Research and analysis

Estimating the administrative burden of 2022 import and export customs declarations for trade between Great Britain and the European Union: Executive summary

Published 15 July 2025

This report was commissioned under the Conservative administration (2010 to 2024).

HM Revenue and Customs (HMRC) Research Report 820.

Traders importing and exporting between Great Britain (GB) and the European Union (EU) incur an administrative (admin) burden, beyond any duties payable.

This burden arises from resource to prepare required information on a customs declaration and legislative requirement to submit to HM Revenue and Customs (HMRC). This admin burden did not exist on GB-EU trade before the United Kingdom (UK) left the EU (EU exit).

An administrative burden is not unique to customs. All HMRC taxes required to be met by businesses to comply with the UK’s tax administration incur an admin burden.

This summary and associated paper sets out the admin burden estimate for import and export customs declarations for trade between GB and the EU in 2022. Data used is deemed the best available information at the time of estimation and is used alongside tested assumptions to form an estimated figure.

HMRC estimate the total admin burden traders faced for the completion of import and export customs declarations for GB-EU trade in 2022 was £1.8 billion.

This estimate is based on the 38.6 million import and export declarations received in 2022 relating to trade between GB and the EU. The volume of declarations is sourced from HMRC administrative databases and aligned to published Official Statistics.

The admin burden of GB-EU import and export declarations is estimated by multiplying the volume of declarations by an estimated per declaration cost. This aligns with internationally recognised Standard Cost Model methods to estimate admin burden.

Further information on the estimate and volume of declarations can be found in the Summary method, Results and Detailed method sections of the full paper.

The 2022 estimate of £1.8 billion for GB-EU import and export customs declarations compares to a previously published estimate summarised at £7.5 billion. This previous estimate was not based on direct data but was inferred from intra-EU trade estimates. For more detail of the previous estimate refer to the details laid out in the Background section of the full paper.

The biggest driver of reduction in the overall estimate is the volume of declarations being substantially lower than previously estimated. The difference between 2022 outturn and that previously estimated is 75% lower for imports and 89% lower for exports.

The reduction in the overall admin burden figure is 70% for imports and 83% for exports. This would suggest most of the reduction in total estimated admin burden is accounted for by the previous overestimation of declaration volumes.

Prior to EU Exit, when the previous estimate of volumes was made, the UK compiled trade statistics for EU trade using Intrastat. Intrastat is the system for collecting information and producing statistics on the trade in goods between countries of the European Union.

This collected limited information from only the largest traders of goods. This survey was used as the basis for estimating the volume of EU customs declarations, post exit, alongside several assumptions.

Due to various uncertainties at the time of estimation and with limited evidence to go on, it was very difficult to predict outcomes. The compounding effect of assumptions therefore resulted in the overestimation of the volume of import and export declarations between the UK and EU.

It is important to note that declaration volumes are a suitable metric for measuring the approximate number of import and export consignments. However, this is not necessarily the case for volume or value of trade.

For example, a single declaration could be for £100 worth of goods or £100 million. Meaning, the same value of trade, £100 million, could be declared in 1 or 100 declarations.

Differences between declaration volumes received following EU exit and that estimated beforehand is not proportional to trade volume differences before and after EU exit. Therefore, a change in one should not be used to infer an equal change in the other.

There are different ways of measuring UK trade, of which both HMRC and the Office for National Statistics release statistics each month.

Based on the overall volume and admin burden estimate totals, the estimated average cost of a declaration, in 2022, is £48. However, the cost faced by an individual trader will vary depending on the business, movement and agent usage.

The estimated average cost per declaration from the previous published impact assessment was £36, which is 34% lower than the £48 mentioned above.

The increased 2022 figure is likely due to factors such as wage growth, better understanding of responsible staff and updated agent costs. This comes from information provided by traders themselves.

Further details on the comparison are set out in the Comparison between 2019 impact assessment and estimate for 2022 declarations section of the full paper.

Table 1 in the full paper provides further detail into the estimated cost breakdown per admin burden group. The per declaration costs outlined in the full paper may not necessarily be applicable to non-EU declarations.