Call for evidence outcome

Call for evidence: An Independent Customs Regime – summary of responses

Updated 25 July 2022

1. Introduction

The 2025 UK Border Strategy sets out the government’s vision for the UK border to be the most effective in the world. A border which simplifies processes for traders, improves the security and biosecurity of the UK and embraces innovation. Central to this vision is an independent UK customs regime that is business-friendly and responsive to the needs of the wider border industry, in this way reinforcing the UK’s status as a leading hub for international trade in goods.

The government announced in April that no further import controls on EU goods would be introduced this year and committed to publishing a Target Operating Model (TOM) in due course. The TOM will set out a new global border approach for Sanitary and Phytosanitary (SPS) and safety and security controls, to be introduced at the end of 2023. This new approach will apply equally to goods from the EU and goods from the rest of the world and will be based on a proper assessment of risk, with a proportionate, risk-based and technologically advanced approach to controls.

The most advanced borders in the world increasingly rely on the use of technology and data to assure movements across the border. The government has already committed to delivering a number of transformational programmes including the Single Trade Window (STW), which will start to deliver from 2023, and exploring the creation of an Ecosystem of Trust (EoT) between government and industry which will harness cutting-edge technologies to improve the trader experience and reduce burdens. Currently, the government is working with industry to set up a number of pilots to test new capabilities across supply chain security and technology.

In parallel to these transformational cross-government programmes, HM Treasury (HMT) and HM Revenue and Customs (HMRC) are committed to making improvements to existing customs processes and facilitations to ensure it is as easy as possible for traders of all sizes to navigate the customs system, whilst preventing non-compliance and upholding the UK’s high fiscal, regulatory and security standards at the border.

The first step in this process is to review three fundamental building blocks of the customs system. Following discussions with stakeholders, HMT and HMRC chose to focus in the first instance on these areas as they are integral to the trader experience when interacting with the UK’s customs regime. The three building blocks are:

• the customs intermediary sector
• the Simplified Customs Declaration Process (SCDP)
• the Transit facilitation

HMT and HMRC published a Call for Evidence (CfE) in February 2022 that sought views from businesses and the wider border industry on these three building blocks. HMT and HMRC would like to thank stakeholders for their detailed consideration of the issues that were explored in the publication. We are grateful for the thorough written responses that stakeholders provided to us as well as the views that stakeholders shared in engagement meetings. This summary of responses plays back some of the key insights and suggestions that stakeholders provided in relation to each of the three building blocks.

The government recognises that there are more opportunities to simplify and improve the UK’s customs system beyond the three areas covered in this CfE and is committed to engaging with stakeholders to feed into future policy development, including by making full use of the insight respondents have provided on these issues and others through this CfE.

Overview of responses

The consultation period ran from 7 February 2022 to 2 May 2022, and during this time HMT and HMRC heard from 85 respondents via 51 meetings and 53 written representations.

As part of the CfE, respondents were asked introductory questions to help us understand more about the nature of their business or organisation and the main interactions they have with the UK’s customs regime.

The written responses received covered a wide range of perspectives from across the border industry, including trade associations representing the views of thousands of small and medium-sized traders. Responses were split relatively evenly between intermediaries who complete declarations on behalf of traders large and small, businesses with differing levels of experience trading goods internationally, and from trade associations representing members in key import and export-focused sectors.

Most intermediaries that responded to the CfE operated across the UK, with their primary operations based in England, although often accompanied by offices in other parts of the UK. Some intermediaries also mentioned having a European presence including the Netherlands, France, Spain, Germany and Greece. Fast parcel operators, customs agents or brokers and freight forwarders were the most common service descriptors.

While the majority of responding intermediaries were either medium-sized businesses employing between 50 to 249 people, or large businesses with 250 or more employees, the ratio of dedicated customs agents to total annual facilitated movements varied across all intermediary sizes. Most intermediaries that responded were established prior to EU Exit and had between 5 and 50 years of experience operating in the industry. Of the minority with fewer than 5 years of experience, most were expansions of existing businesses into the customs intermediary sector to take advantage of new opportunities following EU Exit, rather than the establishment of entirely new businesses.

The traders that responded directly to the CfE were spread across various industries, including food retail, consumer goods, alcohol production and chemical manufacturing. The majority were based in England, with operating sites and offices across the UK.

Most traders that responded directly were classified as large businesses, employing over 250 people. Of this group, the majority made over 10,000 movements per year and had at least 20 years’ experience trading internationally. Over half of businesses that responded were very long established with at least 100 years’ experience of importing or exporting goods.

We also received a number of responses from trade associations representing small and medium-sized traders in a variety of industries including the automotive sector, the meat trade, aerospace and defence through to drinks and hospitality. Membership size varied significantly, typically ranging from 50 up to 1500 members. A small number of associations were significantly larger, ranging from 20,000 to over 160,000 members. Membership size was not always indicative of influence and market coverage, with some smaller bodies representing a significant percentage of their industry.

2. Summary of responses – Customs intermediaries

Responses to the CfE emphasised that intermediaries play a vital role in the customs process for many traders. Respondents reported using a customs intermediary for a wide range of services, including making their customs declarations for both imports and exports, arranging the transportation of goods, operating warehouses, and giving advice on customs. To get a rounded view of the market, we also invited intermediaries to respond to this CfE.

The intermediaries chapter sought views on three main themes: ease and cost of access, quality and the future of the sector. Broadly, stakeholders felt that there is sufficient capacity in the sector. In general, stakeholders reported that the cost of using an intermediary was proportionate to the services they provide. However, several referenced a wide variation in costs between different intermediaries.

Feedback was mixed on the quality of the sector. Most stakeholders said that they had generally received a satisfactory service from their intermediary, but there were some accounts of poor-quality services being provided. Intermediaries suggested that some of the quality and cost issues may be attributable to recent changes and uncertainty over rules; perceived poor HMRC systems, guidance, and support; and a lack of knowledge in the sector. To improve the quality of the sector, some stakeholders suggested introducing regulation in the form of licensing or standards, including on a voluntary basis.

Looking to the future of the sector, some stakeholders felt that automation would provide the greatest scope for innovation, but that there were currently some barriers to innovation.

Ease and cost of access

The majority of respondents reported that they currently face no significant issues accessing intermediary services. It was widely recognised that capacity in the sector has been improving since EU Exit, and although a few stakeholders thought that the sector would struggle to take on more work, most agreed there is sufficient capacity for GB-EU trade.

Most intermediaries that responded said they offered their services to all types of business, although some noted that they sometimes choose whether or not to take on a client depending on their commercial attractiveness. A minority of stakeholders reported it being difficult to choose and compare from a range of intermediaries. A number of reasons for this were cited, including lack of cost transparency, intermediaries often being appointed by suppliers, a feeling (particularly amongst small and medium-sized enterprises (SMEs) and for specialist movements) that there was limited information available on which to base appointing an intermediary, and a perception of a lack of choice in intermediaries after the end of the Transition Period.

Generally, stakeholders described using intermediaries for a wide range of services. A small number of respondents expressed their wish to be able to do some customs processes, such as import declarations, in-house. Most respondents stated that there was a large variety in price between different intermediaries, and many acknowledged that the cost is generally higher for infrequent traders using intermediaries. Roughly two-thirds of respondents said that the cost of using an intermediary is proportionate to the services offered. A minority of stakeholders said that the cost of services is not always transparent.

Intermediaries reported a wide range of key factors that drive their pricing including market competition, the volume of declarations per client, the cost of software, staff training and wages, the complexity of and time needed to complete declarations, and relatedly, the quality of data provided.

Quality

Overall, feedback on the quality of services provided by different types of intermediary was mixed. The majority of respondents reported receiving a satisfactory service overall, even if most had also seen or experienced a poor service to some extent or at some point. The accounts of poor quality were not restricted to a particular type of intermediary, although some stakeholders said that the service received from customs agents was good or better than other types of intermediaries.

Of the stakeholders that reported that their intermediary had submitted incorrect or incomplete declarations on their behalf, in most instances this did not have a detrimental impact on the movement taking place. Some respondents made reference to their experience of intermediaries tending to complete a declaration quickly rather than accurately. Some respondents mentioned that intermediary errors resulted in them paying an incorrect amount of duty or VAT.

Of the respondents that stated they had seen or experienced poor quality in the sector, there were several possible explanations cited. Some felt that recent changes to customs rules meant the sector hadn’t managed to stay up to date and train staff accordingly. Some felt that there were inefficiencies in government systems and processes which were barriers to intermediaries providing a better-quality service, for example the transition to the Customs Declaration Service (CDS), and in particular the stakeholder resource required to support it. Some stakeholders said that the government should offer intermediaries further financial support for training. A minority of respondents reported that there were no barriers to providing a better-quality service, and that the sector would naturally improve over time.

The future of the customs intermediary sector

Stakeholders reported that automation, for instance of processes such as data collection, would provide the most significant scope for innovation in the sector, but they also identified a range of barriers to innovation. The most frequently mentioned was the perception of some stakeholders that government systems are complicated, and it is difficult to access relevant customs information. Some respondents also felt that customs infrastructure and technology is often outdated, and a number felt that the uncertainty and instability around customs processes had resulted in a lack of knowledge in the sector. There was also concern over whether intermediaries would be able to train staff in time for the transition to CDS.

There were a range of suggestions from stakeholders on how to aid innovation in the intermediary sector. These included the improvement or simplification of government customs systems and infrastructure and addressing non-compliant intermediaries. A small minority of respondents mentioned that they would benefit from an option to submit import declarations themselves. Some stakeholders suggested introducing regulation in the sector in the form of licensing or standards, including on a voluntary basis, to improve the education and quality of the sector. Examples were drawn from various countries that regulate their intermediary market in these ways, including the USA, the Netherlands, Singapore, Greece, Spain, Australia and Canada. On the other hand, some respondents believed that the sector would develop on its own without any form of government intervention.

3. Summary of responses – Simplified Customs Declarations Process (SCDP)

The SCDP is a two-stage electronic declaration process which moves fiscal and statistical controls inland. Traders provide less data than a full customs declaration at the frontier and then a supplementary declaration later. This gives flexibility to traders and supports the flow of trade at the border. The CfE had two broad aims: to determine the level of awareness and use of SCDP amongst traders; and identify areas of improvement to the process.

Respondents were asked a series of questions which moved through the SCDP process in chronological order. Overall, feedback regarding SCDP was positive. Awareness of SCDP was, however, slightly higher amongst larger traders, with larger traders and intermediaries particularly praising the benefits of SCDP with regard to clearing high volumes of goods at the border.

There were a number of suggestions for improvement, including simplifying the authorisation process, improving the C21 form, and extending the deadline to submit supplementary declarations for imports beyond the fourth working day.

The final section of the CfE looked at SCDP’s interaction with other customs processes. Interest in self-assessment and aggregation was varied, with SMEs least interested in either due to the extra administration and software required. Stakeholder responses will be considered alongside the results of HMT’s and HMRC’s recent Customs Duty and Import VAT Self-Assessment and Aggregation (SAA) pilot.

Awareness of SCDP and its benefits

Overall, respondents showed a good awareness of SCDP. There were, however, clear differences in awareness between large traders and SMEs, with SCDP not routinely being known or used by smaller traders. From responses, it was clear that this is linked to smaller traders being more likely to use intermediaries to complete their customs declarations and finding the authorisations process more difficult to complete. Larger traders, that moved a higher volume of goods on a regular basis, found more benefit to using SCDP.

Respondents noted several benefits in using SCDP and found it a helpful process that eases the burden of trade and customs requirements. The main benefits highlighted were the reduced data set required for SCDP at the frontier, and the perceived faster release of goods at the frontier. These benefits give traders the ability to manage their workload in order to complete more timely and accurate supplementary declarations at a later date. In particular, larger traders and intermediaries noted that this was invaluable for their businesses and allowed them to move a high volume of goods efficiently and with more certainty. Moreover, intermediaries said this brings huge benefits in terms of processing declarations quickly for their clients.

Allowing supplementary declarations to be completed at a later date also allows some traders to manage their staffing levels more efficiently, as staff can complete supplementary declarations within normal working hours rather than in real time alongside the arrival of goods. Respondents told us that this increased time to gather information for the supplementary declaration also allows for more accurate completion and compliance.

Applying to use SCDP

Respondents suggested the SCDP authorisation process was too complex, citing the system as confusing and requiring a high administrative burden. The application form was reported as being too long, with a poor user interface.

Respondents suggested a range of improvements to the authorisation process, with the majority of respondents requesting better, and more, guidance on how to complete the authorisation process. A large number of respondents requested an online user portal be created, suggesting this contain a guided step-by-step walkthrough of the application process with detailed examples.

Stakeholders offered ideas on how to simplify the application process. These included automating the process by pre-filling data fields with information already held by HMRC and enabling traders to become authorised for all individual simplified procedures on the basis of one ‘master authorisation’. Some respondents asked if Authorised Economic Operator (AEO) status could be used as the starting point for further facilitations.

Other suggestions for improvements to the authorisation requirements included removing the need to provide and update a list of commodity codes against which the facilitation is being used, allowing one duty deferment account for multiple authorisations, and linking SCDP to other authorisation processes.

At the border: Using the Simplified Declarations Procedure (SDP) or Entry in Declarant’s Records (EIDR)

We asked a series of questions around the frontier process, focusing on the differences between using the SDP and EIDR. The Simplified Declarations Procedure is used for releasing goods at the frontier to most customs procedures, including free circulation and special procedures, by submitting a reduced data set. In comparison, whilst EIDR is also used for releasing goods at the frontier, it also allows traders to retain data in the declarant’s own records rather than sending it to HMRC. The CfE posed questions to better understand whether traders had specific concerns with either process or preferences between them.

There were a mix of preferences between the Simplified Declarations Procedure and EIDR, with more preference shown for the Simplified Declarations Procedure. Respondents that preferred the Simplified Declarations Procedure provided reasons and related suggestions for how to improve EIDR. It was noted that C21 forms are viewed as resource-intensive and time-consuming when required to clear goods at certain ports when using EIDR, and that the data required for a C21 is similar to that on a Simplified Frontier Declaration, resulting in little additional benefit from using EIDR over the Simplified Declarations Procedure. Some traders said this put them off using EIDR.

Other traders did prefer EIDR, despite noting the administrative burden, because it allows for more information to be kept in traders’ records rather than being submitted. Some noted, however, that they still have to use the Simplified Declarations Procedure for SPS and controlled goods, and would find it beneficial if EIDR could be extended to SPS goods as well.

After the border: supplementary declarations

Supplementary declarations must be accepted and finalised by the end of the monthly reporting period in which the goods cross the border. For most traders, this means supplementary declarations must be submitted by the end of the fourth working day of the month following the date of import.

Most respondents did not wait until the fourth working day of the month following import to submit their supplementary declarations, instead opting to submit regularly throughout the month. This was to reduce the risk of non-compliance. Respondents with a high volume of imports did, however, note that some declarations are completed on the last day. Often these are for imports that have been made towards the end of the month.

The majority of traders did think that it would be beneficial to extend the deadline for submitting supplementary declarations, with respondents suggesting the deadline be extended to between the seventh and fifteenth day of the following month. It was highlighted that meeting the deadline was particularly challenging for imports that took place towards the end of a month due to the short turnaround time, and that extending the deadline would give traders more time to ensure their declarations were accurate and would ensure workload could be evenly spread.

Smaller traders were less likely to express an interest in extending the deadline. These respondents did, however, acknowledge that this was mainly because they have a lower volume of goods to process. Some respondents expressed concern that delaying declarations would just defer the burden to a later date.

Respondents who use an intermediary did not report any confusion over who is responsible for completing the supplementary declaration.

Other considerations: Customs Duty and Import VAT Self-assessment and Aggregation (SAA) pilot

We asked respondents for their views on aggregation of supplementary declarations, where traders can reduce the number of declarations submitted to HMRC by aggregating multiple consignments of goods into a single supplementary declaration. A small proportion of respondents currently use aggregation and noted that it would be beneficial to simplify it further if, for example, fewer fields were required or if aggregation could take place over a monthly period.

Alongside the CfE, HMT and HMRC also ran a pilot which tested the use of customs duty and import VAT self-assessment and aggregation with three trusted traders. This found that aggregation rules were viewed as overly complex, or unsuitable for the business model and importing habits of the large traders that participated in the pilot. Overall, participants found self-assessment and aggregation did not provide any savings in terms of reduced time or costs compared to SCDP that they had already optimised.

In the CfE, we also asked respondents for their views on self-assessment, where the trader takes responsibility for assessing their customs duty and import VAT and provides less information to HMRC as a result. Of the small proportion of respondents that did show an initial interest, flexibility was seen as a main benefit. Of those who use intermediaries, respondents noted that self-assessment may remove the need to use them and that this may result in an increase in the liability of the trader for compliance and accuracy. Some traders also shared concerns around the complexity of calculating customs duty themselves and that there could be costs associated with implementing the systems required for this.

Other considerations: Customs Warehouses, Export, Duty Management Software

The final section of the SCDP chapter asked respondents whether they used SCDP to declare goods into or out of a customs warehouse, if they used SCDP for export, and whether they used duty management software to support their use of SCDP.

Respondents noted that it is a complex and difficult process to turn warehouses into customs warehouses, with this acting as a deterrent to using customs warehouses. However, of the minority of respondents who do use customs warehouses, SCDP was viewed as beneficial because it removed the need to report to customs authorities every time goods were removed from the warehouses.

The majority of respondents did not use SCDP for exports, citing that this was because the export declaration requirements are simpler than import declarations. Suggestions were made, however, regarding the export process more generally.

Use of duty management software was mixed. Those who did use duty management software reported that the benefits included better control of inventory and records, increased accuracy of reporting and automation of processes.

Some respondents thought improvements could be made to duty management software. Traders would welcome HMRC allowing post-entry amendments to declarations, with respondents noting that this is not currently an option. Smaller traders responded that software is necessary for SCDP, and expressed concern that the cost of such software makes it inaccessible to SMEs.

4. Summary of responses – Transit

Current users value Transit for speeding up the border clearance process and suspending duty, VAT, and excise payments until the final point of destination. The majority of these users are large businesses who operate just-in-time supply chain models such as fast parcel operators, logistics specialists and automotive manufacturers. When SMEs use Transit, they are more likely to do so via an intermediary.

Respondents indicated opportunities for improvement, including:

• Transit guidance could be clearer and easier to navigate and HMRC communications could be clearer on the benefits of using Transit. Guarantee requirements specified by the Common Transit Convention (CTC) are a barrier to using Transit. To mitigate this, awareness of guarantee waivers could be improved
• the application process could be improved by being online. It is currently paper-based and duplicative in places
• traders who have authorised consignor and consignee status could be given additional benefits such as being able to start and end Transit movements at any approved location
• users would welcome the ability to track Transit movements in real time and reduced ‘dwell time’ before goods can be unloaded to end the Transit movement

The costs and benefits of using Transit

Respondents told us that the main benefit of using Transit was that it removed friction at the border as a result of it being a duty suspension regime. This had additional benefits of increasing the speed of delivery times and reducing overheads on storage facilities.

Several respondents reported on the benefits of the Authorised Consignee authorisation, saying that it allowed goods to be cleared at the trader’s premises rather than at a government office at the port. Other respondents reported benefits of Transit as a duty suspension regime for exports, saying that it allowed goods to move across multiple Customs territories (e.g. EU, EFTA and CTC countries) without having to pay duties and VAT until the final destination.

Almost all respondents reported that the requirement for a Customs Comprehensive Guarantee (CCG) was the largest cost they encountered and the biggest barrier to using Transit. Legal risks and the likelihood of defaulting on a guarantee were poorly understood, and respondents had limited awareness of guarantee waivers. Several respondents reported IT costs as an issue, including software licenses and staff training in New Computerised Transit System (NCTS) use. The cost of using intermediaries to operate Transit on their behalf was also mentioned as an issue.

Feedback was also provided on administrative costs. These ranged from the costs of reviewing Transit requirements to the cost of security seals for vehicles and maintaining the standards required for authorised consignor and consignee status.

Help and advice on Transit

The most commonly reported issue on which respondents sought advice and guidance was the application process for authorised consignor and/or consignee status, and the process to obtain a CCG.


Respondents reported twenty-seven different sources of advice and guidance for Transit. The highest proportion of respondents reported using Transit guidance on GOV.UK. This was followed by the Transit Manual Supplement and the NCTS Helpdesk. A small number of respondents reported using the European Commission’s Transit Manual and HMRC’s large business tax specialists as their main sources of information.

Many respondents stated that the Transit guidance and communications should cater for different groups of Transit users and have clearer signposting of where to get help. Depending on the knowledge and experience of the user, some respondents wanted to see the guidance simplified and include more examples and scenarios, while other users wanted more detailed information in the Transit Manual Supplement.

In response to feedback on improving guidance and information and reducing the cost of a CCG, HMRC has formed a ‘Task and Finish’ Group with members of the Joint Customs Consultative Committee (JCCC), who will help us review the guidance on GOV.UK and co-design other guidance products to ensure information is conveyed in the best possible way to businesses.

Sector-specific feedback (for intermediaries, hauliers, and fast parcel operators)

The respondents who completed this section were predominantly trade bodies and hauliers.

50% of respondents used Transit for exporting to the EU. A number of these respondents indicated that they mainly used Transit for road movements.

Less than 50% of respondents offered the service of completing Transit documents for other businesses. A small number of respondents offered moving goods for third parties using their authorised consignor and consignee status. These respondents also offered the additional service of sharing their Customs Comprehensive Guarantee in spite of concerns on the risks involved should the Transit movement be closed incorrectly.

A third of respondents used Transit to move groupage loads. Of the respondents who didn’t use Transit for groupage loads were a number of global logistics companies. This suggests there is no direct correlation between Transit and groupage movements.

The future of Transit

Several authorised consignees suggested improvements and simplifications to the process of closing Transit movements by clarifying how to close movements and making it easier for traders to do so. Feedback also provided a number of other suggestions, including making Transit paperless, improving NCTS to enable the tracking of movements in real time, and the ability to check whether movements had been closed.

Some respondents also commented on the difficulty of providing additional data requirements that will be needed once phase 5 of NCTS is delivered in November 2023.

In respect of these additional data requirements, now this has been agreed by all contracting parties we do not propose to take any further action on this point. However, Transit officials will continue to monitor the issue. The next phase of NCTS will not include the functionality to track a Transit movement, but this will be considered for inclusion in future deliveries. In the meantime, HMRC will look at how we can ensure users are aware of the ability to do this using the European Commission’s EUROPA webserver, which enables Transit movements to be tracked by entering a movement reference number.

Many respondents suggested a simpler and easier Transit authorisation application process that removes the need to provide duplicate information repeatedly for new or amended authorisations. A small number of respondents reported that they did not apply to use the simplification because the current paper-based process seemed too difficult to complete.

Other feedback from respondents included providing an expedited and easier process for trusted traders who already hold other authorisations and allowing all UK Border Force interventions to take place at traders’ approved premises as opposed to Inland Border Facilities (IBFs), which they said could reduce the pressure on IBFs and make the process more efficient.

5. Summary of responses – further suggestions

While the CfE focused on the three above policy areas, we are grateful for the valuable insight stakeholders volunteered on their experiences with other aspects of the customs system. Feedback was wide-ranging and included reflections on the approach the government could take on the design and delivery of the Single Trade Window (STW) and views on potential improvements to existing customs facilitations outside of those covered in the CfE.

Many respondents noted the importance of joined-up interaction between government border agencies and the need to provide one entry point for all customs data through a single portal, signalling their support for the work underway to facilitate this under the STW programme. Stakeholders provided helpful suggestions, including comments on the submission of data, and demonstrated interest in feeding into the design of the STW. A further consultation on STW was published recently, and the government will engage regularly with users throughout the development of the STW.

Some traders noted that the current process to become authorised to use certain customs facilitations can sometimes feel burdensome and duplicative. Relatedly, a significant number of responses suggested improvements that government could make to the current Authorised Economic Operator (AEO) offering. Any changes to the AEO offering would need to be in line with the international AEO standards set by the World Customs Organisation. There was broad support for the government’s exploration of widening and developing the government’s current offer for the most trusted and compliant traders as part of the EoT programme.

Stakeholders also proposed numerous suggestions on other customs systems and processes, ranging from technical feedback on the use of Economic Operators Registration and Identification (EORI) numbers to more high-level feedback such as reflections on the delivery plan for CDS migration.

HMT and HMRC would like to thank all those who volunteered this useful and wide-ranging feedback as part of the CfE. The insight gathered will contribute to ongoing policy development as part of the government’s ambition to have the most effective customs regime and best border in the world by 2025.

6. Next steps

HMT and HMRC are grateful for the rich insight that stakeholders provided in their responses to the CfE. Officials will use this to inform policy development over the coming months. On a practical level, we will take steps to implement process and operational enhancements that respond directly to suggestions that stakeholders put forward. On a strategic level, the feedback received will be considered as part of the policy making process, including as the government sets out further details of our plans for a new global border regime in the autumn.

Annex: List of respondents

There were 85 Respondents in total:

• 1st Penguin Shipping Ltd
• ABInBev (Anheuser-Busch InBev)
• ADS Group Ltd
• AEB
• ALDI Stores Ltd
• Americold UK
• Asda Stores Ltd
• Association of International and Courier Express Services (AICES)
• BAE Systems plc
• BASF (Badische Anilin und SodaFabrik) plc
• Bestfoods
• Berwyn Consultants
• BMW Group
• Bounty Freight Ltd
• Britannia Bureau Ltd
• British Beer and Pub Association (BBPA)
• British International Freight Association (BIFA)
• British Ports Association (BPA)
• British Universities Finance Directors’ Group (BUFDG)
• Cambium Advisory Ltd
• Casper Shipping Ltd
• Caterpillar Inc
• CCS-UK User Group Ltd (BT Group plc, DB Schenker Ltd, DHL Global Forwarding (UK) Ltd, The Association of Freight Software Suppliers [AFFSS], Agency Sector Management (UK) Ltd [ASM], Heathrow Airport, Border Force)
• Chartered Accountants Ireland
• Chartered Institute of Taxation (CIOT)
• ClearBorder
• CNS (Community Network Services) Ltd
• Customs Practitioners Group (CPG)
• Dains Accountants Ltd
• Declaron/BDO
• Descartes – Pentant Ltd
• Deloitte UK (Deloitte LLP)
• DHL International (UK) Ltd
• Diageo plc
• EORI UK Ltd (Customs Clearance Consortium)
• Etsy Inc
• Europa Worldwide Group
• Every Vehicle Lease Ltd
• Federation of Small Businesses (FSB)
• FedEx Express UK Transportation Ltd
• Food and Drink Federation (FDF)
• Ford UK
• Fresh Produce Consortium (FPC)
• Gaston Schul Customs Ltd
• Geodis United Kingdom Ltd
• GlaxoSmithKline plc (GSK)
• Haleon plc
• Haltermann Carless UK Ltd
• Hellmann Worldwide Logistics Ltd
• Indalo Transport Ltd
• Institute of Directors (IoD)
• Institute of Export and International Trade (IOE&IT)
• International Meat Trade Association (IMTA)
• KPMG International Ltd
• Livingston International Europe Ltd
• London Chamber of Commerce and Industry (LCCI)
• Marks and Spencer (M&S) Group plc
• MCP (Maritime Cargo Processing) plc
• Metro Shipping Ltd
• Momart Ltd
• Morgiel Fine & Organic Foods Ltd
• Morley Consulting Training Ltd obo Chartered Institute of Logistics and Transport (CILT)
• MPM Products Ltd
• Müller UK and Ireland
• North and Western Lancashire Chamber of Commerce
• Octain Ltd
• Private citizen
• PHC Europe B.V.
• Procter and Gamble
• PricewaterhouseCoopers (PwC UK)
• Rail Delivery Group (RDG)
• Royal Mail Group
• Sainsbury’s plc/Argos Ltd
• SC Johnson EurAFNE Ltd
• Siemens Healthcare
• Society of Independent International Trade and Customs Experts (SIITACE)
• Society of Motor Manufacturers and Traders (SMMT) Ltd
• Society of Motor Manufacturers and Traders (SMMT) Customs and Tariff Working Group
• STEF Group
• TechnipFMC plc
• Tesco plc
• UK Chamber of Shipping
• UK Customs Solutions Ltd
• UK Warehousing Association (UKWA)
• UPS
• Unilever plc

HMT and HMRC would also like to thank those stakeholders who elected to provide their feedback anonymously.