What Happened

On 22 September 2025, HMRC secured a £4.7 million judgement against WM Morrison supermarkets over the declared origin of aluminium foil. This case is more then a technical customs dispute, it signals a major compliance and financial risk for UK importers.

What Happened

• Morrisons declared foil as Thai origin.
• HMRC argued the real origin was China, as processing in Thailand (heating, cutting, boxing) was insufficient to create a new product.
• The tribunal agreed: minimal processing and public statements about avoiding duties failed the ‘economically justified’ test.
• Result: £4.7 million in unpaid duty and VAT.

Why it’s Significant

• First major UK ruling on non-preferential origin since Brexit.
• Highlights that origin is not just a logistics issue, it’s a financial exposure.
• HMRC used open source evidence and applied EU case law principles.

Key Risks for Importers

• Anti dumping duties can reach 30-50% of product value.
• HMRC can look back three years or more.
• Knock on effects: VAT, penalties, interest and margin restatements.
• Burden of proof lies with the importer.

Implications for Finance Leaders

• Non preferential origin now sits alongside VAT and transfer pricing as a material risk category.
• Supplier certificates alone are not enough.
• Independent customs audits should become standard practice.

Action Points

• Treat origin compliance as a financial control, not just a trade function.
• Review supplier processes and evidence for declared origin.
• Consider periodic independent audits to mitigate exposure.

The Bigger Picture

HMRC has signalled its intent to challenge origin declarations aggressively. This ruling will not remain isolated. Finance leaders don’t need to be customs experts, but they do need assurance that their teams’ origin declarations can withstand scrutiny.

Help is Available