Guide
Make a customs declaration on CDS for an import into Great Britain
How to prepare and submit a standard customs import declaration on HMRC's Customs Declaration Service (CDS) for goods entering Great Britain. Covers data gathering, commodity-code classification, customs procedure code, valuation, duty and import VAT, submission via software or a customs intermediary, query notes, and the four-year record-keeping rule.
If you import commercial goods into Great Britain (England, Scotland or Wales), you must make a customs declaration to HMRC for almost every consignment. The declaration tells HMRC what the goods are, where they came from, what they are worth and how much duty and import VAT you owe. It is the legal mechanism that releases your goods into free circulation.
You make the declaration through the Customs Declaration Service (CDS) — the only HMRC platform for import declarations since CHIEF closed on 1 October 2022. CDS does not have a public web form: declarations are submitted through CDS-connected software, and most importers do this through a customs intermediary (a freight forwarder, customs agent or fast-parcel operator) rather than connecting in-house.
This guide walks through a standard (full) declaration. If you have authorisation for the Simplified Customs Declaration Process — a two-step regime where a basic declaration releases the goods and a supplementary declaration follows by the fourth working day of the next month — see Use simplified customs procedures (SCDP) instead.
Before you start
You need to have these in place before the goods reach the border. A declaration cannot be lodged without them, and goods stuck at the frontier accrue storage and demurrage charges:
- a GB-prefix EORI number — apply at gov.uk/eori, free, allow up to 5 working days
- a customs intermediary appointed in writing (with direct or indirect representation), or your own CDS-connected software with a CDS subscription
- a method of paying duty and import VAT — either immediate payment, a duty deferment account with a Customs Comprehensive Guarantee, or (for VAT only) Postponed VAT Accounting
- any import licence or certificate required for controlled goods (firearms, plants, food of animal origin, dual-use items, medicines)
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1. Gather the source documents
Pull together the paperwork that the declaration draws from: the commercial invoice (price, currency, Incoterms), the packing list (weights, packages, marks), the transport document (bill of lading, air waybill or CMR), and — if you intend to claim a preferential tariff rate — a valid proof of origin from the exporter (statement on origin, REX number, or the basis for an importer's-knowledge claim). Errors at this stage propagate into every later step.
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2. Determine the commodity code
Classify each line of goods to a 10-digit commodity code using the UK Integrated Online Tariff at gov.uk/trade-tariff. The commodity code drives the duty rate, the VAT rate, any quotas or anti-dumping duties, and any import controls. Misclassification is the single most common cause of customs penalties. If the goods are technical or a borderline case, request a Binding Tariff Information (BTI) ruling from HMRC for legal certainty.
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3. Determine the customs procedure code (CPC)
The CPC tells HMRC what you are doing with the goods. The default for a straightforward import is release to free circulation (CPC starting 40 00). If you are using a special procedure — customs warehousing, inward processing, temporary admission, end-use, or outward-processing re-import — the CPC changes and you must hold the underlying authorisation. The wrong CPC can trigger duty on goods that should have been suspended, or release goods that should have stayed under customs supervision.
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4. Determine the valuation method
The default is Method 1 — transaction value, the price actually paid or payable for the goods when sold for export to GB. Around 95% of declarations use Method 1. You must add specific costs to the invoice price under regulation 130 of SI 2018/1248 — including freight to the GB frontier, insurance, royalties and licence fees, commissions (other than buying commission), and the value of any "assists" supplied free or at reduced cost by the buyer. If Method 1 is not available (no sale, related parties affecting price, conditional sale), work down the hierarchy through Methods 2 to 6.
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5. Calculate duty and import VAT
Apply the duty rate from the UK Global Tariff (or the preferential rate if you are claiming origin under an FTA such as the TCA or CPTPP) to the customs value. Import VAT is normally charged at the standard rate on the customs value plus duty plus freight to the place of delivery in the UK. If you are VAT-registered, claim Postponed VAT Accounting (PVA) so the import VAT goes onto your VAT return (boxes 1 and 4) rather than being paid at the border — this is cash-flow neutral. Non-VAT-registered importers must pay import VAT at the border and cannot reclaim it.
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6. Submit the declaration via CDS
Either your customs intermediary submits the declaration on your behalf, or you submit it through your own CDS-connected software. Direct representation makes the intermediary your agent only — you alone are liable for the duty. Indirect representation makes the intermediary jointly and severally liable with you. Confirm in writing which type of representation applies before the intermediary lodges the declaration. CDS issues a Movement Reference Number (MRN) on acceptance.
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7. Respond to HMRC query notes promptly
CDS may issue a query (Document Code or DMS error) asking you to upload additional evidence — a copy of the invoice, the licence, the proof of origin, or a valuation explanation. Goods stay at the border until the query is cleared. Respond through CDS within the time limit shown on the query; ignored queries lead to automatic refusal and the goods being held or re-exported.
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8. Archive supporting documents for four years
Under regulation 18 of SI 2018/1248 you must keep the customs declaration and every supporting document for at least four years from the end of the year of import. Keep invoices, transport documents, proofs of origin, licences, valuation working papers and any correspondence with HMRC. Records must be retrievable within a reasonable time on HMRC request — a post-clearance audit can come at any time inside the four-year window.
VAT-registered importers benefit from Postponed VAT Accounting
If you are VAT-registered, elect Postponed VAT Accounting (PVA) on the CDS declaration. Import VAT is then accounted for on your next VAT return — declared in box 1 and reclaimed in box 4 in the same return — making the cash-flow effect neutral. PVA is free, requires no application, and you download a monthly PVA statement from your CDS dashboard for your VAT records.
If you are not VAT-registered, you must pay import VAT at the border (or via duty deferment) and you cannot reclaim it. Factor that into your landed cost. Voluntary VAT registration may be worth considering if your import VAT is material.
Direct or indirect representation — choose carefully
If you appoint a customs intermediary, the type of representation matters because it determines who is liable for the duty:
- Direct representation — the intermediary acts in your name and on your account. You alone are the declarant and the person liable for the duty. Most freight forwarders prefer this because it protects them.
- Indirect representation — the intermediary acts in their own name but on your account. The intermediary is the declarant. You and the intermediary are jointly and severally liable for the duty. HMRC can pursue either party for the full amount.
Get the representation type, scope and liability allocation in writing before any declaration is made. Disputes about who owes duty after the fact are far more common than they should be.
What HMRC sees and audits
CDS keeps every declaration you have ever lodged. HMRC's compliance teams run analytics across declarations to spot misclassification patterns, valuation outliers and unusual preference claims. A post-clearance audit typically asks for the four-year archive plus narrative explanations of how you arrived at the declared values and codes. Strong working papers turn a difficult audit into a routine one.
What to do if you find an error after release
If you spot a mistake after the goods have cleared — wrong commodity code, missed addition to value, wrong preference claim — you can amend the declaration using form C2001 or by writing to the National Clearance Hub. An unprompted voluntary disclosure (made before HMRC raise it with you) substantially mitigates any civil penalty under HMRC's published practice. See the dedicated guide Correct a customs declaration error or make a voluntary disclosure.
Civil penalties for declaration errors
(SI 2018/1248), read with sections 25–28 of the Finance Act 2003, HMRC can
impose civil penalties of <strong>£1,000</strong> for less serious customs
contraventions and <strong>£2,500</strong> for more serious ones — including
inaccurate declarations, failures to keep records, and breaches of authorisation
conditions. Penalties stack <em>per contravention</em>, so a recurring error
across many declarations multiplies fast.</p>
<p>A reasonable-excuse defence is available, and an <em>unprompted</em>
voluntary disclosure typically attracts no penalty or a substantially reduced
one. Knowing or fraudulent evasion is criminal under sections 50, 167 and 170
of the Customs and Excise Management Act 1979 — maximum 7 years on indictment.</p>