Although the purchase price was not officially disclosed, industry analysts and transport media have consistently placed the value in the region of £500–600m. Freightliner operates critical UK rail freight corridors, ports and inland terminals, making this a strategically significant acquisition that strengthens CMA CGM’s intermodal and decarbonised logistics offering in the UK. 3. Sennder acquires C.H. Robinson’s European Surface Transportation business — c. €1.3–1.4 billion Digital freight forwarder sennder completed the acquisition of C.H. Robinson’s European Surface Transportation (EST) operations, a deal widely reported to value the business at around €1.3–1.4bn. The transaction included substantial UK operations, staff and customers, making it one of the largest road freight and forwarding deals affecting the UK in 2025. The acquisition significantly expanded sennder’s UK footprint and marked a major consolidation moment in European full-truckload and digital freight markets. 4. InPost acquires Yodel — c. £100–200 million (estimated) Polish parcel and logistics group InPost acquired Yodel, one of the UK’s largest parcel delivery and last-mile logistics operators. While the deal value was not formally published, market estimates and M&A league tables suggest a valuation in the range of £100–200m, reflecting Yodel’s scale but also margin pressures in the UK parcel sector. The acquisition gave InPost immediate nationwide coverage and significantly accelerated its UK growth strategy beyond parcel lockers into full last-mile logistics. 5. Premier Logistics acquires WT Transport — c. £20–30 million (estimated) At the domestic end of the scale, UK-based Premier Logistics acquired WT Transport, forming a larger regional freight, warehousing and distribution group. The combined business operates over 100 vehicles with more than 300,000 sq ft of warehouse space. While deal terms were undisclosed, industry estimates place the transaction in the £20–30m range. Although smaller than multinational deals, it was one of the most significant UK-to-UK freight acquisitions completed in 2025.

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11 December 25

1. TSI Instruments Ltd v HMRC — £8.43 million Import VAT Disallowed This 2025 First-tier Tribunal decision is one of the most financially significant UK customs VAT cases in recent years. TSI Instruments imported high-value scientific equipment into the UK for repair and calibration on behalf of overseas customers and paid import VAT on entry. HMRC later denied recovery of approximately £8.43 million, arguing that TSI was not the owner of the goods at importation and had failed to use an appropriate customs special procedure such as Inward Processing. The tribunal agreed with HMRC, confirming that paying import VAT does not create a right to recover it unless the importer has legal ownership or the correct procedure in place. The case has major implications for repair, maintenance and contract-manufacturing models. 2. DHL Air (UK) Ltd v HMRC — Over £3 million Customs Duty Assessment DHL Air challenged a substantial customs duty assessment exceeding £3 million relating to the import of civil aircraft parts under end-use relief. HMRC argued that DHL’s authorisation for the relief had expired at the time of import and that duty relief could not be applied retrospectively. The Upper Tribunal sided with HMRC, holding that customs reliefs must be properly authorised at the time of importation and that administrative oversight was not a defence. The case reinforces HMRC’s strict approach to procedural compliance and the high financial risk of lapses in customs authorisations for complex, high-value imports. 3. Canadian Solar EMEA GmbH v HMRC — Multi-Million Anti-Dumping Exposure In this complex trade defence case, HMRC challenged the classification and declared origin of imported solar panels, arguing that anti-dumping duties should apply due to Chinese components being routed through third countries. While the precise liability fluctuated during proceedings, the sums involved were multi-million-pound. The Upper Tribunal examined supply chain substance, transformation rules and evidential standards, supporting HMRC’s position that origin engineering cannot defeat trade remedies. The case highlights the growing enforcement focus on origin manipulation and the financial exposure associated with global manufacturing structures. 4. Roseline Logistics Ltd v HMRC — £1.12 million Import VAT Liability Roseline Logistics was held liable for £1.12 million in unpaid import VAT after submitting customs declarations using Postponed VAT Accounting (PVA) on behalf of an importer that was not VAT-registered at the time. HMRC argued that the declarations were invalid and that the customs agent bore joint and several liability. The First-tier Tribunal agreed, confirming that intermediaries have a duty to verify client eligibility for customs procedures. The case has sent shockwaves through the freight forwarding and customs brokerage sector, underlining that agents can carry material financial risk where compliance checks fail. 5. B&M Retail Ltd v HMRC — £1.17 million Excise Penalty Although primarily an excise case, B&M Retail’s dispute had a clear international trade dimension involving cross-border movements of excise goods. HMRC imposed a £1.17 million penalty for serious compliance failures, arguing that B&M handled excise goods without proper authorisation or controls. The Upper Tribunal upheld HMRC’s assessment, finding that governance failures justified a high penalty. The decision illustrates how excise liabilities arising from international movements can escalate rapidly when systems and oversight break down.

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10 December 25

6. FTU Pod Trans v HMRC — £472,000 Excise Duty and Smuggling Assessment FTU Pod Trans, a Polish haulage company, faced an excise duty assessment of £472,378 after HMRC discovered a large quantity of concealed cigarettes in a vehicle entering the UK. The company argued lack of knowledge, but the tribunal found sufficient evidence of involvement or negligence. HMRC’s assessment and accompanying penalties were upheld. The case demonstrates HMRC’s robust enforcement posture on illicit cross-border trade and the severe financial consequences for logistics operators implicated in smuggling, whether directly or indirectly. 7. Reliable Shipping Ltd v HMRC — £320,000 Customs Duty and Import VAT Reliable Shipping challenged HMRC assessments totalling over £320,000, arising from alleged undervaluation and misclassification of imported goods. HMRC rejected claims that the company was unable to pay or that assessments were excessive. The First-tier Tribunal upheld HMRC’s position, reinforcing that valuation errors — whether deliberate or careless — can result in significant retrospective liabilities. The case is frequently cited in discussions on customs valuation risk and the importance of defensible transfer pricing and invoice structures. 8. Piramal Healthcare UK Ltd v HMRC — £196,000 Import VAT Repaid Piramal Healthcare was required to repay £196,254 in import VAT it had reclaimed on goods imported into the UK for processing. HMRC argued that Piramal did not own the goods at import and therefore had no entitlement to recover the VAT. The tribunal agreed, confirming that ownership at the time of importation is fundamental to VAT recovery. Although smaller in value than some cases, the decision has wide relevance for contract manufacturing, toll processing and pharmaceutical supply chains. 9. Canmi Ltd v HMRC — Customs Broker Liability for Excise Duty In this case, customs intermediary Canmi Ltd was held jointly and severally liable for £13,972 in unpaid excise duty due to incorrect declarations on beer imports. While the monetary amount was relatively modest, the principle was significant: HMRC successfully argued that intermediaries cannot rely solely on client instructions where errors occur. The tribunal’s decision reinforces the compliance burden placed on customs brokers and the potential for liability even in low-margin transactions. 10. FTU Pod Trans — £307,000 Wrongdoing Penalty (in addition to Duty) Separate from the underlying excise duty assessment, HMRC imposed a £307,045 wrongdoing penalty on FTU Pod Trans. The tribunal upheld the penalty, finding that the behaviour met the threshold for deliberate or serious non-compliance. The case illustrates how penalties can nearly double the financial exposure in international trade enforcement actions, particularly where HMRC concludes that conduct goes beyond mere carelessness.

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26 November 25

The UK Government has opened a new application window for duty suspensions and autonomous tariff quotas (ATQs), reinforcing its post-Brexit strategy to support domestic manufacturers and processors facing global cost pressures. The programme allows UK and Crown Dependency businesses to temporarily reduce or remove import duties on specific goods, typically raw materials or components used in production, helping firms remain competitive in international markets. What are duty suspensions and ATQs? Duty suspensions remove or reduce customs duties on eligible goods for a defined period, with no limit on the volume that can be imported at the reduced rate. Autonomous tariff quotas (ATQs), by contrast, allow only a capped quantity of goods to benefit from lower tariffs, after which normal duties apply. Both mechanisms apply on a Most Favoured Nation (MFN) basis, meaning qualifying goods can be sourced from any country or territory. The concessions do not affect other charges such as VAT or trade remedy measures, including anti-dumping duties. Crucially, duty suspensions and ATQs are open to all UK and Crown Dependency importers while in force, rather than being restricted to the original applicants. Where multiple tariff concessions exist, importers are encouraged to ensure goods are declared under the most advantageous rate. Northern Ireland considerations: Businesses importing goods into Northern Ireland under a duty suspension or ATQ must also consider whether goods are “not at risk” of moving into the EU, a key requirement under the Windsor Framework. HMRC guidance applies to ensure compliance with UK-EU trading arrangements. Current suspensions and how to apply: Existing duty suspensions can be identified via the UK Trade Tariff lookup tool, with a comprehensive list and expiry dates published in the Tariff Suspension Reference Document. The application window for new duty suspensions covering the 2025–2026 cycle is now open, with a deadline of 11:59pm on Wednesday 4 February 2026. Applicants are advised to consult the government’s suspension guidance pack, which sets out eligibility criteria, assessment processes, and detailed instructions for completing applications. Support is available from the Tariff Suspensions Team at the Department for Business and Trade. Review of expiring measures: Alongside new applications, the Government is undertaking a major review of existing suspensions. Around 290 duty suspensions are due to expire in 2026. While these measures were originally scheduled to end on 30 June 2026, they will now be extended to 31 December 2026 to allow a public review to run alongside the current application window. Stakeholders are being invited to submit views both for and against extending these suspensions further, potentially to 31 December 2028. Feedback must be submitted by 11:59pm on Wednesday 4 February 2026.

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26 November 25

The Chancellor’s latest Budget has signalled a significant shift for the UK retail sector, with plans to phase out the long-standing “de minimis” tax exemption on low-value imports. The change, which will end the duty-free treatment of overseas parcels valued at £135 or less, is designed to level the playing field between domestic retailers and international e-commerce platforms. For years, British high-street and online retailers have argued that the exemption has distorted competition, allowing ultra-low-cost overseas sellers — notably fast-growing platforms such as Shein and Temu — to undercut UK prices. While VAT is typically collected at the point of sale, the absence of customs duty and simplified import procedures have reduced costs for overseas sellers and fuelled a surge in direct-to-consumer parcel volumes. What is the de minimis rule? Under the current system, goods valued at £135 or below can enter the UK without incurring customs duty, using a simplified import process. The policy was originally designed to reduce administrative burdens on customs authorities and speed up cross-border trade. However, critics argue that it has become outdated in an era of mass e-commerce, contributing to an influx of low-value parcels and raising concerns about product standards, safety, and regulatory compliance. Government direction of travel While the exemption will not be removed immediately, the Government has made clear its intention to phase it out over time. Industry sources indicate that full implementation may not occur until around 2029, allowing retailers, logistics providers, and HMRC to adapt systems and processes. Further guidance from HMRC on the treatment of low-value imports is expected as part of the transition. For UK retailers, the move represents a long-awaited policy shift. Removing the exemption is expected to reduce the price advantage enjoyed by overseas sellers and help address concerns that cheap imports are undermining domestic businesses. The Government also argues that tighter controls will improve consumer protection by ensuring imported goods meet UK regulatory and safety standards. From a fiscal perspective, the Treasury expects the change to generate hundreds of millions of pounds in additional revenue once fully implemented. However, consumers may eventually see higher prices or additional charges on low-value overseas purchases, particularly as customs duties are applied more widely. The UK’s decision mirrors a broader international reassessment of de minimis thresholds. The EU is considering reforms to its own low-value import regime, and the United States has also faced mounting political pressure to tighten its de minimis rules amid similar concerns over unfair competition and product safety. Together, these developments point to a global shift away from policies designed for a pre-e-commerce era. In the short term, shoppers will continue to benefit from low-cost overseas purchases. But the direction is clear: the gradual removal of the de minimis exemption marks a structural change in the online retail landscape, with far-reaching implications for cross-border trade, pricing strategies, and supply chains over the coming years.

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30 July 25

Businesses in the UK that need to import goods under special customs procedures – but don’t hold an existing authorisation – can now use a simplified process known as Authorisation by Declaration (AbD). The scheme provides temporary customs relief, easing import duties and VAT under certain conditions. But the option comes with restrictions, and government guidance warns it’s best suited to occasional or one-off use. AbD functions as a one-off authorisation tied to a single customs declaration. It gives businesses temporary access to customs special procedures – such as inward processing, authorised use, and temporary admission – allowing them to suspend duties while goods are stored, processed, or used temporarily in the UK. The simplified option is available up to 10 times per year and applies only to consignments valued under £500,000. These limits do not apply to Temporary Admission, which allows goods to be brought in for a defined period without paying duties, provided they are not altered during their stay. While AbD can offer valuable savings, it usually requires a refundable financial guarantee covering the full amount of customs duty and VAT. The government notes that companies seeking a longer-term or more frequent use of special procedures may find it easier and cheaper to apply for prior authorisation, which in most cases removes the need for a guarantee. The Department for Business and Trade encourages businesses to carefully assess their needs. AbD is particularly useful for firms that: - Rarely use special customs procedures - Have a one-time need not covered by an existing authorisation - Prefer not to go through a formal pre-approval process Offence and Defence: How Special Procedures Work Special customs procedures are a key tool in the UK’s broader trade strategy, offering both flexibility and cost savings. They include: - Temporary Admission: Imports goods for temporary use with duties suspended. Alterations are not permitted, but repairs are allowed. - Inward Processing: Allows goods to be processed in the UK without immediate duty or VAT. Duties apply only if the goods enter the domestic market. - Authorised Use: Grants duty relief if goods are used for a specific, approved purpose. - Outward Processing: Lets companies send goods abroad for repair, with reduced duties when they are returned to the UK. To use AbD, businesses must: - Declare the appropriate procedure code on their import or export declaration - Provide a security deposit or financial guarantee - Keep clear records and submit a bill of discharge (when required) to reclaim any deposit - If using an agent to file declarations, businesses must inform them of the intention to use AbD and agree on how the guarantee will be handled. Limits and restrictions, there are several cases where AbD is not allowed. These include: - Customs warehousing - Goods subject to anti-dumping duties - Use of simplified declarations for imports - Backdated or retrospective authorisations - Use of equivalence procedures (substituting goods in processing) - Inward Processing Exemptions: AbD cannot be used for processing controlled items such as weapons, excise goods, works of art, or catalysts, among others. Companies must process their own goods and cannot outsource processing under AbD. - Outward Processing under AbD is limited to repairs only. Goods cannot be altered or further processed abroad under this scheme. - Temporary Admission also comes with conditions: goods must be used for a specific, approved purpose, not be substantially altered, and must be re-exported within a set timeframe – usually up to two years. The Authorisation by Declaration scheme offers UK businesses a flexible route to benefit from customs duty relief – but it’s not a one-size-fits-all solution. For companies with occasional or one-off needs, it presents a convenient option. However, those requiring frequent access to customs procedures, or dealing in sensitive goods, may be better served by pursuing full authorisation. Businesses are encouraged to review the full government guidance and consult with HMRC or a customs advisor to ensure compliance. https://www.gov.uk/guidance/using-a-special-procedure-without-a-prior-authorisation

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