Transport & Logistics UK-wide

Freight forwarding and customs: representation, warehousing and dangerous goods

If you forward freight, clear goods through customs on behalf of others, or run a bonded warehouse, you may act as a customs representative, hold customs warehousing authorisation from HMRC, and — if you move dangerous goods — appoint a dangerous goods safety adviser. This guide covers the customs and dangerous-goods regimes specific to freight forwarding, on top of the universal warehouse duties in the spine guide.

Guide summary

If you move goods for other businesses, you must check if you are a customs representative, need a customs warehouse authorisation, or must appoint a dangerous goods safety adviser. Choose direct or indirect representation in writing. Get HMRC authorisation before storing goods under duty suspension. Appoint a qualified DGSA if you carry dangerous goods above set limits.

  • Agree representation type in writing with your client before submitting declarations
  • Use direct representation (code 2) – client solely liable for customs debt
  • Use indirect representation (code 3) – you and client share liability
  • Indirect representation is mandatory when client is not UK-established
  • Get HMRC written authorisation before entering goods to customs warehousing
  • Keep stock records that match every entry, removal and customs declaration
  • Duty and VAT are suspended while goods stay in the warehouse – no time limit
  • Appoint a qualified DGSA if you carry dangerous goods above threshold quantities
  • DGSA must prepare an annual report for your business each year
  • Criminal prosecution and unlimited fine for not appointing a DGSA when required
On this page

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This guide is for businesses that move goods on behalf of others — freight forwarders, customs agents and bonded warehouse operators. You may handle customs declarations, hold goods under duty suspension, and carry dangerous goods. The universal warehouse duties (health and safety, fire, lifting, DSEAR and the rest) are in Set up and run a safe warehousing and storage operation — start there, then work through the regimes below.

A. Acting as a customs representative

If you make customs declarations for other businesses you act as a customs representative. You can act under direct representation (in the importer's or exporter's name) or indirect representation (in your own name, taking joint liability for the customs debt). The basis you choose affects your liability, so agree it in writing with your client.

B. Customs warehousing authorisation

To store non-UK goods under duty and import VAT suspension you need customs warehousing authorisation from HMRC. You must keep stock records, meet the conditions of your authorisation, and account for goods when they are removed to free circulation or re-exported.

C. Dangerous goods safety adviser (DGSA)

If your business consigns or carries dangerous goods by road, rail or inland waterway above the threshold quantities, you must appoint a qualified dangerous goods safety adviser (DGSA) and prepare an annual report, kept available to the authorities on request. The duty arises under the carriage-of-dangerous-goods regime (ADR/RID). The dangerous-substance storage duties under DSEAR are in the spine guide.

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    What to do next

    Confirm the universal warehouse duties in the spine guide are in place, then complete the warehousing and transport support compliance checklist for the freight forwarding and customs items.

Official sources

Authoritative guidance for freight forwarders and customs agents.