What is Returned Goods Relief (RGR)?

RGR is a customs relief that allows UK businesses to re-import goods that were previously exported without paying import duty and VAT again, provided the goods are returned in the same state and within three years of export.

What is Customs Drawback and how is it different from RGR?

RGR applies when goods are returned to the UK in the same state. Customs Drawback applies when goods imported into the UK are subsequently re-exported. The trigger is different: RGR is about returns, Drawback is about re-exports. Many businesses qualify for both, and our audit checks all routes simultaneously.

How much could we recover?

Recovery depends on your return volumes, product values, duty rates, and data quality. Our eligibility check and recovery potential tool give you a quick indication, and a full audit quantifies the exact opportunity across RGR, Customs Drawback, and duty overpayments.

Do we need to change our returns process?

Not necessarily. If you already have a stable returns operation, our Customs Gateway service plugs into your existing setup. For businesses that need more support, our Managed Compliance Hub handles the full process end to end.

What data do you need from us?

At minimum, we need export references (MRNs), returns data (order IDs, SKUs, return reasons), and import entry records showing duty and VAT paid. We will assess your data readiness during onboarding and help fill any gaps.

Who remains the importer of record?

You do. Meridian operates as your Direct Customs Representative under a signed Letter of Authority. You remain the Declarant and importer of record at all times.

How far back can you audit?

We can review up to three years of historical import and returns data to identify missed relief opportunities across RGR, Customs Drawback, and duty overpayments.

What if our data has gaps or missing MRNs?

That is common. We run a structured data readiness assessment and work with you to recover missing references, align schemas, and build a clean dataset before filing any claims.

Can you help if we re-export goods imported into the UK?

Yes. Our Customs Drawback service covers goods imported into the UK that are later re-exported. We link import entries to export proof and file for drawback or relief where eligible, covering up to 3 years.

We are a 3PL. Can you work with our clients?

Absolutely. Our 3PL Partnership Programme lets you offer duty and VAT recovery as a value added service to your e-commerce clients. We handle the compliance, you handle the logistics.

Our pricing is performance-based and tailored to your returns volume. Recovery audits operate on a success fee model: no recovery, no fee. Ongoing managed service fees are volume-based. All fees are agreed in writing before any work begins. Contact us for a pricing consultation.

Evidence Packs: What HMRC Expects | Meridian Drawback UK

A duty recovery claim is only as strong as the evidence behind it. HMRC does not take your word for it. They need documented, structured proof that the goods qualify for relief and that the claim is accurate. This guide covers what HMRC expects for both RGR and Drawback claims, and how to build a defensible evidence pack for every case.

What HMRC expects for RGR claims

For Returned Goods Relief, HMRC needs to see a clear, provable story: the goods were exported from the UK, they were returned in the same state, and the correct relief was claimed at re-import. The evidence pack must cover:

Proof of original export

The export MRN is the anchor of every RGR claim. It proves the goods left the UK and provides the reference HMRC uses to verify the original declaration. Without it, the claim cannot proceed.

Commercial documentation

Commercial invoices, packing lists, and transport documents (airway bills, bills of lading) that support the declared value, description, and quantity of the goods. These must be consistent across the export and re-import.

Same state evidence

For RGR claims, HMRC needs to see that the goods returned in the same condition as when they were exported. This is typically demonstrated through intake photography, condition grading, and scan event records at the point of return.

Import entry records

The CDS declaration for the re-import, showing the correct RGR Customs Procedure Code (CPC) was applied and the appropriate relief was claimed. This is where the filing itself becomes part of the evidence.

Chain of custody documentation

Records showing the journey of the goods from export to return. Tracking numbers, carrier manifests, and warehouse intake logs that demonstrate the goods were not diverted, altered, or substituted.

For a full overview of RGR eligibility and the returns lane, see Returned Goods Relief explained.

What HMRC expects for Drawback claims

Drawback evidence follows a different path, proving that duty was paid on import and that the goods were subsequently re-exported. The key documents include:

Original import entry showing duty paid (MRN, HS code, duty amount)
Export declaration for the re-exported goods (export MRN)
Exit confirmation proving the goods left the UK
Commercial invoices linking the import to the export
Transport documentation for the re-export shipment
For overpayment claims: corrected classification, valuation, or origin evidence

For a deep dive into all three recovery routes (RGR, Drawback, and overpayments), see Customs Duty Drawback: Recovering Duty on Re-Exports.

Common evidence mistakes

Most claims fail not because the goods are ineligible, but because the evidence is incomplete, inconsistent, or poorly organised. The most common mistakes:

Incomplete photo evidence

A single photo is not enough. HMRC expects multi-angle evidence that clearly shows the item, its condition, and any identifying marks. Blurry or poorly lit photos undermine the claim.

Missing MRN linkage

The most common failure. If you cannot link the return to the original export MRN, the claim fails. This is why MRN matching is the critical first step in any evidence pack.

Inconsistent data across systems

When the returns platform says one thing, the warehouse system says another, and the customs declaration says something else, HMRC sees a claim that cannot be trusted.

No structured retention

Evidence that exists but cannot be retrieved is as bad as evidence that does not exist. HMRC can review claims for years after filing. If you cannot produce the evidence on request, the claim is at risk.

Filing without checking

Submitting claims with known data gaps or unresolved exceptions creates audit risk. Every claim should pass a quality check before filing.

The MRN linkage problem is the most common failure. Read more about how to solve it in MRN Matching: Why It Matters.

Best practices for audit-ready evidence

Standardise intake evidence capture with a defined checklist for every return
Automate MRN matching to reduce manual errors and speed up the process
Use structured exception queues to handle unresolvable cases transparently
Retain all evidence for at least 7 years in line with HMRC requirements
Run regular quality audits on evidence packs before filing
Build immutable audit logs so every action is timestamped and traceable

How Meridian builds evidence packs

The Meridian Compliance Hub automates evidence pack assembly. For every case, the platform collects export references, commercial documents, and intake evidence into a structured, checklist-driven pack. Every action is logged in an immutable audit trail. Evidence is retained for the full HMRC review period. And exceptions are flagged and resolved before filing, so rejections are rare and disputes are quick to resolve.

The result: HMRC sees a clear, transparent claim backed by complete, organised evidence. Approvals are faster. Rejections are fewer. And your operation is defensible at every stage.