Export Declarations to the EU: What UK Exporters Must File and When

If your business sends goods from Great Britain to the EU, every single commercial consignment needs a customs export declaration before it is allowed to leave the UK. There is no small-value exemption and no “it’s only going next door to France” get-out. Since the UK became a third country to the EU, export clearance is a legal requirement, and the deadlines for submitting the paperwork are tighter than many businesses expect. Getting this wrong does not just risk a fine — it means a lorry held at the port, a missed ferry slot, or a container that cannot be loaded.

This article sets out what has to be filed, when, and the practical steps your business should take to avoid delays.

The declaration itself: what it is and where it is filed

An export declaration is the official notification to HMRC that goods are leaving the UK, giving customs the chance to check the shipment before it departs. All export declarations are now made through the Customs Declaration Service (CDS), which has fully replaced the old CHIEF system. CHIEF closed for exports at the end of March 2024 following a phased migration, so there is no longer any option to fall back on the legacy platform.

Before you can submit anything, you need a few things in place:

• A GB EORI number — without one, a declaration cannot be lodged at all.
• The correct commodity code for each product, which drives the customs procedure and any licensing requirements.
• A Declaration Unique Consignment Reference (DUCR), the master reference that links everything together.
• Full details of consignor, consignee, value, currency, packaging, transport method and any certificates or licences needed.

You can submit declarations yourself if you have compatible software and the in-house expertise, or appoint a customs agent or freight forwarder to do it on your behalf. Most smaller exporters choose the latter, since CDS data requirements are detailed and the consequences of errors fall on the exporter regardless of who keyed the entry.

Timing: the deadlines differ by mode of transport

This is where many exporters come unstuck. HMRC sets minimum notice periods before departure, and they vary depending on how the goods are leaving the country:

• Road and inland waterways: at least one hour before departure.
• Sea, containerised cargo to nearby destinations (the Baltic, North Sea, Mediterranean, Black Sea, Iceland, the Faroes, Greenland): at least two hours before the vessel leaves port.
• Sea, other containerised cargo: at least 24 hours before loading.
• Sea, non-containerised cargo: at least two hours before departure.
• Air freight: at least 30 minutes before the aircraft leaves a UK airport.
• Rail: timing depends on journey length to the office of exit, generally one hour or more before arrival there.

On top of the mode-based timing, you must also check whether the port or terminal you are using requires the declaration to be submitted as “arrived” or “pre-lodged”. Many roll-on roll-off (RoRo) locations used for EU trade — the short-straits ferry ports and the Channel Tunnel — operate on a pre-lodgement model through the Goods Vehicle Movement Service (GVMS). Here, the declaration must be completed and linked to a Goods Movement Reference before the lorry ever reaches the port, because there is no physical stop for customs to intervene once the vehicle is in the traffic flow.

The combined declaration for RoRo and Channel Tunnel movements

For most road freight heading to the EU through a RoRo port or the tunnel, you are not filing a customs declaration and a separate security declaration — the two are combined into a single submission on CDS. This includes the safety and security data that would otherwise form a standalone exit summary declaration (EXS), such as the vehicle registration, and trailer or container number for unaccompanied freight. Once submitted, HMRC returns a routing outcome (commonly referred to as route 1, 2, 3 or 6) which tells the haulier whether the goods can proceed or need to be presented for documentary or physical checks.

A standalone EXS is only needed in narrower circumstances — for example, where goods move without a full export declaration, or where cargo has sat in temporary storage for more than 14 days. For the vast majority of commercial EU-bound shipments, the export declaration already carries the required safety and security information.

Simplified declarations and proof of export

If your business exports regularly and does not always know the full details of a consignment at the point of departure — bulk commodities are a common example — you may be able to use a simplified declaration procedure. This splits the process into an initial, lighter-touch submission before departure, followed by a supplementary declaration giving the full detail, which must be submitted within 14 days of the goods leaving.

Whichever route you use, keep the departure message or other commercial evidence that the goods actually left the UK. This is your proof of export, and HMRC expects to see it if you have zero-rated the sale for VAT purposes or used a customs special procedure. Without it, HMRC can require you to account for VAT as though the sale were domestic.

What UK exporters should do now

1. Confirm you hold a valid GB EORI number and are registered for CDS, not relying on CHIEF access that no longer exists.
2. Check the goods location code and port you are using to establish whether declarations there must be arrived or pre-lodged.
3. Build the mode-specific deadline into your despatch planning — an hour’s notice for road freight sounds generous until a driver is already queuing.
4. Agree clearly with your haulier or forwarder who is submitting the declaration and who holds responsibility for the GVMS goods movement reference.
5. Retain departure evidence for every shipment as proof of export for VAT and audit purposes.

Export declarations are now a routine but unforgiving part of trading with the EU: the rules are well documented, but the margin for error at busy ports is small. If you would like help setting up your export process, checking commodity codes, or handling CDS declarations on your behalf, get in touch with our customs clearance team.

Sources and further reading

• Making a full export declaration – GOV.UK (gov.uk)
• Export goods from the UK: step by step – GOV.UK (gov.uk)
• Get UK customs clearance when exporting goods: step by step – GOV.UK (gov.uk)
• Sending goods to the EU through roll on roll off ports or the Channel Tunnel – GOV.UK (gov.uk)
• Making an exit summary declaration for exports from Great Britain and Northern Ireland – GOV.UK (gov.uk)
• Applying to use simplified declarations for exports – GOV.UK (gov.uk)
• Get an EORI number: Who needs an EORI – GOV.UK (gov.uk)
• HMRC announces phased approach to CDS export migration – ICAEW (icaew.com)