Britain Is Making a UK Business Jointly Liable for Your Import Duty. The Date Everyone Is Quoting Isn't in the Bill.

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On 13 July 2026 the UK government published draft legislation for Finance Bill 2026-27 that removes the £135 customs duty relief on low-value imports. Almost every summary of it you will read gives the same deadline: October 2028.

That date is not in the draft legislation. The commencement clause contains no date at all.

And the date is not the most important thing in the document anyway. Buried at section 2 is a new creature in UK customs law — a fiscal representative, a UK business that becomes jointly and severally liable for the import duty debts of an overseas seller. If you sell frames into Britain from outside it, that clause matters far more to you than the duty ever will.

1. What actually happened, and when

The sequence is worth getting straight, because the reporting has compressed four separate events into one.

  • Budget 2025 — the government announced the removal of the relief and the introduction of a new set of customs arrangements.
  • December 2025 to March 2026 — a 12-week consultation on the proposals.
  • 23 June 2026 — a government announcement accelerating the reform "by six months", framed as backing the high street against cheap imports, alongside a review of how VAT is collected from businesses trading through online marketplaces.
  • 13 July 2026 — the summary of consultation responses, a policy paper, an explanatory note, and the draft legislation.

What exists today is a draft clause for a Finance Bill. It is not an Act. It has not been enacted, and until it is, none of it binds anybody. That is the first thing to hold on to, because several trade summaries describe the repeal in the past tense.

2. The £135 relief is a customs duty relief — and only that

The stated policy objective, verbatim from the policy paper:

"The government is removing the customs duty relief for low-value imports and reforming the way these goods are declared into the UK to ensure all goods are appropriately controlled and support improved compliance."

Two words in that sentence do a lot of work: customs duty. This measure is about duty and declarations. The policy paper we read says nothing at all about VAT on goods under £135 — the separate regime under which overseas sellers account for UK VAT at the point of sale on consignments at or below that value. That silence is a negative finding from reading the document, not a statement that the VAT regime is unaffected. If your pricing assumes a particular VAT treatment at £135, do not read this reform as confirming it, and do not read it as changing it either. Check that regime on its own terms.

This distinction is the same one that runs through the European side of the story. A duty and a fee for a formality are different charges with different machinery behind them, and merchants lose money by treating them as one line item.

3. Section 1: what "low-value goods" will mean

The draft inserts a new section 33A into Part 1 of the Taxation (Cross-border Trade) Act 2018. Its opening words:

"Goods are low-value goods for the purposes of this Part if— (a) they are comprised in a consignment the value of which does not exceed £135"

Note the unit. The test is the value of a consignment, with further conditions to be specified by the Treasury, and the Treasury may amend the threshold by regulations. So £135 is not a fixed number either — it is a number a minister can move.

The consignment framing is worth holding next to what Europe has done. The EU's Union handling fee is set at "EUR 2 per item", and the adopted text does not define "item". A pair of prescription glasses is a frame, two lenses, a case and a cloth. Under a consignment test that is one thing; under a per-item test nobody yet knows whether it is one thing or five. Two regimes, two counting units, and only one of them has told you how to count.

4. Section 2: the fiscal representative, and joint and several liability

This is the clause that should change how you plan. The draft inserts a new section 19A into Part 1 of TCTA 2018. The operative words:

"A fiscal representative is jointly and severally liable with the principal for— (a) any import duty to which the principal is liable in respect of low-value goods"

The policy paper describes the role plainly: "a UK-based business that assumes joint and several liability for any debts incurred by an overseas seller in relation to LVI customs declarations".

Read that as a commercial fact rather than a legal one. Joint and several liability means HMRC can pursue the representative for the whole debt without first exhausting its remedies against the overseas seller. Somebody in the United Kingdom, with UK assets, stands behind your duty.

Nobody provides that for a flat monthly fee. The cost of this reform to an overseas eyewear seller is not the duty on a £90 frame. It is the price of persuading a UK business to underwrite an open-ended liability for your declarations — which will be priced as guarantees are priced, with deposits, caps, indemnities and the right to walk away.

What is still open: the draft creates the power and the liability. It does not, in what we have read, make appointment of a fiscal representative mandatory, and the policy paper reserves the detail — "further provisions about fiscal representatives" — to secondary legislation and public notices. Whether this is a route you may take or a route you must take is not yet settled in the text. Treat it as the likely direction of travel, not as a duty that already exists.

5. Section 3: the quiet clause that makes the representative hard to avoid

Section 3 amends section 21(8) of TCTA 2018 so that regulations may limit the acts a customs agent may perform — including preventing agents from making declarations for "a specified description of goods".

Put sections 2 and 3 side by side. One creates a UK person who is liable for your duty. The other takes a power to stop your existing broker from filing the declaration. If that power is exercised for low-value goods, the fiscal representative stops being an option and becomes the only door into the country. A clause that looks administrative is the one that determines whether the clause before it is optional.

6. Section 4: the declarations themselves

Section 4 amends Schedule 1 to TCTA 2018, changing who is eligible to make a customs declaration for low-value goods and when it must be made. The substance sits in secondary legislation that does not exist yet; the policy paper reserves "data requirements, compliance and enforcement provisions, and administrative processes" to later instruments and public notices.

This is the part of the reform with real operational weight — a declaration per consignment, with data you may not currently collect, on volumes that were previously waved through. It is also the part you cannot plan against today, because it has not been written.

7. Section 6: a second relief goes, on its own timetable

The last clause is easy to skim past:

"Section 5 of the UK Reliefs document (consignments containing goods of negligible value) ceases to have effect"

That is a separate relief from the £135 one, and it is abolished by a separate clause — with its own separate commencement power: "This section comes into force on such day as the Treasury may by regulations made by statutory instrument appoint."

So there is not one switch here. There are at least two.

8. The date: what the bill says, and what everyone is quoting

Here is the commencement clause in full:

"5 Commencement of sections 1 to 4
The amendments made by sections 1 to 4 come into force on such day as the Treasury may by regulations made by statutory instrument appoint; and different days may be appointed for different purposes."

There is no date in it. No deadline, no longstop, no October 2028.

The October 2028 everyone is quoting comes from the policy paper, which says: "The measure will come into force on such day as the Treasury may by regulations made by statutory instrument appoint by October 2028 at the latest."

A policy paper is a statement of intention by the government of the day. It is published alongside draft legislation; it is not part of it, it is not enacted with it, and it does not constrain the exercise of the power the clause confers. The deadline in the headlines lives in a document that binds nobody.

This is the same shape of error as the European one, one step further along. In the EU, the amount of the new Union handling fee sits in a delegated act that has been adopted but not published, and its start date is still a square-bracketed instruction to the Publications Office — while every trade source reports "1 November 2026", a backstop from a political agreement, as though it were a commencement date. In the UK, the date is not unpublished; it does not yet exist, and a minister will choose it.

9. "Different days may be appointed for different purposes"

Nine words that most summaries drop. They mean the definition, the fiscal representative regime, the customs-agent restriction and the declaration rules can each be switched on separately — and section 6 has its own power on top. Six clauses, potentially six dates.

Planning for "October 2028" therefore misstates the risk in both directions. The fiscal representative regime could be commenced well before the duty change, to let the infrastructure bed in. Or the definition could be commenced early and the rest years later. The thing to watch is not a date in a diary. It is the laying of a commencement statutory instrument.

10. Why eyewear sits in the middle of this

Three features of the category put it squarely in scope.

Price point. The great majority of frames, sunglasses, readers, lens accessories and contact lens boxes sold cross-border sit comfortably under £135 a consignment. This is not a reform that clips the top of your catalogue; for most eyewear sellers it is the whole catalogue.

Returns. Optical e-commerce runs return rates that trade sources commonly put in the 20–40% band. Every reform that adds a per-consignment cost or a per-consignment formality multiplies against that rate, and the duty and fee regimes differ sharply in whether anything comes back when the goods do.

Multi-component orders. A glazed pair is several things in one parcel. Whether that is one consignment, one item or five is exactly the question the two regimes answer differently — and the question the EU instrument has not answered at all.

11. Britain and Europe are solving the same problem with different mechanics

Both sides of the Channel have concluded that low-value cross-border parcels are under-controlled and under-taxed. They have reached for different levers, and the difference is the whole story for anyone selling into both.

European Union United Kingdom
Instrument Regulation (EU) 2026/2108 (in force) plus a delegated act (adopted, unpublished) Draft clauses for Finance Bill 2026-27 (not enacted)
Old threshold EUR 150 duty exemption, removed 1 July 2026 £135 customs duty relief, removal proposed
Who is on the hook The platform or distance seller is treated as the importer A UK fiscal representative, jointly and severally liable with the seller
Mechanism Reassigns the role Adds a guarantor
Counting unit "EUR 2 per item" — "item" undefined Value of a consignment not exceeding £135
Start date A square-bracketed placeholder in an unpublished delegated act "Such day as the Treasury may … appoint" — no date in the clause
The date being reported 1 November 2026 (a political backstop) October 2028 (a policy-paper intention)

The EU changes who you are in the transaction. The UK leaves you who you are and puts somebody else's balance sheet behind you. If you sell into both, you need two different answers to the same commercial question — and neither regime has given you its start date.

12. What to do now

  1. Stop planning to an October 2028 date. It is an intention in a policy paper, not a deadline in a clause. Plan instead for a commencement SI that could be laid earlier, later, or in pieces.
  2. Work out what share of your UK-bound orders are consignments under £135. For most eyewear catalogues the honest answer will be "nearly all of them". That number is the size of your exposure.
  3. Ask your customs broker, in writing, whether they intend to act as a fiscal representative — and what they would charge to accept joint and several liability. Ask now, while you are one of few asking.
  4. Ask the same broker what happens if regulations bar customs agents from declaring low-value goods. Section 3 takes that power. Your contingency should not be discovered on the day it is exercised.
  5. Model the cost as a guarantee, not as a duty. Deposits, caps and indemnities, not pence per frame.
  6. Check your consignment construction. How you split or combine a glazed order across parcels will interact with a consignment-value threshold in ways it does not today.
  7. Keep the UK and EU workstreams separate. Different units, different liable persons, different instruments. Conflating them is how a pricing model ends up wrong on both sides.
  8. Set a watch on the Finance Bill's progress and, after enactment, on commencement regulations. That is the trigger, not a calendar entry.

Frequently asked questions

Is the £135 relief gone?
No. Draft legislation has been published for Finance Bill 2026-27 that would remove it. It has not been enacted, and even once enacted the clauses commence only when the Treasury appoints a day by statutory instrument.

So is October 2028 wrong?
It is the government's stated intention in a policy paper published on 13 July 2026, and it may well be met. It is not in the draft clause, and nothing in the clause prevents an earlier or later day being appointed.

Will I have to appoint a fiscal representative?
Unresolved. The draft creates the status and the joint and several liability. Whether appointment is compulsory, and for whom, is left to secondary legislation that does not exist yet. Plan for it as a live possibility.

Does this change the VAT I charge on a £100 frame shipped to a UK customer?
The documents we read do not address VAT on low-value goods. That is a separate regime and you should check it separately. Do not infer from this reform that it has changed, and do not infer that it has not.

What is "negligible value relief" and why does it matter separately?
It is a distinct relief, for consignments of goods of negligible value, abolished by its own clause with its own commencement power. If you rely on it for samples, marketing inserts or accessories, it is on a different timetable from the £135 change.

Is £135 fixed?
No. The draft allows the Treasury to amend the threshold by regulations.

I only sell into the EU, not the UK. Can I ignore this?
For compliance, yes. For pricing and logistics strategy, it is worth knowing that two major markets are converging on the same objective through different mechanisms, and that the direction of travel in both is to find somebody with local assets to hold liable. See our pieces on the removal of the EU's EUR 150 exemption and the new Union handling fee.

Where this fits with the rest

This is the fifth telling of one story. On the American side, Section 301 changed what frames cost and the IEEPA ruling may have left you owed a refund. On the European side, the EUR 150 exemption went and a per-item fee replaced the gap. Britain is the fifth.

The connecting thread is not the money. It is the search for a liable person. Europe's device register already turns on whose hands the frames passed through; European product law turns on what the object is classified as; and in an AI checkout the question becomes who the seller of record even is. The UK's fiscal representative is the same question with a different answer: not who you are, but who will stand behind you.


This article is general information about proposed legislation and is not legal, tax or customs advice. The draft clauses discussed here have not been enacted and may change. Nothing here states VisionCarePro's own compliance status. Take advice on your own circumstances from a qualified customs or tax adviser.

Sources. HM Government, draft legislation and explanatory note for Finance Bill 2026-27, "Reforming customs rules for low value imports", published 13 July 2026 (draft clauses 1 to 6, inserting sections 33A and 19A into Part 1 of the Taxation (Cross-border Trade) Act 2018, amending section 21(8) and Schedule 1, and disapplying section 5 of the UK Reliefs document) · HM Revenue & Customs and HM Treasury policy paper, "Reforming the customs treatment of low value imports into the UK", 13 July 2026, including the summary of responses to the consultation run from December 2025 to March 2026 · GOV.UK news story, "Government backs high street with acceleration of cheap import reforms and crackdown on dodgy online sellers", 23 June 2026 · Budget 2025 announcement of the removal of the relief · Regulation (EU) 2026/2108 (OJ L, 2026/2108, 19 September 2026) and Commission Delegated Regulation C(2026) 6694 final of 21 September 2026, as transmitted by Council document ST 13480/26, for the European comparison. Checked 26 September 2026.

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