
Gibraltar Customs Clearance:
Latest Gibraltar Customs guidance covering Transaction Tax refunds, goods dispatched before 15 July 2026, ASYCUDA, T1GI/T2GI, Customs guarantees and commercial clearance procedures.
First published: 22 July 2026 | Last updated: 5 September 2026
Gibraltar’s new customs and trading arrangements have been in operation since 15 July 2026. This living operational guide tracks what is happening in practice: Commercial Gate conditions, customs processing, documentation problems, official guidance and the practical lessons emerging for importers, retailers, freight operators and customs representatives.
This living operational guide is updated when substantive new information becomes available. Detailed explanations of the underlying rules remain available in Gibraltar.com’s Gibraltar Treaty Update: Practical Terms and Transaction Tax on Imported Goods guides; this page is intended to show how the system is working in practice.
IMPORTANT UPDATE — 5 SEPTEMBER 2026
HM Government of Gibraltar issued a Public Guidance Note on 4 September 2026 confirming a refund process for qualifying goods that were dispatched to Gibraltar before the new Customs and Transaction Tax arrangements came into effect on 15 July 2026.
The clarification is particularly relevant to Gibraltar businesses, importers, clearing agents and individuals whose goods had actually started their movement to Gibraltar before 15 July, but were cleared after the new arrangements commenced and became subject to Transaction Tax.
Under Article 269(1) of the UK–EU Agreement in respect of Gibraltar, transitional treatment applies to goods whose movement started before the Agreement took effect and ended afterwards.
The critical point is the date on which the movement or transport of the goods actually started.
Goods do not qualify merely because an order was placed, an invoice was issued or payment was made before 15 July. There must be reliable evidence showing that the goods were dispatched, shipped or otherwise placed in transport before that date.
Where a qualifying consignment was subsequently cleared and Transaction Tax was paid under the post-15 July regime, HM Customs Gibraltar will consider a claim for reassessment under the pre-15 July import-duty regime.
Where that reassessment establishes an overpayment, the verified difference will be refunded.
For the wider framework now applying to imports, exports and the movement of goods, see Gibraltar.com’s Gibraltar–EU Treaty: Trade & Customs Guide.
The clarification makes an important distinction between the date of the commercial transaction and the date on which the goods themselves started moving.
An order confirmation, commercial invoice or payment dated before 15 July does not, on its own, establish eligibility.
Goods that were ordered and paid for before 15 July but remained with the supplier and were not dispatched until afterwards do not qualify simply because the purchase took place earlier.
By contrast, goods that were actually dispatched, shipped or placed in transport before 15 July, but completed their journey and were cleared after the new arrangements commenced, may fall within the transitional provisions.
For businesses reviewing affected consignments, the relevant sequence is:
Order / invoice / paymentDispatch and commencement of transportCustoms clearanceTransaction Tax paid
It is the commencement of movement before 15 July 2026 that is central to eligibility.
A trader, clearing agent or member of the public who considers that a consignment qualifies may pursue a claim.
The submission route depends on who lodged the original Customs declaration.
Where a clearing agent lodged the Customs declaration, the affected business or individual should make the claim through that clearing agent. The completed claim form and supporting documentation should be provided to the agent for onward submission to HM Customs Gibraltar.
Businesses that are registered ASYCUDA users and lodge their own Customs declarations may submit their claims directly to HM Customs Gibraltar.
Completed claim forms and supporting documentation for direct claims should be submitted to:
The same email address may also be used for assistance or clarification concerning the refund process.
HM Customs has issued a specific Refund Claim Form for claims under these transitional arrangements.
The completed form must accompany the supporting documentation for the claim.
Where a clearing agent lodged the original Customs declaration, the claimant should obtain and process the form through that clearing agent.
Registered ASYCUDA users who lodge their own declarations can obtain clarification concerning the claim form and direct submission process from HM Customs at refunds@hmcustoms.gov.gi.
HM Customs must be able to verify both the eligibility of the goods under the transitional arrangements and the amount originally paid.
The relevant SAD/E-number or numbers should therefore be identified for each potentially qualifying Customs entry.
The supporting documentation should include:
Evidence showing that the movement of the goods started before 15 July may include:
The distinction between commercial and transport records is important.
An invoice establishes information about the commercial transaction. Proof of payment establishes when payment was made. Neither necessarily establishes when the goods physically entered transport.
For the transitional arrangements, documentary evidence showing actual dispatch or commencement of transport before 15 July 2026 is therefore essential.
The transitional procedure does not mean that the whole amount of Transaction Tax paid will automatically be returned.
A qualifying consignment is considered for reassessment under the pre-15 July import-duty regime.
HM Customs will verify the amount originally paid and the treatment that would have applied before the new arrangements commenced.
Where this establishes an overpayment, it is the verified difference that is refunded.
Submitting a claim does not itself create an entitlement to a refund. A claim may be declined where the evidence does not demonstrate that movement started before 15 July 2026 or where the amount claimed cannot be substantiated.
Businesses that imported goods around the 15 July 2026 changeover should review their Customs and transport records to identify consignments that may have been caught between the previous Import Duty arrangements and the new Transaction Tax regime.
A useful review sequence is:
Dispatched before 15 JulyEvidence of transportCleared after 15 JulySAD/E-numberTransaction Tax paid
The review should not be restricted to goods ordered immediately before 15 July.
Goods may have been purchased considerably earlier but still potentially fall within the transitional arrangements if their movement actually commenced before 15 July and ended afterwards.
Conversely, goods ordered, invoiced or paid for before 15 July do not qualify on that basis alone if their transportation did not commence until after the new arrangements came into effect.
For businesses importing regularly during the transition period, the refund procedure may therefore be relevant to more than one consignment.
For the current practical Treaty position, including Customs, Transaction Tax and business requirements, see Gibraltar.com’s Gibraltar EU Treaty Practical Guide for Residents and Businesses.
This refund process deals specifically with the transitional treatment of goods whose movement started before 15 July 2026 and ended afterwards.
It is separate from the continuing Customs procedures applying to current imports, including:
The wider movement-of-goods framework is covered in Gibraltar.com’s Gibraltar–EU Treaty: Trade & Customs Guide.
The separate issues surrounding transit guarantees, reported importer deposits and the Global Guarantor are covered in Gibraltar.com’s Customs Guarantees, T1GI/T2GI and the Global Guarantor.
The 4 September clarification provides a defined route for Gibraltar businesses and individuals whose goods were genuinely already moving when the new Customs and Transaction Tax arrangements commenced.
It also clarifies an important issue for businesses reviewing historic entries:
The relevant test is when the movement of the goods actually began — not simply when they were ordered, invoiced or paid for.
For regular importers, this may affect several consignments. Customs entries, transport documentation, invoices and payment records from the period surrounding 15 July should therefore be considered together when identifying potentially qualifying movements.
Possibly, but ordering the goods before 15 July is not sufficient on its own. The evidence must show that the movement or transport of the goods actually started before 15 July 2026.
No. Payment before 15 July does not itself establish eligibility. There must also be evidence that the goods were dispatched, shipped or otherwise placed in transport before that date.
No. A commercial invoice forms part of the supporting documentation but does not, by itself, prove when the movement of the goods began.
Potentially, yes. Where the movement started before 15 July, ended afterwards and Transaction Tax was subsequently paid, the consignment may be considered for reassessment under the transitional arrangements.
Evidence may include a CMR or consignment note, bill of lading, air waybill, courier or carrier tracking record, freight documentation, dispatch note or other reliable transport evidence showing when movement commenced.
Yes. The relevant SAD/E-number or numbers should be identified as part of the claim.
Yes. The relevant commercial invoice or invoices should be included with the supporting documentation.
Yes. Proof of payment forms part of the evidence used by HM Customs to verify the claim and the amount originally paid.
Yes. HM Customs has issued a specific Refund Claim Form for this transitional refund process. The completed form must be submitted with the relevant supporting documentation.
Where a clearing agent lodged the original Customs declaration, the claim should be made through that clearing agent. The completed form and supporting documents should be provided to the agent for onward submission to HM Customs Gibraltar.
Yes. Registered ASYCUDA users who lodge their own Customs declarations may submit claims directly to HM Customs Gibraltar.
Completed claim forms and supporting documentation for direct submissions should be sent to refunds@hmcustoms.gov.gi.
Yes. The same email address may be used for assistance or clarification concerning the refund process.
Not necessarily. HM Customs will reassess a qualifying consignment under the applicable pre-15 July import-duty regime. Where this establishes an overpayment, the verified difference will be refunded.
No. Submission of a claim does not itself establish entitlement. HM Customs must verify eligibility and the amount paid before issuing a refund.
Potentially, yes. A regular importer may have several consignments that meet the transitional criteria. Each relevant entry and its supporting evidence will need to be identified and considered.
The critical date is when the movement or transport of the goods actually started. An order date, invoice date or payment date may form part of the supporting records, but none determines eligibility on its own.
Gibraltar.com will continue to monitor the practical operation of Gibraltar’s new Customs arrangements, including Transaction Tax, transitional refunds, T1GI and T2GI procedures, Customs guarantees, ASYCUDA processing, Commercial Gate operations and practical issues affecting Gibraltar businesses and importers.
This living operational guide will be updated when substantive new information becomes available.
For broader guidance, see Gibraltar.com’s Gibraltar–EU Treaty: Trade & Customs Guide and Gibraltar EU Treaty Practical Guide.
IMPORTANT UPDATE — 8 AUGUST 2026
New practical issues have emerged around T1GI and T2GI transit guarantees, including reports that customs representatives may require Gibraltar importers to provide substantial advance financial cover.
We have reviewed the formal customs guarantee requirement, reports of deposits equivalent to 21% of the value of goods, and the current published position regarding HM Government’s previously announced Global Guarantor.
There is an important distinction between the legal requirement for a customs transit guarantee and any separate cash deposit or financial security required by an individual customs representative.
Read the 8 August Customs Guarantees & Global Guarantor Update
The initial disruption affecting commercial goods after implementation of the new customs arrangements has begun to settle, although the system remains in an early operational phase. Commercial goods are moving, but importers, freight operators and customs representatives should continue to allow additional time for documentation, declarations and more complex consignments.
Government, HM Customs and business representatives continue to monitor implementation and address operational issues as they arise. No official normal-processing benchmark has yet been published for Commercial Gate clearance times. The Operational Status chart below has therefore been updated conservatively and remains AMBER in the principal operational areas.
This update concerns commercial goods and customs clearance only.
| Area | Status | Current position — 30 July 2026 |
|---|---|---|
| Commercial Gate | AMBER | Operational. Significant freight queues and clearance delays were reported during the initial implementation period. No official normal-processing benchmark has yet been published. |
| ASYCUDA | AMBER | The system remains in use. An interruption was reported during the first days, but no continuing outage has been officially announced. |
| Customs declarations | AMBER | Transitional and new Treaty movements continue to require careful processing. Unfamiliar procedures and incomplete documentation may still contribute to delays. |
| Time-sensitive goods | AMBER | No further major incident has been publicly confirmed, but medicines, fresh produce and other urgent consignments remain particularly exposed to documentary or transit delays. |
| Business guidance | AMBER | Official technical notes and business FAQs are available. Further practical post-implementation clarification may still be required as operational issues emerge. |
| Treaty implementation | GREEN | The customs and Transaction Tax arrangements remain in provisional operation from 15 July 2026. |
| Government/business engagement | AMBER | Government, HM Customs and business representatives continue to monitor implementation and address operational issues as they arise. |
| Continuing review | GREEN | Updated when substantive new information becomes available. |
After several days of disruption, freight movement began to improve by Friday 24 July. The Commercial Gate remains operational. Around 170 trucks entered Gibraltar on 21 July and 184 on 22 July, compared with reported pre-Treaty daily volumes of approximately 230–250. The position is improving, but delays and reduced delivery capacity continue to be reported, and no official normal-processing benchmark has been published.
The Government confirmed on 23 July that two technical causes affecting medicines had been identified on the Spanish side and that the necessary corrections were being applied. The delayed chemotherapy consignment arrived, no patient treatment was affected and there was no concern over GHA or pharmacy stock levels. Food consignments of non-EU origin also resumed, although time-sensitive movements remain an area requiring close monitoring.
The Spanish Tax Agency published additional NCTS6 requirements on 21 July for T1GI and T2GI movements. From 22 July, declarations must include an Additional Supply Chain Actor with the role of consolidator, and the net mass recorded for goods within a referenced house consignment must match the net mass in the related import or export declaration. Contingency plans are also available for the designated customs posts at La Línea and Algeciras for use when the relevant customs applications are unavailable or affected by an IT incident.
Postal items to and from Gibraltar are no longer moving directly by air under the previous arrangements and are instead being transported by road through Spain. Longer transit times have been indicated while the new route and Spanish-side operational procedures settle. Businesses and individuals relying on urgent post or parcels should allow additional time and review tracking and delivery expectations accordingly.
HM Customs officers continue to visit larger importers to guide them through the process, alongside the training already offered before implementation. Government, Customs, Spanish authorities, customs agents and freight operators continue to work through problems as they arise. The Business Transition Advisory Group has met following implementation, and a further meeting is expected in the coming weeks, but no date has yet been published.
The frontier is the final stage of a wider customs process, not the place where that process should begin. Importers need to confirm the route, declarations, transit arrangements, data fields, tax treatment and responsibilities before the goods leave the supplier. The new Spanish NCTS6 validations make pre-dispatch checking even more important, particularly for groupage and consolidated loads.
Many UK, EU and overseas suppliers will not understand Gibraltar’s new procedures or the change to postal and overland routes. Importers should provide written shipping and documentation instructions rather than assume the supplier, carrier or postal operator already knows which information, codes and references are required.
Businesses using experienced customs agents and customs-clearing services, supported by freight forwarders, couriers and logistics providers, are better placed to identify the correct transit procedure, apply current NCTS6 requirements, prepare declarations and resolve errors before a consignment reaches the Commercial Gate. For smaller importers, outsourcing the process may be more efficient than attempting to manage every declaration internally.
Generic descriptions, uncertain commodity classifications, missing origin evidence, incomplete values and mismatched consignment data can create delays. Businesses should maintain reliable product records covering description, classification, origin, customs value, applicable licences, certificate or exclusion codes, Transaction Tax treatment and, for consolidated movements, the required house-consignment and net-mass information.
Goods sent from the United Kingdom are not automatically UK-origin goods. A product manufactured elsewhere and distributed through the UK may remain a third-country product for customs purposes. The origin claimed must be supported by appropriate evidence, irrespective of whether the goods now reach Gibraltar by road, post or another permitted route.
The supplier, carrier, consolidator, customs agent, transit guarantor, Spanish customs representative, Gibraltar importer and HM Customs may all form part of the same movement. A missing document, incorrect code, inconsistent mass figure or misunderstood responsibility at one stage can delay the entire consignment, even where the remaining documentation is correct.
Importers of medicines, refrigerated products, fresh food and urgent operational supplies should identify named escalation contacts before dispatch. They should confirm how cold-chain integrity, storage and delivery timing will be protected if clearance is delayed. Businesses relying on urgent mail or parcels should also review lead times now that postal traffic is moving overland through Spain.
Businesses operating with very limited stock may need to allow more lead time or hold a modest buffer while the procedures settle. Freight flow has improved but has not yet been shown to be consistently normal, and postal transit times may also be longer. This is especially relevant where a late delivery could interrupt healthcare, hospitality, retail, construction, workshop or professional operations.
Before a commercial consignment is dispatched, the importer should:
Businesses that need help interpreting customs valuation, Transaction Tax, commercial records or contractual responsibilities can also locate accountants and tax advisers and legal services through Gibraltar.com. All directory links are provided for information and ease of reference, not as recommendations.
EU goods generally move to a designated customs post under a T2 transit procedure. After the relevant formalities are completed, a T2GI movement is opened for the journey to Gibraltar. HM Customs closes the T2GI movement on arrival and collects Gibraltar Transaction Tax and any applicable excise duty where the goods are being placed on the Gibraltar market.
Non-EU goods generally use T1 and T1GI procedures. Applicable EU customs duty is dealt with at the designated customs post, while HM Customs deals with the Gibraltar element of the import. Additional product-compliance, sanitary or regulatory controls may apply according to the goods and their origin.
For the full legal and procedural framework, read the Gibraltar.com guides and the official HM Government, HM Customs and Spanish customs technical guidance listed at the end of this page. Related commercial guidance is also available through the Doing Business in Gibraltar hub.
The standard Transaction Tax rate is 15% during the first Treaty year, with reduced, zero and exempt treatment applying to qualifying goods. The tax is based on the relevant customs value rather than the retail selling price. Customs value can include duties, excise and incidental expenses such as transport, insurance, commission and packing.
Businesses should therefore calculate landed cost product by product. Applying a flat 15% increase to the retail price does not accurately reflect how Transaction Tax operates. Where classification, valuation or tax treatment is uncertain, specialist advice should be obtained before pricing or dispatch.
Yes. It remains operational. Freight delays began to ease by Friday 24 July, but movement has not yet returned consistently to the reported pre-Treaty level and no official normal-processing benchmark has been published.
ASYCUDA remains the HM Customs Gibraltar declaration system, and no continuing Gibraltar-side outage has been officially announced. Separate Spanish NCTS6 validations and contingency arrangements have been updated for movements connected with Gibraltar.
Reported causes include unfamiliar procedures, transitional and new-system goods being processed at the same time, missing or incorrect codes, inconsistent data, groupage complexity, duplicate system entry and coordination problems across the Gibraltar and Spanish customs chain.
No. The relevant transitional treatment depends on the applicable rule and supporting evidence. For movement-based treatment, businesses need evidence that transport or shipment began before implementation, not simply an earlier order or payment date.
No. Dispatch and legal origin are different. Any preferential origin claim must satisfy the applicable rules and be supported by evidence.
Not necessarily. Official guidance states that a Gibraltar business may not need its own NIF/EORI where a customs agent completes the formalities and pays the relevant taxes and duties from the agent’s own account. The arrangement should be confirmed before dispatch.
The standard rate is 15% during the first Treaty year. Reduced, zero and exempt treatment applies to qualifying goods.
The Government has indicated that a further meeting will be arranged in the coming weeks. No specific date has been published as at 27 July 2026.
One-off commercial deliveries: The Department of Business one-off delivery exception concerns business registration and licensing only; it does not remove applicable customs, Transaction Tax, product, vehicle or transport obligations.
This page provides general information on Gibraltar’s developing customs and trading arrangements. Businesses should check the applicable legislation and the latest guidance issued by HM Government of Gibraltar, HM Customs and the relevant Spanish customs authority and obtain professional customs, freight handling, tax or legal advice where appropriate.
Gibraltar.com provides practical explanations and connects readers both to related Gibraltar.com guidance and to relevant service-provider categories. Contextual service links are included for information, support and ease of reference. They do not constitute recommendations and do not replace individual professional advice.
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Published by the Gibraltar.com Editorial Team
First published: 22 July 2026 | Last updated: 5 September 2026
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