Let’s for a moment assume, as they do, that the number of clearances will not reduce (which they seem to have ignored – oddly) that means the cost will be £100 a clearance. That is made up of an assumed £32.50 charge on each side of the import or export plus, I guess, a broadly similar cost to business to actually complete the forms.
So the rational question to ask is whether it might cost £35.00 for business to complete a customs declaration. Even if large parts of this could be automated the whole process will take time, effort, management, communication, systems, checks, audits and delivery so that the right person has the right form on the right consignment at the right time. Of course costs will vary. But allowing for overheads and on costs of employment £35 seems entirely fair for business.
In which case it seems fair for processing too. Twice over, of course.
So my gut reaction is that HMRC may well be in the right area with this one.
But to do country by country reporting to sate the delusions of one monomaniac has no costs at all.