Choose and work with a customs agent

Since the Customs Declaration Service (CDS) replaced CHIEF in 2022, businesses cannot make customs declarations directly to HMRC without specialised software. Most importers and exporters use a customs agent or freight forwarder to handle declarations on their behalf.

Using an agent does not transfer your legal responsibilities. You remain liable for the accuracy of information on declarations and for any customs debt arising from errors.

When you might not need an agent

You can make declarations yourself if you have:

• A Government Gateway account
• An EORI number starting GB or XI
• A CDS subscription
• CDS-compatible customs software
• Sufficient knowledge of customs procedures and tariff classification

Self-declaration suits businesses with straightforward, high-volume trade in a limited range of products where investing in software and expertise is cost-effective.

Types of customs intermediary

There are four main types of customs intermediary, each suited to different business needs:

Choosing the right type

Freight forwarder: Best if you want end-to-end logistics handled by one provider. They arrange transport, insurance, and customs clearance as a complete service.

Customs broker: Best if you already have logistics arrangements but need customs expertise. Brokers specialise in declarations and compliance.

Express operator: Best for occasional small shipments where convenience matters more than cost. Built-in customs clearance means less administration for you.

Specialist agent: Essential if you trade in regulated goods like perishables, pharmaceuticals, dangerous goods, or controlled substances. Generic agents may not have the specialist knowledge required.

What to look for in an agent

When shortlisting agents, consider:

• CDS experience: The system is relatively new - ask how many declarations they have processed
• Your commodity types: Some goods require specialist knowledge (chemicals, food, textiles with complex origin rules)
• Geographic coverage: If you trade with specific countries, check they have experience with those markets
• Duty relief schemes: If you use inward processing, warehousing, or temporary imports, ensure they can handle these
• Communication: You need to provide accurate information quickly - check their systems work for you

AEO status

Authorised Economic Operator (AEO) certification indicates an agent meets HMRC's standards for customs compliance and security:

Finding agents

HMRC publishes registers of customs agents and express operators. These are downloadable spreadsheets listing businesses that have asked to be included. AEO-certified agents appear at the top of each register.

Important: HMRC does not vet, approve, or recommend any business on these lists. The information is provided by the agents themselves and is not verified.

You can also find agents through:

• British International Freight Association (BIFA) - trade association with over 1,600 member companies, sets industry standards
• Trade associations in your sector
• Recommendations from other importers/exporters

Understanding costs

Customs agent fees vary significantly. Get detailed quotes from several providers and compare total costs including all additional charges:

Factors affecting cost

Your actual costs depend on:

• Declaration complexity: Multiple commodity codes, special procedures, or licensing requirements increase work
• Volume: High-volume traders can negotiate discounts or monthly retainers
• Deferment arrangements: Using the agent's deferment account costs more than using your own
• Additional services: T1 transit, GVMS notifications, ENS declarations add to the base fee

Ask for a full breakdown of charges and clarify what triggers additional fees. The cheapest per-declaration fee may not be the lowest total cost if additional charges apply frequently.

Direct vs indirect representation

How your agent represents you determines who is liable for customs debt if something goes wrong. This is critical to understand:

Why this matters

Under direct representation (the standard arrangement), you are solely liable for any customs debt. If your agent makes an error using information you provided, HMRC will pursue you for underpaid duty.

Under indirect representation, both you and the agent are jointly liable. HMRC can pursue either party for the full amount.

Practical impact: Most UK customs agents only offer direct representation because they are unwilling to accept joint liability. If you are not established in the UK, you may struggle to find an agent because indirect representation would be mandatory.

Written authorisation

You must confirm in writing the terms and conditions of representation, specifying whether direct or indirect. Keep a copy - HMRC may request evidence of authorisation.

Without written authorisation, or if your agent makes decisions without written instructions, they may be treated as an indirect representative with joint liability implications.

Your ongoing responsibilities

Using an agent does not transfer your legal obligations. You remain responsible for:

• Accurate information: Providing correct details about goods, value, origin, and any licences
• Tariff classification: Ensuring the correct commodity codes are used (even if your agent suggests them)
• EORI number: The entity whose EORI appears on the declaration is the declarant and liable for customs debt
• Record keeping: Maintaining import and export records for at least 3 years

HMRC can assess back-duty for up to 3 years from the date customs debt was owed, extendable in some cases. Regular review of your declarations helps catch errors before HMRC does.

Setting up CDS authorisation

Before your agent can make declarations using your accounts, you must authorise them in the Customs Declaration Service:

Steps to authorise your agent

1. Sign in to CDS with the Government Gateway credentials used to subscribe
2. Click 'manage account authorities'
3. Select 'add agent'
4. Enter your agent's GB or XI EORI number
5. Select which accounts they can access (deferment, cash, guarantee)
6. Set the authorisation period (start and end dates)
7. Optionally allow the agent to view your account balance
8. Submit the authorisation

Alternative: using the agent's deferment account

If your agent uses their own Duty Deferment Account instead of yours, you do not need to set up CDS authorisation. The agent pays duties and VAT on your behalf, then invoices you. This typically incurs an administration fee (around 2% of the duty amount).

This approach is simpler if you do not have your own deferment account, but increases your per-declaration costs.

Information to provide your agent

For each shipment, your agent needs:

• Commercial invoice: Goods description, value, seller, buyer, terms of sale
• Tariff classification: Commodity codes (or ask your agent to classify, though you remain responsible)
• Country of origin: Where goods were manufactured, not just shipped from
• Licences and certificates: Import licences, phytosanitary certificates, origin certificates
• Authorisation details: If using special procedures (inward processing, warehousing)
• Representation type: Confirm whether direct or indirect

Establish a clear process for providing this information in good time. Delays in providing documentation can result in goods being held at the border or additional storage charges.