Origin Is Not Just a Label: What the £4.7m Morrisons Ruling Means for Your Import Declarations
Category: Customs Compliance | Read time: 5 min
In September 2025, HMRC secured a £4.7 million judgment against WM Morrison Supermarkets over the declared origin of aluminium foil. The foil was declared as Thai. HMRC said it was Chinese. The tribunal agreed with HMRC.
For most UK importers, the instinct is to read a headline like that and think: that's a supermarket, that's a big business problem, that doesn't apply to me.
It does. And here's why.
What actually happened?
Morrisons imported aluminium foil that had undergone processing in Thailand — heating, cutting, and repackaging — before being declared as Thai origin on entry to the UK.
The problem is that China is subject to significant anti-dumping duties on aluminium products. Thai origin was not. The financial difference was material.
HMRC's position was that the processing carried out in Thailand was not sufficient to change the origin of the goods. Under UK rules of origin, processing must result in a genuine and economically justified transformation — not simply repackaging or minor adaptation designed to avoid a higher duty rate. The tribunal found that the processing failed this test. Morrisons' own public statements were used as part of the evidence against them.
The result: £4.7 million in unpaid duty and VAT, plus the precedent that HMRC will pursue origin declarations aggressively and successfully.
Why this is a wake-up call for every UK importer
This was the first major UK tribunal ruling on non-preferential origin since Brexit. It matters not because Morrisons is unusual, but because their situation is not.
Across UK importing businesses — from manufacturers to retailers to distributors — the declared origin on import declarations is often taken directly from a supplier's certificate without independent verification. Most businesses trust their supply chain documentation without asking whether it would survive scrutiny.
HMRC rules of origin require that goods genuinely originate from the declared country. For non-preferential origin — which determines whether anti-dumping or safeguard duties apply — the test is whether the goods have undergone their last substantial transformation in the declared country. Minor processing does not qualify. Repackaging does not qualify. Heating and cutting foil does not qualify.
The burden of proof rests entirely with the importer. Not the supplier. Not the freight forwarder. You.
And HMRC can look back three years or more.
What "substantial transformation" actually means
This is where many businesses get caught. The UK rules of origin for non-preferential purposes require that goods either:
Are wholly obtained in a single country: grown, extracted, or manufactured there without materials from anywhere else, or
Have undergone their last substantial transformation there, defined by a change in commodity code at the four digit level, a specific manufacturing or processing operation, or a value-added threshold
The critical word is "substantial." Cutting, assembling, mixing, or repackaging in a third country does not automatically confer origin. If the core manufacturing — the process that gives the product its essential character — happened elsewhere, that is where the goods originate.
HMRC is increasingly using data analytics, trade statistics, and open-source intelligence to identify mismatches between declared origin and known manufacturing geography. The Morrisons case was not caught through a routine declaration check. It was identified through targeted analysis.
The risks your business may already be carrying
Anti-dumping duties on goods from China, Russia, and other markets can reach 30 to 50 percent of product value. If your supply chain routes goods through a third country before UK import, and your declarations rely on origin certificates from that third country, your liability exposure deserves a hard look.
The financial consequences are not limited to duty. VAT applies on top. Penalties and interest accrue from the date of original import, not the date of discovery. And for businesses operating on thin margins, a retrospective HMRC demand covering three years of imports can be existential.
The Morrisons case did not happen because someone made a careless mistake. It happened because origin was treated as a logistics administrative function rather than a financial control.
What Readyset recommends
At Readyset, we work with importers, manufacturers, and distributors who rely on international supply chains. We see origin compliance treated as an afterthought in the vast majority of customs reviews we carry out — and the Morrisons ruling signals that HMRC no longer sees it that way.
If your business imports goods where the manufacturing geography is complex, or where the declared origin differs from where the raw materials or components originate, this ruling is directly relevant to you. Not theoretically. Directly.
The starting point is a structured review of your current origin declarations and the supply chain evidence that supports them. Do your supplier certificates reflect actual manufacturing origin, or country of last processing? Could those certificates withstand the scrutiny HMRC applied to Morrisons? Do you have independent verification, or are you relying entirely on documentation provided by your supplier?
These are not difficult questions to answer with the right expertise. But they are expensive questions to leave unanswered.
The bigger picture
HMRC has signalled clearly, through this ruling, that UK rules of origin are an active enforcement priority. Anti-dumping duties exist precisely because goods routed through third countries to avoid them undermine the purpose of trade policy. HMRC will pursue those cases.
For UK importers, the lesson is not that rules of origin are complicated — they are, but that is manageable. The lesson is that they are consequential, and that the consequences fall on you.
If you are not confident that your origin declarations would survive a tribunal, it is worth finding out now rather than later.
Readyset Consultancy provides customs compliance and trade advisory services to UK importers and exporters. If you have questions about your origin declarations or want a review of your current customs position, book a free consultation.
Related reading:
