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Independent customs regime: UK government publishes consultation response summary


Published: 09 Aug 2022 Update History

The government will use the responses to this call for evidence to inform the policy-making process. It intends to set out further details of its plans for a global border regime in the autumn.

The 2025 UK Border Strategy sets out the government’s vision for a UK border that:

  • simplifies processes for traders;
  • improves the security of the UK; and
  • embraces innovation. 

To achieve this, the government aims to develop an independent UK customs regime that is business-friendly and responsive to the needs of the wider border industry.

In February 2022, HMT and HMRC published a call for evidence that sought views from the border industry on the areas deemed integral to the trader experience when interacting with the UK’s customs regime:

  • the customs intermediary sector;
  • the simplified customs declaration process (SCDP); and
  • the transit facilitation.
The responses provided to the call for evidence, summarised below, will be used to inform policy development over the coming months. This will include implementing operational improvements that respond directly to suggestions made by stakeholders.
On a more strategic level, the feedback will influence the government’s plans for a new global border regime. The government intends to set out further details on the global border regime in the autumn.

Customs intermediaries

Intermediaries play a vital role in the customs process for many traders and are used for a wide range of services, including:

  • making customs declarations for imports and exports;
  • arranging the transport of goods;
  • operating warehouses; and
  • providing advice on customs.
It is worth noting that intermediaries were invited to respond to the call for evidence. 
The majority of respondents reported that they face no significant issues accessing intermediary services. Capacity has improved since the UK left the EU.
However, feedback on the quality of services provided by intermediaries was mixed. Although most respondents thought the service received from intermediaries was satisfactory overall, most respondents had also experienced poor service to some extent. This feedback was not restricted to a particular type of intermediary.
There was some significant overlap between suggested reasons for poor quality service in the sector and barriers to innovation in the sector. This included complicated and inefficient government systems. Significant and frequent change to customs rules and processes in recent years was also mentioned.
It is hoped that the move to the customs declaration service (CDS) will improve some of these issues. However, there was concern that intermediaries may not be able to train staff in time for the transition later this year.

Simplified customs declarations process

The SCDP is a two-stage electronic declaration process that moves fiscal and statistical controls inland. Traders provide less data at the border and then file a supplementary declaration later.

Awareness of the SCDP was found to be much lower with SMEs than with larger traders. SCDP does not appear to be used routinely by smaller traders. It seems this is because smaller traders are more likely to use intermediaries and found the authorisation process too difficult.

Those businesses that use SCDP provided positive feedback overall, with several benefits noted. Allowing supplementary declarations to be made at a later date allows traders to manage their workload and complete more accurate declarations.

However, respondents suggested that the SCDP authorisation process is too complex. The application form is too long and has a poor user interface. An online user portal was suggested to improve this.


Traders value transit for speeding up the border clearance process and suspending VAT and duty payments until the final point of destination.

However, some improvements to transit were suggested, including:

  • clearer guidance that is easier to navigate;
  • improving the application process through the introduction of an online system;
  • providing additional benefits to traders with authorised consignor and consignee status; and
  • the ability to track transit movements in real time.

Further suggestions

The call for evidence also allowed respondents to comment on other aspects of the customs system. Some of the most frequent comments included:

  • the importance of joined-up interaction between government border agencies, including the need to provide one entry point for all customs data through a single portal;
  • the current authorisation process to use certain customs facilitations is considered burdensome and duplicative; and
  • reflections on the delivery plan for CDS migration.

The first of these points will be considered in more detail in the consultation on The UK Single Trade Window announced on 21 July 2022.

Read the full summary of responses to the call for evidence here.

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