Why this ruling signals a shift in HMRC’s approach – and how the Cambridgeshire Chamber of Commerce can help businesses stay protected
A recent tribunal decision has sent shockwaves through the import community – even if many businesses haven’t yet noticed. In September 2025, HMRC secured a £4.7 million victory against supermarket chain Morrisons in a dispute over where its aluminium foil was “made”.
It may sound like a minor technical matter, but this judgment changes how the UK applies the concept of non-preferential origin – and it’s something that could affect almost any business moving goods across borders.
The background
Morrisons imported aluminium foil that had undergone light processing in Thailand. The retailer declared Thailand as the country of origin, which meant the product avoided the additional tariffs that apply to Chinese-made foil.
HMRC challenged that classification, arguing that the Thai operations – which involved reheating, trimming, and packaging – didn’t significantly alter the product. The tribunal agreed. Because those activities added minimal value and weren’t considered genuine manufacturing, the foil was legally deemed Chinese in origin, triggering a £4.7 million customs liability.
The case underscores a simple but crucial point: the country where a product undergoes its final processing doesn’t always determine its true origin.
Why this matters to importers and exporters
For companies that trade internationally, this decision highlights a growing area of compliance risk.
Most businesses are familiar with preferential origin rules – the ones that unlock lower tariffs through trade agreements. But non-preferential origin governs anti-dumping duties, sanctions, and other protective measures. It’s this side of the system that HMRC is now focusing on more closely.
Even small or routine processing in a secondary country may no longer be enough to establish a new origin. Publicly available information – even from a supplier’s website – can be used by HMRC as evidence when deciding whether your declarations hold up under scrutiny.
In other words, it’s not just your logistics or customs agent’s concern anymore. It’s a financial risk that sits firmly at the boardroom table.
The wider implications
Additional duties in these cases can be steep — sometimes exceeding 30 per cent of a product’s value – and HMRC can revisit declarations made years earlier. This can mean not only back payments of duty, but also penalties, interest, and restated financial results.
What’s more, the tribunal confirmed that responsibility for proving a product’s origin always lies with the importer. Certificates from suppliers may not be sufficient if the underlying evidence doesn’t demonstrate substantial transformation.
For businesses with complex supply chains, that’s a wake-up call.
How the Cambridgeshire Chamber of Commerce can support you
The good news is that expert help is available – locally.
The Cambridgeshire Chamber of Commerce works with hundreds of importers and exporters, providing the guidance, tools, and assurance needed to stay compliant in a fast-changing trade environment.
Our International Trade Team can:
– Review your supply chain and origin declarations
– Help you understand how HMRC’s evolving approach may affect your products
– Offer training and workshops on rules of origin and customs compliance
– Connect you with trusted specialists for independent audits and certification
Whether you’re a seasoned global trader or just starting to export, the Chamber is here to help you trade with confidence — and without unnecessary risk.
Act before HMRC does
This tribunal ruling is unlikely to be a one-off. It signals that HMRC is ready to challenge importers who rely on assumptions or incomplete evidence.
If you’re unsure whether your goods are correctly classified, now is the time to review your processes.
Get in touch with the Cambridgeshire Chamber of Commerce today to speak to our international trade experts. We’ll help you strengthen your compliance, protect your margins, and keep your global operations running smoothly.
Cambridgeshire Chamber of Commerce
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