GMR for an empty trailer and oral declaration traffic – when it is still required

Many drivers and dispatchers assume that travelling to the UK with an empty trailer to collect a load, or carrying goods declared under oral declaration, means they can board the ferry without a GMR. This is one of the most common — and most costly — mistakes in managing RoRo traffic through UK ports. A Goods Movement Reference is a system document processed by GVMS (Goods Vehicle Movement Service), and the requirement for one is not based on the value or type of goods, but on the simple fact of passing through a port integrated with that system. This article explains precisely: which scenarios always require a GMR, when you can legally travel without one, how to reconcile oral declaration with GVMS, and how to generate a GMR in practice for an empty trailer or a tractor unit travelling unladen.

Official source: GOV.UK – Get a goods movement reference

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What is a GMR and why GVMS changes the rules

A Goods Movement Reference (GMR) is a unique number generated in GVMS that links a vehicle to specific customs declarations or authorisations. Without a valid GMR scanned at the border check, a vehicle will not be permitted to board the ferry at RoRo ports operating under GVMS.

GVMS has been in operation since 1 January 2022 as part of the full import control model for goods entering the UK. Ports that have implemented it — including Dover, Holyhead, and Liverpool — require a GMR from every vehicle, regardless of whether it is carrying commercial goods, duty-exempt goods, or travelling completely empty.

The key principle: a GMR is a port and transport requirement, not a customs one. Even if there is no customs declaration to attach — a GMR is still required at GVMS ports.

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When a GMR is always required — list of scenarios

The table below shows the most common cases:

Scenario	GMR required?
Tractor unit + loaded trailer, GVMS port	YES
Tractor unit + empty trailer, GVMS port	YES
Tractor unit without trailer (solo), GVMS port	YES
Goods under oral declaration (<£1,000, non-commercial), GVMS port	YES
Duty-exempt goods (ATA Carnet, ToR), GVMS port	YES
Postal consignments carried by vehicle through a GVMS port	YES
Crossing through a non-GVMS port (e.g. a small local port)	NO
Eurotunnel (Eurostar Shuttle) – special operating mode	Depends on operator

Practical rule: if the port operates GVMS, a GMR is always required — without exception for load type.

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When you can legally travel without a GMR

There is a limited number of situations in which a GMR is not required:

1. Non-GVMS ports A small number of UK ports have not implemented GVMS. These include certain smaller ferry terminals. Before using such a route, confirm the port's status directly with the operator or on GOV.UK, as the list of GVMS ports is regularly extended.

2. Eurotunnel (Le Shuttle) — special operating mode Eurotunnel operates its own control system and for a period ran outside the standard GVMS framework. However, from 2024 Eurotunnel has been progressively integrated with GVMS — always check the current requirements on the operator's website before travelling.

3. Private passenger without a commercial vehicle GMR applies to commercial vehicles (HGVs, goods vans). Private vehicles carrying no commercial load are not subject to GVMS.

4. Non-RoRo sea freight GMR is a requirement for roll-on/roll-off traffic. Containers transported by sea (Lo-Lo) use separate customs procedures.

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Oral declaration and GMR — how they work together

Oral declaration is a simplified customs procedure available for: - non-commercial goods with a value below £1,000 (e.g. personal equipment, samples) - goods covered by a personal baggage exemption - certain categories of goods exempt from duty by their nature

A common misconception: because there is no formal customs declaration to attach to GVMS, no GMR is needed. This is wrong.

How it works in practice: 1. The driver generates a GMR in GVMS (via GOV.UK or through TSP software) 2. When creating the GMR, the driver selects the "oral declaration" or "by conduct" option — without attaching any MRN declaration numbers 3. A GMR with the oral/by conduct category selected is a valid document entitling the driver to board the ferry 4. At the border, the customs officer may ask about the goods — the driver declares them verbally

A GMR is therefore a carrier of information about the clearance method, not the customs declaration itself.

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"By conduct" traffic — what it means

"By conduct" is a term describing a situation in which goods are treated as declared to customs by the very act of passing through the appropriate border lane — without completing a formal document.

This applies mainly to: - Goods forming part of a passenger's personal baggage (non-commercial) - Certain exemption categories based on value

In the context of heavy goods vehicles, "by conduct" is rarely applicable — the overwhelming majority of commercial traffic requires a formal customs declaration. However, even where a vehicle qualifies for by conduct (e.g. carrying only the driver's personal belongings), a GVMS port still requires a GMR with the appropriate category selected.

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How to generate a GMR for an empty trailer — step by step

An empty trailer travelling to collect a load in the UK, or returning unladen, requires a GMR in exactly the same way as a loaded vehicle. Here is how to generate one correctly:

Step 1: Log in to GVMS The system is accessible via GOV.UK or through integrated TSP (Transport Service Provider) software.

Step 2: Create a new movement Enter: - Vehicle / trailer registration number - Planned port and date - Direction: import to UK or export from UK

Step 3: Select the load type For an empty trailer, select the "No goods" or "Empty vehicle" option — depending on the GVMS interface version. No MRN declaration number is attached.

Step 4: Generate the GMR The system assigns a unique GMR number. Save it and ensure it is available as a QR code or number for scanning at the port gate.

Step 5: Verification at the port gate Port staff scan the GMR. The vehicle is permitted to board the ferry.

GMR field for an empty trailer	Value
Goods description	"Empty trailer" / "No goods"
MRN declarations	None (field left blank)
Movement type	Import/Export — depending on direction
Vehicle reg	Registration number of tractor unit and trailer

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Common mistakes and their consequences

Mistake 1: No GMR for an empty trailer Outcome: refused boarding, need to generate a GMR on the spot (if time permits), a delay of several hours or loss of the ferry booking.

Mistake 2: GMR assigned to the wrong vehicle A GMR is linked to a specific registration number. Changing the tractor unit or trailer requires an updated or new GMR.

Mistake 3: Expired GMR A GMR has an expiry time. If the journey is delayed beyond the planned window, the GMR may expire and need to be regenerated.

Mistake 4: Oral declaration without a GMR As described above — the absence of a GMR at a GVMS port blocks entry regardless of the clearance method.