Guides / CDS import declarations · Updated 30 September 2026

How a customs broker files your UK import declaration in CDS

When you use a customs broker, your job is to give them accurate information and clear written instructions. They build and submit the declaration in CDS. This guide explains how that split works, how duty and import VAT are paid, and what usually holds a declaration up.

Who actually submits the declaration

Every commercial import into Great Britain needs an import declaration in the Customs Declaration Service (CDS), the HMRC system that replaced the older system CHIEF. gov.uk is clear that you can deal with customs yourself or hire someone to do it for you. Most businesses use a customs broker, freight forwarder or express operator, because the declaration needs specialist software and a working knowledge of the tariff. If you are unsure whether you need one at all, see do you need a customs broker.

Hiring a broker does not hand over all of your responsibility. HMRC guidance says you remain responsible for due diligence on declarations made for you, and the broker cannot act for you without written instructions that state whether they act as your direct or indirect representative.

Direct or indirect representation: who carries the debt

The type of representation decides who HMRC can pursue if duty turns out to be underpaid.

Representation	Whose name the declaration is in	Liability for the customs debt
Direct	The importer's	The importer (principal) is solely liable, unless the agent makes a deliberate or unreasonable error despite clear instructions
Indirect	The agent's, acting for the importer	Importer and agent are jointly and severally liable

Because indirect representation exposes the broker to the debt, brokers usually ask for more documentation, financial checks or payment security before agreeing to it. Agree the arrangement in writing and keep a copy, as gov.uk advises.

What the importer must provide

A broker can only declare what you tell them. Before the goods arrive, have the following ready:

Your EORI number starting with GB (for imports into England, Wales or Scotland).
The commercial invoice, showing the goods, the price paid and the terms of sale. HMRC uses the customs value to calculate duty and import VAT.
A clear description of each product so the broker can confirm the commodity code. The code sets the duty rate and shows whether an import licence is needed.
Origin information and any proof of origin, if you want to claim a lower rate under a UK trade agreement.
Any licence or certificate for controlled goods, such as animals, plants, medicines, chemicals or hazardous materials.
Written instructions on the type of representation, and on whether you want to use postponed VAT accounting.
Details of how duty will be paid, for example authority for the broker to use your duty deferment or cash account.

Postponed VAT accounting needs a written instruction. gov.uk says you must tell your agent in writing if you want to use it, before the declaration is made. Once the declaration is submitted, that choice cannot be changed for that declaration.

What the broker does in CDS

With your documents in hand, the broker's work usually follows this order:

Checks the data. They confirm the commodity code against the UK Trade Tariff, check that the invoice value and currency make sense, and look for any licence or certificate requirements.
Chooses how the charges will be paid. The declaration has to say which account or method covers duty and VAT.
Builds and submits the declaration. This is done through CDS-compatible software, using your EORI and, where postponed VAT accounting applies, your VAT registration number at header level.
Watches the responses. CDS sends messages back to the software as the declaration moves through its stages, ending with a final tax calculation when it has cleared.
Passes documents back to you. This includes the movement reference number (MRN), which identifies the declaration from then on.

If you want to see what the individual fields and steps look like in practice, Easy Clearance has published a step-by-step walkthrough of the CDS import declaration. This guide concentrates on how the work is split between you and your broker.

Paying duty and import VAT

gov.uk lists several ways to pay the charges on a CDS import:

Duty deferment account. Charges are collected monthly by Direct Debit instead of per shipment. HMRC says this delays payment by an average of 30 days and can help goods clear faster, because payments do not have to be handled for each transaction.
Cash account. You hold a balance in CDS that you top up, and charges are taken from it.
Immediate payment. You can pay by online bank approval, debit or corporate credit card, bank transfer or cheque. Personal credit cards are not accepted.
General guarantee account. Used where amounts are disputed or not yet known, for example with some Temporary Admission declarations.

You can authorise a broker to use your deferment, cash or guarantee account. You manage those authorities, and view your statements, in HMRC's online service for managing import duties and VAT accounts. If you miss a payment deadline, you may have to pay a penalty, interest or both.

Postponed VAT accounting

If you are VAT-registered in the UK, you can use postponed VAT accounting to declare and recover import VAT on the same VAT Return, instead of paying it at the border. No approval is needed. Each month you download a postponed import VAT statement from the same HMRC service and use it for your VAT Return. Import VAT paid in other ways appears on the C79 import VAT certificate. HMRC suggests checking these statements against your own records so that every import is covered.

After clearance: records and corrections

Keep the commercial invoices, the customs paperwork and your C79 certificates. gov.uk states that you must keep records of these.

Mistakes can be corrected, but the method depends on timing:

Before clearance, and before the final tax calculation message, the declarant can amend the declaration directly in their software without contacting HMRC. A declaration can also be cancelled in the software in some situations, for example when the goods have not yet arrived.
After clearance, changes go through HMRC, usually using an online notification form. You have up to 3 years from acceptance to amend a declaration, and 90 days from acceptance to cancel one.

If you have overpaid duty or VAT, gov.uk has a separate process for claiming a repayment.

Why declarations get held up

Most delays come from missing or inconsistent information, not from the system. In practice, watch out for:

A wrong or vague commodity code. The code sets both the duty rate and any licence requirement, so an error affects the tax and can leave out a document that should have been declared.
Invoice problems. A value or description that does not match the goods, or a missing invoice, makes it hard to support the customs value.
Unsupported preferential origin. A preference claimed without proof of origin may be challenged.
Missing licences or certificates for controlled goods.
Payment problems. A missing account authority, an empty cash account or an incorrect payment reference can delay clearance.
No written instructions on representation or postponed VAT accounting. The broker cannot act properly without them.

If you send complete, consistent documents before the goods move, your broker can deal with most of these points before the declaration is submitted, not after HMRC raises them.

Related guides

Need an import declaration filed?

Easy Clearance is a UK–EU customs clearance agency that handles import and export declarations, T1/T2 transit and UK–Poland removals.

Read the CDS guide

Sources

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.