Short answer
A driver heading to the UK secures the vehicle with a padlock or a numbered seal (plus a TIR cord on a soft-sided vehicle), checks it after every stop and immediately before border control, and records every check. The Level of Penalty Code reductions depend on those records. The company is responsible for equipment, instructions, training and monitoring.
Why the record matters as much as the padlock
Since 13 February 2023, securing the vehicle does not remove the penalty, but it decides how much it is. Border Force may reduce a penalty if the responsible person shows they took the actions set out in the Carriers’ Liability Regulations 2002 (as amended in 2023): securing, checking, reporting and keeping records (s.32(2B)–(2D) IAA 1999). A check that was not recorded is, in practice, hard to prove.
Before departure and at loading
- Get a vehicle security checklist from your employer or use the Home Office checklist on GOV.UK. The securing instructions are also available in other languages, including Polish and German.
- Supervise loading. If you cannot, check the vehicle as soon as possible after loading.
- Check the fabric (bodywork, canvas) and note any damage on the checklist.
- Hard-sided vehicle: lock the doors and secure them with a padlock.
- Soft-sided vehicle: also fit a working TIR cord secured by a robust padlock or a uniquely numbered seal, and record the seal number before departure.
- Secure panniers and pallet lockers, and check the wind breaks and the space around the axles.
After every stop
- Walk around the vehicle: fabric, roof, locks, cord and seals. Pull each security device to check it is intact.
- Break the seal or open the lock and check inside. If you replace a seal, record both the old and the new number.
- Look for signs of tampering. If you see any, check the load and load space and report it to the local authorities.
- Record the check: date, time, place, signature.
Immediately before the UK control zone
- Repeat the full after-stop check and record it.
- If the vehicle could not be secured using the optimal method, carry out a thorough check of the load and load space.
- If you know or suspect someone is hiding in the vehicle, do not go through UK border control and do not board the ferry or train. Tell an immigration officer, the police or Border Force, and do not approach anyone hiding.
Overview: regulation, action, record
- Reg. 2B, before the journey: uniquely numbered seal, working TIR cord, fabric check, working locks. Record: seal numbers before departure (2E(4)).
- Reg. 2C, during the journey: checks after every stop, if tampering is suspected, on a change of driver and immediately before immigration control. Record: every check (2E(3)).
- Reg. 2D, reporting: police in the country where it happened or an immigration officer; if you suspect an entrant, do not enter control. Record: who it was reported to and when.
- Reg. 2E, records: the company records that it provided the security measures (2E(2)); the driver records their actions; breaking or replacing a seal (2E(5)); a copy of the records in the vehicle (2E(8)).
The company’s obligations
- Equip every driver with padlocks or numbered seals, a TIR cord and spare checklists.
- Give drivers written instructions in their language and train them. CPAS accreditation requires training with a knowledge check and an annual refresher.
- Collect the checklists and review them within 30 days of the end of the journey; under CPAS they are kept for 6 months.
- E-checklists are accepted under CPAS if they cover the same checks as the Home Office checklist.
The most common problem
In the cases we handle, Border Force most often refuses a reduction because a check was not recorded, not because the vehicle was not secured. Do not complete the checklist after the event, as this undermines its credibility.
More in the knowledge base: CPAS accreditation step by step: requirements and changes from 1 January 2026, What can you get a Border Force penalty for? and How to defend yourself and reduce a Border Force penalty?.
Free consultation
With our fleet subscription, drivers complete checklists on their phone and the company sees them in its dashboard. We also help align company procedures with the 2002 Regulations. The first consultation is free.
