Submission to the UK Government consultation on the proposed reform of the customs treatment of low value imports into the UK

This is a response made by CETEx to the open consultation by HM Treasury and HM Revenue and Customs seeking views on the reform of the customs treatment of low value imports into the UK. The response focuses on the potential economic, environmental and socio-economic impacts of the proposed tariff reforms.

Selected key points

Relevant international climate and trade obligations

• The proposed low value imports (LVI) reform could support the delivery of the UK’s climate commitments – under the Paris Agreement and the Climate Change Act 2008 – by curbing the growth of the UK’s imported emissions.

Potential socio-economic impacts from low-value import reform

• Low-value import reform may limit the exposure of consumers to hazardous substances that are frequently found in low-value products imported from abroad, including clothing, jewellery, electronics and children’s toys.
• The authors recommend that the UK Government conducts an equality impact assessment for different population groups as the reform may have a negative impact on consumers who rely on low-value e-commerce by exposing them to higher prices. This impact may be disproportionately felt by consumers on low-incomes, consumers of fast fashion and people living with restricted mobility.

Opportunities and challenges of the proposed new customs arrangements

• The authors highlight that the most significant opportunity of the reform is its potential to curb ultra‑fast fashion imports, which currently dominate low‑value parcel flows into the UK and have significant environmental impacts: the textile industry, for example, contributes around 10% of global greenhouse gas emissions. ​
• Overall, the authors argue that the proposed reform allows the UK to keep pace with similar customs reforms in the EU and US.
• However, the authors highlight the risks of delaying reform until 2029. These risks include exposing local producers disproportionately to customs duty charges in the US and EU, increasing environmental costs and encouraging online retailers to target the UK to compensate for losses in other international markets.