The Department for Environment, Food & Rural Affairs (DEFRA) together with HM Revenue & Customs (HMRC) have published updated operational guidance for exporting controlled goods from Great Britain during HMRC system outages. The notice details the fallback procedures exporters must follow when electronic declaration platforms, such as the Customs Declaration Service (CDS), encounter technical disruptions and standard continuity plans are invoked.
Under normal operations, controlled goods—which include regulated waste streams, hazardous substances, and licensed materials—require validated electronic export declarations before departure from British ports. The refreshed guidance clarifies which categories of controlled goods may continue under standard fallback declaration rules during a system failure, and which require specific manual clearances or direct regulatory intervention before movement.
Why It Matters
Customs IT outages present immediate operational risks to cross-border logistics. Freight forwarders and exporters relying on real-time permission to progress risk severe port congestion, missed shipping windows, and accrued demurrage fees when digital systems stall. Clear instructions regarding fallback declarations allow logistics teams to maintain material flows while remaining compliant with national export controls.
Impact on UK–Türkiye Plastics Trade
For UK waste management companies exporting plastic scrap and Turkish reprocessors expecting scheduled feedstock deliveries, border delays disrupt processing timelines and vessel allocations. While standard green-list plastic waste trades under Annex VII procedures, shipments subject to secondary controls or prior notification regimes must adhere strictly to HMRC's emergency protocols when digital systems fail. Exporters trading between Great Britain and Türkiye must ensure their shipping agents understand fallback requirements to prevent loads being held at UK departure ports during IT outages.
Practical Takeaway
UK waste exporters should review their customs contingency plans to ensure operational alignment with HMRC fallback procedures. Logistics leads ought to maintain pre-formatted manual declaration templates and verify contact channels with licensing authorities so that export documentation can be processed swiftly if electronic declaration systems go offline.
