Business, Freight News, Logistics


The danger of customs double jeopardy

[ December 10, 2025   //   ]

Retailers looking to sell goods from the UK overseas are having a rough few years. First Brexit, and now the American administrations tariffs have created a new landscape for international trade marked by new complexity and cost, writes Duncan Wakeling, operations manager at Customs Support Group’s London Gateway office.

Fanning the flames is the growing importance of free, seamless returns to the international customer. Returns are impacting the consumer journey both before and after the point of sale. According to the 2024 Consumer returns in the Retail Industry report by the National Retail Federation (NRF), 76% of consumers consider free returns a key factor in deciding where to shop, while 67% said a negative return experience would discourage them from shopping with a retailer again.

The pressure is undeniably on for UK companies who want to sell abroad this holiday season. They mustn’t just navigate tightening tariff regimes and the ever more Byzantine customs requirements that govern international trade, but do so in two directions.

It’s not solely a matter of getting your goods to your customer; it’s about getting them back again if the customer doesn’t want them without paying import duties that further erode your margins. 

There are solutions to these headaches, but without the right knowledge and tools, many UK companies are electing to forgo international sales (and the associated revenue) instead.

Selling overseas has never required fancier footwork. At the start of the year, the US applied a baseline tariff of 10% on most UK exports, alongside higher sector-specific duties including 25% on car imports and parts, up to 50% on steel and aluminium, and potential future measures affecting pharmaceuticals and aerospace components.

The end of the US de minimis exemption in August adds further administrative and cost pressures for online sellers, removing the low-value threshold that previously simplified small-parcel shipments.

In this environment, many UK sellers have chosen to wind down their international sales rather than risk fines or deal with steep duties and regulatory headaches. Following Brexit, 14% of UK firms (around 16,400 companies) that previously exported to the EU stopped doing so the following January.

More recently, data from the UK’s Office for National Statistics revealed the value of UK exports to the US fell by £500 million or 11.4% in September, the lowest in five years.

Free returns and the double duty risk

The challenges facing UK companies looking to sell abroad are significant, and they’re being compounded by the fact that free returns have become a key differentiator when competing for business online.

Researchers for the NRF study found that, when it comes to making a return, ease is essential for consumers. The overwhelming majority (84%) of customers said they would be more likely to shop with a retailer that offers box-free, label-free returns and immediate refunds.

As a result, improving consumers’ returns experience topped the report’s list of retailer priorities this year, with 40% of retailers agreeing that a better return experience means customers will spend more with their brand over time.

UK retailers are understandably hesitant to expand into global markets due to uncertainty around the duties associated with re-importing returned or unsold goods. A lack of clarity on processes, compounded by limited in-house customs expertise, is adding to the number of businesses choosing to avoid overseas sales channels altogether.

Every time goods cross a border, the border authority will ask for tax to be paid on those goods, even if those goods are on their way back to the company that sold them. Paying unnecessary tax in addition to the cost of handling returns and losing revenue can be a huge pain point for organisations. The only way to get around this is to prove that goods returned to the UK are previously exported UK goods. Otherwise, they’ll be treated as a new import.

Returned Goods Relief: A critical tool

Returned Goods Relief (RGR) is an essential tool for avoiding unnecessary duty payments on goods that are temporarily exported, unsold, or returned. RGR allows qualifying goods to re-enter the UK or EU without incurring additional import duty, provided specific conditions and documentation requirements are met.

How RGR works:

●          Eligibility: Goods must have originally been exported from the country claiming relief, and must not have been altered other than necessary maintenance

●          Evidence: Export declarations, returned goods information sheets, and commercial records must prove the items re-imported are the same as those exported

●          Declaration: RGR must be claimed at the point of re-import, supported by all required documentation

However, the process hinges on accurate tracking. For many retailers getting tripped up by double duty, the problem lies in their inability to link the returning goods to the original export in their systems. This results in critical information being left off paperwork and steep customs bills. Even if they aren’t and fees are avoided, manually processing RGR applications can end up costing more in labour than paying additional duty at the border.

Digitally tracking shipments and automating the declarations process so each returned item is linked to its original export documentation and eligible returns are processed without incurring new duties.

Preparing for more global regulation

With the US tightening tariff policy and ending de minimis exemptions, and with the UK and EU continuing to operate under divergent customs frameworks, retailers must adapt their operations to remain competitive. Accurate, timely and cost-effective classification processes are essential to ensuring goods not only make it through customs, but make it back again without delays and extra costs. Robust tracking, documentation and customs procedures are increasingly fundamental to international e-commerce, especially as hassle-free returns move from nice-to-haves to must-haves.

Heading into the holiday season, ensuring your fulfilment and returns processes work smoothly is more than a matter of supply chain hygiene. In an economic landscape where the only thing less forgiving than margins are customer expectations, a smooth returns policy is a source of competitive advantage.

Agility is a must-have, and finding a customs partner that can leverage human experience and cutting-edge technology is the fastest, most cost-effective way to inject it into your business. Successfully implementing RGR into the fulfilment process offers a practical route to reducing cost exposure, supporting margin protection and giving access to global markets back to UK businesses without the risk of paying twice at the border if customers get cold feet.

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