But my favourite line was when the HGV has incorrect paperwork "Enforcement would be against the driver, rather than the haulier or freight forwarder who has formal responsibility for completing the customs paperwork" -- that's nice.   I am responsible, but you get fined.
Seems reasonable to me. The responsibility for completing the paperwork may be with one person (the freight forwarder) but they cannot be present on every vehicle to ensure that all the paperwork is retained, unaltered, and that no additions/subtraction of cargo happen. Some responsibility must be with the driver. Otherwise the lorry driver who had 39 Vietnamese dead in his refrigerated lorry would not have been prosecuted.
The forwarder is responsible for completing the paperwork, but the driver is responsible for presenting it. I would imagine that the paperwork provided by the freight forwarder is done so electronically, and checked automatically at the time of completion. A paper copy would then accompany the shipment (driver).