Recommendation 19

HMRC told us that its main trader concerns related to small businesses. It had a high level of confidence that large traders, which are responsible for about 85% of the value of imports from the EU to the UK, would be ready for January 2022.60 Its focus was therefore on improving the readiness of the remaining 15%, which is around 90,000 smaller traders, 41,000 of which carry out what HMRC consider to be a material level of trade (between £50,000 and £1,500,000). Many traders had already submitted customs declarations by 51 Qq 42, 72 52 Q 160 53 C&AG’s Report, paras 1.12, 1.13 54 Q 143 55 Qq 59, 143, 154, 175, 176 56 Q 138; C&AG’s Report, para 3.3 57 Q 35 58 Q 61 59 Q 161 60 Qq 166, 181 16 EU Exit: UK Border post transition October 2021 and HMRC told us it was still making efforts to improve the readiness of the remaining traders that are harder to reach since they have either stopped international trading or do it infrequently. Even if most large traders and a significant proportion of smaller traders are ready for import controls, the impact on those who are not ready could still be serious.61