Empty Containers and EXS: The Rule Hauliers Often Miss

The Rule: Empty Still Counts

A surprising number of hauliers discover — often after a delay at the border — that empty container and trailer movements can require an EXS. The logic is simple from HMRC's perspective: if something is being transported under a contract, safety and security authorities want to know about it.

Under the Customs (Safety and Security Procedures) Regulations, an EXS is required when:

• An empty pallet, container, or vehicle is moved under a transport contract.
• The movement includes empty reusable packaging — stillages, roll-cages, dollies, or similar returnable equipment.

It doesn't matter that the container is empty. What matters is that a contract exists and the equipment is crossing the UK border outbound.

What Hauliers Often Assume (and Why It Goes Wrong)

Common misconceptions:

• "It's empty, so there's nothing to declare." — Incorrect. The empty equipment itself is the subject of the declaration.
• "The ferry operator handles it." — Sometimes, but not always. Always confirm contractually who is filing.
• "I filed an ENS on the inbound leg, so I'm covered." — ENS and EXS are separate filings. Inbound cover does not extend to the outbound leg.

What to File

A standard EXS with the following data:

• Carrier details (the haulier or transport operator)
• GB EORI number
• Container/trailer identification (BIC code for containers, vehicle registration for trucks)
• Destination and route
• Empty equipment description — including quantity and type for reusable packaging
• Estimated time of departure

Why Errors Are Common

The paperwork is straightforward, but the trigger is easy to miss. Many hauliers are focused on the loaded leg of a journey and don't anticipate that the return empty leg also requires filing.

Our Recommendation

If you run regular outbound-and-return routes, set up a bulk EXS workflow with a representative who understands the empty-container rule. It's cheaper than one delayed crossing.

EXS Declaration UK handles empty container movements routinely for haulage customers across the UK. Same-day submission, 24/7 availability, no surprises at the port.

Contact us to set up regular cover.