UK border authorities have given carriers and intermediaries until 30 September 2026 to address recurring errors in Entry Summary Declarations (ENS), warning that continued non-compliance could ultimately result in customs civil penalties.
The warning concerns safety and security declarations submitted for goods entering Great Britain, with authorities highlighting particularly poor compliance in accompanied roll-on/roll-off and Channel Tunnel road movements.
According to a Safety & Security compliance notice circulated to the freight industry, two fields are causing particular problems: “Identity of Means of Transport crossing the Border” and “Container Number / Trailer Number”.
ENS declarations for imports from the EU into Great Britain have been compulsory since 31 January 2025. HM Revenue & Customs says declarations must be complete and accurate and submitted before the goods arrive. The information is used by UK authorities to carry out security risk assessments ahead of arrival.
Truck registration – not trailer number
One of the most common errors concerns the identity of the vehicle crossing the border. For accompanied ro-ro movements, operators should enter the registration number of the tractor unit. The same applies to road freight travelling through the Channel Tunnel.
Authorities have identified declarations where operators have instead entered generic placeholders such as “Truck”, used the trailer registration number, entered both the tractor and trailer numbers in the same field, or failed to update an incorrect vehicle registration when the planned vehicle changed.
Vehicle registration numbers should be entered without spaces or special characters. The rules are different for unaccompanied ro-ro freight: in that case, the IMO identification number of the ferry is used as the means of transport crossing the border.
The separate container/trailer field must meanwhile contain the correct unique trailer or container number. If a container is being carried on a trailer, authorities instruct declarants to provide the container number in preference to the trailer registration number.
HMRC’s published dataset confirms that the identity of the means of transport is a mandatory ENS data field, while the container number is conditionally mandatory where containers – including unaccompanied ro-ro trailers – are being moved.
Vehicle changes mean the ENS may need changing too
The warning is also relevant where operators swap vehicles after the declaration has already been submitted. HMRC says an ENS can be amended at any time before the goods arrive at the border if information changes or is found to be incorrect. The original declaration must still have been submitted within the relevant deadline.
For accompanied ro-ro freight, the ENS must generally be submitted at least two hours before arrival. For road freight using the Channel Tunnel, the minimum deadline is one hour before arrival at the Eurotunnel terminal in Coquelles, France.
Haulier remains responsible even when someone else files the ENS
The rules are particularly important for road operators because responsibility differs depending on how the goods cross the border. For accompanied ro-ro freight, the haulage company is legally responsible for lodging the ENS. The same applies to road freight travelling through Eurotunnel. For unaccompanied ro-ro movements, responsibility lies with the ferry operator.
A haulier can appoint an intermediary or another third party to submit the declaration, but HMRC stresses that the carrier’s legal responsibility for ensuring that an ENS has been submitted remains in place. Responsibility for the accuracy of the information generally rests with the party actually lodging the declaration.
Enforcement can include penalties
Operators responsible for ENS declarations have been asked to review their systems, staff procedures and the information supplied by partners in the transport chain and correct problems in the two highlighted fields by 30 September.
The compliance notice warns that problems identified after that date may lead to further enforcement action, potentially including customs civil penalties.
Companies that have already received a warning letter or penalty are not covered by the 30 September deadline and must instead comply with the timeframe already given to them.
HMRC’s published guidance says enforcement of ENS breaches is intended to be evidence-based and proportionate, but can include goods being delayed at the border for additional checks as well as financial penalties.
The government’s schedule of customs contraventions provides for a maximum £1,000 civil penalty for certain breaches involving entry summary declarations, including failure to supply the information required for safety and security risk analysis.
