Small Importers and Unpriced Landed Costs: Evidence from Eight UK Trade Council Members

Subject: Evidence on tariff changes, import administration and landed-cost transparency

1. Purpose and scope

1.This submission places before the Trade Council evidence provided with consent by the UK Small Importer Evidence Group, a group of eight members of the Founders Assembly’s Trade Council. The members are based in the United Kingdom and operate small businesses in different sectors. Their businesses are not identified. The accounts below are anonymized and are presented to describe recurring practices and effects, not to make allegations against any named company.

2.The submission is intended to inform TR-001, the proposed Small Importer Standard. It addresses three connected matters: the practical burden of trade requirements that do not scale to the size of a trader; the difficulty of understanding which requirements apply and when; and the inability to confirm the full cost of moving goods before accepting a quotation or placing an order.

3.The evidence is not a representative survey of UK importers, nor an audit of customs declarations, invoices or tax records. It consists of member-provided timelines and descriptions of documents, supplemented by the Trade Council’s reported evidence base as at 12 September 2026. The Secretariat has preserved the members’ anonymity and has not independently verified individual transaction values. The figures below should be read as reported amounts, not as a statistical estimate of total UK trade costs.

4.The group’s account is consistent with the practical importance of small firms in the wider economy. The United Nations estimates that micro-, small- and medium-sized enterprises account for about 90 per cent of businesses, 60–70 per cent of employment and about half of global gross domestic product.[1] The International Labour Organization estimates that MSMEs provide about 70 per cent of employment worldwide and that about 80 per cent operate in the informal economy.[2] These global estimates do not establish the scale of any particular UK import problem; they underline why rules designed for trade should be workable for firms with limited specialist capacity.

2. Evidence submitted by members

2.1 How the evidence was assembled

5.The eight members submitted evidence to the Secretariat for publication. The material included order and shipment timelines, supplier invoices, freight or brokerage quotations, tariff or regulatory notices, and correspondence or notes describing attempts to obtain an explanation of charges. Where the original documents contained identifying information, the Secretariat did not reproduce those details. Document descriptions are summarized here; they are not represented as public documents or as independently authenticated records.

6.The members’ evidence covers the period from late 2025 through August 2026. It includes imports of components, packaging, household goods and specialist equipment. The common feature is not a single product or route. It is the difficulty of making a reliable cost and compliance decision when requirements, charges or their timing are not clear to a small trader before the relevant commitment must be made.

2.2 Reported cases and amounts at stake

7.Case UK-TR-S4-01 concerned an order of components for a small production run. The member’s timeline records a supplier quotation, a later freight quotation and a further charge disclosed after the goods were moving. The member reported an unplanned amount of approximately £1,180 (about US$1,500),

combining a change in the expected duty treatment with handling and documentation charges. The member described having to choose between absorbing the cost and delaying fulfilment while seeking clarification. The member supplied a dated order record, the initial quotation and a later charge notice.

8.Case UK-TR-S4-02 concerned packaging material bought in a volume that was economical for the supplier but large relative to the member’s cash flow. The member’s records show that the expected total at the point of order did not include all the charges later presented by the transport intermediary. The member reported a difference of approximately £760 (about US$970). A sequence of email notices and an invoice were supplied. The member said the practical problem was not simply the amount: the charge arrived after the member had made a commitment to a customer and had little time to revise the selling price.

9.Case UK-TR-S4-03 concerned specialist equipment needed to complete a customer project. The member reported that an import requirement was discovered while arranging the shipment rather than when assessing the purchase. The resulting administrative work delayed the equipment’s availability and required paid assistance. The member estimated the direct cost and related storage or delay charges at approximately £2,450 (about US$3,120). The evidence included the supplier’s product documents, a broker’s request for additional information and a later invoice. The Secretariat has not assessed whether the underlying classification or charge was correct.

10.Case UK-TR-S4-04 concerned a small shipment of household goods. The member’s notes describe receiving separate estimates from a carrier and a customs intermediary, neither of which set out a single total or clearly identify which amounts could change. The member reported a final difference of approximately £520 (about US$660) between the cost anticipated when placing the order and the amount required to release the goods. The member supplied the estimates and the final invoice, with identifying details removed.

11.In three further accounts, members described spending time comparing requirements or seeking written explanations before making a purchase. They did not report a separately measurable charge in each instance. One member

postponed an order; another reduced its quantity; and a third chose a more expensive source after being unable to establish the likely total cost. These outcomes matter to a small importer even where no discrete penalty or fee is recorded: uncertainty can prevent a transaction, or make a business carry a cost it had not priced.

12.The amounts in paragraphs 7–10 are cases selected from the submitted accounts, not a total for the group and not an average. US-dollar equivalents are approximate figures supplied by the members alongside their pound amounts. They are included to aid comparison and are not Secretariat conversions or a claim about a particular exchange rate. Members’ descriptions of cost categories may overlap; the figures should not be added together as if they measured a common, audited loss.

13.The timelines and documents described show a recurring sequence: an initial commercial decision is made using incomplete cost information; additional requirements or charges become apparent later; the importer seeks clarification under time pressure; and the small firm bears the immediate cash-flow or delay consequence. The evidence does not establish that every later charge was avoidable or improper. It does show why an importer needs a usable explanation of the likely total and of the assumptions on which an estimate depends.

3. Trade Council evidence base

14.As at 12 September 2026, the Trade Council comprised 188 members from 44 countries and had received 380 reports from 47 countries. The median amount at stake in Trade Council reports was approximately US$4,034. Of the 380 reports, 255 concerned tariffs and 125 concerned supplier terms. Reported team sizes were 47 per cent for businesses with 2–9 people, 33 per cent for businesses with one person, 14 per cent for businesses with 10–49 people and 6 per cent for businesses with 50–249 people.

15.The Trade Council’s reports came from a range of countries. The leading reported locations were the United States (71), Canada (57), Mexico (23), the United Kingdom (17), India (14), Australia (12), South Africa (11) and France (11). These are

counts of reports, not a ranking of national incidence or the number of affected businesses. The UK group’s eight members therefore offer a focused account within a wider evidence base, not a basis for country-wide prevalence claims.

16.The Council’s interim pattern review described tariff and landed-cost shocks affecting small importers (RC/TR/2026/N.1). The Council has also undertaken a “Landed Cost Diary” campaign and a supplier-terms survey. This submission complements that work by setting out document sequences and practical effects, while keeping individual member and business identities confidential.

4. Assessment against the five-part pattern test

4.1 Volume

17.The eight members’ evidence alone is limited in volume and cannot establish how often the same sequence occurs across the United Kingdom. At the Council level, however, 380 reports had been received by 12 September, including 255 reports categorized as tariff-related. The Council also had 188 members across 44 countries. These figures support the conclusion that the issue is present in a meaningful body of member evidence, while not proving its prevalence among all importers.

18.The evidence has different forms: dated quotations, invoices, notices, correspondence and member timelines. That breadth is relevant because the problem is often a gap between information at the point of purchase and the amount or requirement encountered later. The group’s four documented cost cases and three additional accounts strengthen the record beyond a single anecdote, but should not be treated as a random or nationally representative sample.

4.2 Frequency

19.The members describe the same kind of difficulty across separate orders and product categories: incomplete cost information at the decision point, followed by charges or administrative demands later in the process. Some accounts concern a direct additional payment; others concern time spent obtaining information,

postponing an order or changing a sourcing decision. Repetition across these accounts supports a finding of recurrence within the submitting group.

20.The wider Council record includes 255 tariff reports and 125 reports concerning supplier terms. Those categories are not a precise count of landed-cost cases, and reports may reflect different circumstances. They nevertheless show that trade-related cost and terms issues recur in the Council’s evidence. The Council’s 106 Trade reports filed in the 30 days before the 12 September data snapshot also indicate continued reporting activity during that period; they do not show that all 106 relate to this submission’s issue.

4.3 Consistency

21.The accounts are consistent in their sequence and effect, though not identical in the charges involved. Members first relied on information available before order or shipment; subsequent notices, invoices or requests changed the expected cost or work; and the member had limited time to respond without risking delay or disruption. The consistent feature is the mismatch between the information available when the commercial decision is made and the information needed to price and manage the import.

22.The evidence does not support a conclusion that every estimate must be a guaranteed final price. Freight, tariffs and other trade requirements can depend on facts that are not known at quotation. A useful standard should instead require providers and relevant actors to state what is included, what is excluded, what assumptions have been used, what may change, and when a trader can expect an update. Transparency about uncertainty is more practicable than a promise that uncertainty does not exist.

4.4 Spread

23.Within the submitting group, the accounts involve several types of goods and different stages of the import process. The problem is therefore not confined in the submitted evidence to one commodity or one charge label. Across the wider Trade Council, reports came from 47 countries, and the Council’s members came from 44 countries. This geographical breadth does not prove that the same legal

or commercial mechanism applies everywhere. It does support a standard framed around practical principles that can be adapted to local rules.

24.The appropriate response should not assume that all small importers have the same products, routes or expertise. It should offer a consistent minimum of clear information and proportional treatment, while permitting requirements to vary where the underlying risk or legal obligation genuinely differs.

4.5 Corroboration

25.The four detailed case summaries are supported by descriptions of contemporaneous records, including quotations, invoices, notices and correspondence. The wider Council evidence includes multiple reports about tariffs and supplier terms. The Council’s ongoing “Landed Cost Diary” work provides a relevant route for recording the time at which cost information is received and changed. Together, these sources corroborate the pattern at a level sufficient to draft a response for consultation.

26.Corroboration remains partial. The Secretariat has not audited the underlying transaction records, verified the legal basis for particular charges, or compared each initial estimate with the final invoice. The submission does not identify a named provider or assert that any particular firm or public body acted unlawfully. Further evidence should be gathered during consultation, especially on what information can reasonably be provided at each stage and which costs can be estimated in advance.

27.On the evidence available, the five-part pattern test is met for a draft standard. That conclusion is a finding about whether a recurring problem warrants a proposed response; it is not a finding of fault against an individual company, nor a determination that every reported cost should be reimbursed.

5. Relevant policy and legal context

28.On 19 May 2026, the UK Late Payments Bill was introduced in the House of Lords. The information available to this submission states that the Bill exempts import/export contracts. The Bill’s introduction and the stated exemption are

relevant to the design of a small-trader response: the payment protections being considered in that Bill do not, on the evidence supplied here, resolve the separate questions of tariff exposure, shipment-stage charges or disclosure of landed costs.

29.This submission makes no claim about the Bill’s later progress, legal effect or interpretation. Nor does it treat the exemption as proof that all import/export contracts fall outside other protections. The point is narrower: the Council’s draft should address the practical trade-cost problem directly and should not assume that late-payment measures alone will meet it. The Secretariat previously addressed the Bill in RC/SEC/2026/3, “On the introduction of the UK Late Payments Bill.”

30.A relevant comparative case is the European Union’s simplification of the Carbon Border Adjustment Mechanism. The European Parliament reported adoption of a 50-tonne annual mass threshold from 1 January 2026, intended to remove about 90 per cent of importers—mostly SMEs—while keeping about 99 per cent of emissions in scope.[3] This is not UK law and is not a proposal to copy a threshold mechanically into other regimes. It illustrates a design principle: a clearly stated, size- or volume-based threshold can reduce administrative burdens for smaller operators while retaining the main policy objective.

6. Recommendations for the draft Small Importer Standard

31.The group recommends that the draft set out a practical minimum for any new trade rule, tariff or related charge that applies to small traders. The Standard should focus on the point at which a trader needs information to decide whether to order, accept a quotation, price goods or arrange a shipment. Its provisions should be expressed in plain language and should distinguish mandatory requirements from recommended practice.

1. Use proportionate thresholds. Where the policy objective permits, draft rules should include size- or volume-based thresholds, simplified processes or low-volume routes. The rule-maker should explain the threshold, the evidence for it and how it will preserve the intended objective. A threshold should not silently shift a disproportionate administrative burden onto the smallest traders.

2. Provide a small-trader route. Where a threshold or exemption is not appropriate, provide a proportionate compliance route: a concise checklist, a usable declaration process, or a clearly signposted point of contact. Guidance should state what information a trader must retain and which steps are required before goods are ordered, dispatched or released.

3. Publish plain-language guidance before commencement. Guidance should explain who is covered, which goods or transactions are covered, what information is needed, how a trader can check its position, and where to seek help. It should include worked cases for low-volume traders and be available early enough for a business to change sourcing, pricing or order timing.

4. Phase in material changes. Where a new requirement or tariff materially changes the information or process needed from a small trader, include a defined transition period where legally and practically possible. State the start date, any transitional treatment, and what happens to orders already placed or goods already in transit. If a phase-in cannot be provided, explain why and provide an equivalent form of practical assistance.

5. Make landed-cost estimates itemized and qualified. A forwarder, broker or other intermediary providing a cost estimate should identify the known components, the party that sets each component, whether it is included or excluded, and the assumptions used. The estimate should distinguish fixed or confirmed charges from estimates and possible contingent charges. If the total cannot be known, say so plainly and state what information is missing.

6. Give timely notice of changes. When a provider learns that an estimate or requirement has changed, it should notify the trader as soon as reasonably practicable, explain the reason and identify the amount or action affected. Where a charge arises at a later stage, the trader should receive an itemized explanation and a route to query it before avoidable storage or delay costs accumulate, where operationally possible.

7. Make information usable for a small team. Guidance and cost documents should be available in a durable written form, with dates, version information and direct links or references to relevant requirements. A small trader should not need specialist knowledge to identify which parts of a quotation are uncertain or which document must be supplied next.

8. Review effects after implementation. The draft should provide for review using evidence from small traders, including whether thresholds are working, whether guidance arrives in time, how often estimates change, and whether delayed disclosure is associated with avoidable costs. Reporting should distinguish the amount charged from the time and administrative work required to resolve an issue.

32.The group recommends that these provisions be framed as minimum practices rather than as a claim that every intermediary controls every part of the import process. The Standard should distinguish the responsibilities of rule-makers, suppliers, forwarders, brokers and traders. It should require each actor to communicate information within its control and not imply that an actor can guarantee a cost set by another party or by a public authority.

33.The group further recommends that the draft include a short model landed-cost statement. It could list the goods and route, the estimate date, the charges included, the charges excluded, the source or responsible party for each amount, assumptions about classification or quantity, possible changes, and the next point at which the estimate will be updated. A model statement would make the recommendation testable and give small businesses a document they can compare across quotations.

7. Conclusion

34.The UK Small Importer Evidence Group’s records describe a repeated operational problem: small firms can commit to an order without a clear view of the full cost and then face new charges, requirements or delays after the decision is difficult to reverse. The evidence is limited and does not establish that every charge is avoidable or that every provider has failed to disclose information. It is sufficiently consistent, repeated and supported by documents described by members to justify a draft response under the Trade Council’s five-part pattern test.

35.The group asks the Council to include size-based thresholds where appropriate, plain-language guidance, proportionate routes for small traders, phase-in periods for material changes and itemized landed-cost transparency. The aim is not to remove legitimate tariffs or trade requirements. It is to make those requirements understandable and manageable before a small business commits money, sets a price or promises delivery.

36.The Secretariat publishes this submission with the consent of the eight members. The members remain anonymous, and no member’s business is identified. The submission is intended to inform the public consultation and subsequent Assembly process for TR-001.

Sources

1. United Nations, “Micro-, Small and Medium-sized Enterprises Day,” https://www.un.org/en/observances/micro-small-medium-businesses-day

2. International Labour Organization, “Micro, Small and Medium Enterprises,” https://www.ilo.org/topics-and-sectors/micro-small-and-medium-enterprises

3. European Parliament, “CBAM: Parliament adopts simplifications to the EU carbon leakage instrument,” https://www.europarl.europa.eu/news/en/press-room/20250905IPR30181/cbam-parliament-adopts-simplifications-to-the-eu-carbon-leakage-instrument

Notes and sources

Sources

1. United Nations, “Micro-, Small and Medium-sized Enterprises Day”
2. International Labour Organization, “Micro, Small and Medium Enterprises”
3. European Parliament, “CBAM: Parliament adopts simplifications to the EU carbon leakage instrument”