Research and analysis

Research exploring changes to safety and security declaration requirements

Published 13 May 2025

Qualitative research with customs intermediaries and carriers in Great Britain exploring readiness for changes to safety and security declaration requirements

HM Revenue and Customs (HMRC) Research Report 791.

Research conducted by Ipsos between February and March 2024. Prepared by Ipsos (Amrita Sood, Shahil Parmar, Aamina Oughradar) for HMRC.

Disclaimer: The views in this report are the authors’ own and do not necessarily reflect those of HMRC.

1. Glossary and abbreviations

This report uses terminology and abbreviations that are explained below.

Application Programming Interface (API)

An application programming interface is a way for 2 or more computer programmes or components to communicate with each other. APIs are often used to share data such as supply chain information within and between organisations.

Border Target Operating Model

The Border Target Operating Model set out a new approach to security controls (applying to all imports), and sanitary and phytosanitary controls (applying to imports of live animals, animal products, plants, and plants products) at the border.

Carrier

For safety and security declarations, the carrier is defined as the ‘operator of the active means of transport’. This generally means the person carrying the goods at the time they are crossing the border, which could be the shipping company, a haulier, or an airline.

Customs agent or broker

Customs agents and brokers complete declarations on behalf of businesses importing or exporting goods. They help to ensure goods moving to and from the country are accurately declared for customs. They do not primarily deal with the physical movement of goods.

Customs declaration

A mandatory form listing the details of all goods being imported or exported to be submitted to the relevant government agency (namely HM Revenue and Customs (HMRC)).

Customs Declaration Service

The Customs Declaration Service supports making import and export declarations when moving goods into and out of the UK.

Customs Handling of Import and Export Freight (CHIEF) system

The Customs Handling of Import and Export Freight (CHIEF) system records the movement of goods by land, air and sea. It allows importers, exporters, and freight forwarders to complete customs formalities electronically and automatically checks entry errors.

Customs intermediary or intermediaries

Someone that a trader or carrier hires to deal with customs on their behalf. Options for intermediaries include freight forwarders, customs agents, brokers, or fast parcel operators.

Customs requirements

Customs requirements refer to handling declarations that need to be submitted when moving goods. These include import declarations, export declarations and safety and security declarations, amongst others.

Customs software

Customs software are IT systems used to allow an authorised user, for example Community System Providers, to submit declarations into HMRC.

Entry Summary Declaration

An Entry Summary Declaration contains safety and security information about goods being imported into Great Britain. It must be completed accurately and submitted by a specified time before goods arrive at the border.

European Union (EU)

The EU countries are Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden.

Export(ing)

Selling goods or services to a customer in a different country.

Freight forwarder

Freight forwarders, also known as shipping agents, facilitate the movement of goods between countries and handle all aspects of the movement, including shipping and customs. They cover the movement of goods via all different mediums: road, rail, air, and sea. They help traders to move goods directly (where they have their own fleet of vehicles) or indirectly (where they contract haulage operators or shipping lines to move goods).

Goods

Tangible products such as books, clothes and tools.

Goods Movement Reference

A Goods Movement Reference is a unique identification number which is generated by the Goods Vehicle Movement Service. The Goods Movement Reference links together all the customs declarations for a particular shipment.

Goods Vehicle Movement Service (GVMS)

The Goods Vehicle Movement Service (GVMS) is an IT platform managed by government to facilitate border movements at certain port locations. If a business moves goods through these ports, it must register with the service.

Hauliers

Hauliers deal mainly with the physical transportation of goods.

Import(ing)

Purchasing goods or services from sellers in a different country.

Medium business

Firms with 50 to 249 employees.

Micro business

Firms with 0 to 9 employees.

Niche business

Niche businesses refers to intermediaries and carriers that specialise in facilitating the movement of very specific types of goods.

Private consultants

Private consultants refer to other intermediaries that are employed to support, advise or where work is outsourced.

Reduced dataset

Alongside the introduction of safety and security requirements for EU imports, HMRC are also introducing a reduced dataset for Entry Summary Declarations, which will be available for both EU and rest of the world imports. This change will be implemented so that those already set up to make Entry Summary Declarations do not need to make any changes to existing systems or procedures if they do not want to.

Rest of the world

Countries outside the UK and EU.

Safety and security declaration

Safety and security declarations are a customs process required by border authorities since 2011 to analyse the potential risk caused to their territory by goods crossing their border.

Single Trade Window

A Single Trade Window is a single gateway between businesses and border processes and systems that allows users to meet their import, export, and transit obligations by submitting information once, and in one place.

Small business

Firms with 10 to 49 employees.

Trader

Businesses who import goods or services to the UK and or export to other countries. This research focussed purely on goods, as customs declarations are not required for services.

2. Executive summary

2.1 Introduction

The Border Target Operating Model set out the new safety and security declaration model for imports into Great Britain. It included the new requirements on imports from the EU as well as the reduced data requirements for all safety and security declarations. The changes were due to come to effect on 31 October 2024, though the implementation date was later extended to 31 January 2025.

HM Revenue and Customs (HMRC) commissioned Ipsos to conduct qualitative research with intermediaries and carriers based in Great Britain. The aim was to explore their understanding and preparedness for the introduction of the new safety and security declaration requirements.

This research took place before the implementation date was extended to 31 January 2025 and therefore covers intermediaries’ and carriers’ preparedness for the 31 October 2024 implementation. Findings from this research, alongside extensive stakeholder engagement, informed the government’s decision to extend the time before implementation, to better prepare businesses for the changes.

2.2 Methodology

Forty qualitative depth interviews were conducted with intermediaries and carriers in February and March 2024. Those interviewed included employees from a range of businesses involved in the movement of goods such as freight forwarders, hauliers, couriers, logistics firms and customs agents.

They offered a range of services, with some managing customs documentation only and others additionally offering haulage and transportation services. To ensure a range of experiences were included, those interviewed varied in terms of:

• business size, from micro businesses through to businesses with up to 250 employees

• trading routes, including those who imported from the EU only and those who imported from the EU and rest of the world

• methods for declaration submission, with some submitting safety and security declarations themselves and some who outsourced completion and submission of declarations

Interviews were conducted via Microsoft Teams and telephone.

2.3 Key findings

Levels of awareness of the changes to safety and security declaration requirements varied amongst participants. Small, micro, and niche businesses (those specialising in facilitating the movement of specific types of goods), and hauliers, were more often unaware of the changes.

Some were aware that safety and security declaration changes were coming, but they lacked detailed information, while others possessed a deeper understanding.

Some intermediaries were unclear about their responsibilities regarding the changes, while others believed carriers were fully responsible. Hauliers and logistics firms generally acknowledged their responsibility for safety and security declarations.

Awareness of the reduced dataset for Entry Summary Declaration (available for both EU and rest of the world imports) alongside safety and security declaration changes, was generally low.

There were mixed views towards the reduced dataset, with some believing that it would not be relevant to their business. Whilst some participants believed the reduced dataset might reduce their workload, others thought it could create additional administrative burden. Participants also expressed a strong desire for more information on the reduced dataset.

A few participants had prepared for the changes to safety and security declaration requirements. Some participants also communicated the declaration changes to their clients. Others awaited additional confirmation and clearer guidance from HMRC before taking steps to prepare.

Although most had not prepared, participants generally felt confident that they would be able to prepare for changes when they received further guidance. They generally did not expect the changes to be difficult to implement and were cautious yet optimistic towards their ability to prepare. Some expressed scepticism that the changes would go ahead as planned. They preferred to wait until closer to the date when changes were going to be introduced. This scepticism was often based on previous experiences of customs changes being delayed.

Participants who had prepared for the changes prioritised communication with their software team or external software provider. Some emphasised their heavy reliance on their Application Programming Interface (API) systems to create efficiencies in customs processes. These businesses wished to ensure compatibility with their current systems.

Some participants expected to rely on their external software provider to implement safety and security declaration changes to their software. They also expected their external software provider to give training on the changes.

Participants generally found HMRC information on broader customs and border changes complex, and not specific enough to their business. Though not all participants were aware of HMRC information on safety and security declaration changes, a few were, and they found it overly complicated and lacking specific relevance to their circumstances. Instead, they turned to trade bodies, private consultants, and industry forums for clearer information.

These sources provided more tailored information and offered more practical guidance on implementation. Respondents recommended HMRC provide clear guidance tailored to their sector and business type regarding safety and security declarations changes, including webinars, flowcharts and examples of completed forms. Overall, communication needs did not significantly differ based on the size of the business or trading routes.

3. Introduction

3.1 Research context

A safety and security declaration is a customs measure required by border authorities since 2011 to analyse the potential risk caused to the territory by goods crossing their border. Since the UK’s exit from the EU in 2020, Great Britain  is no longer part of the EU safety and security zone. The UK government has introduced new border controls in stages, including a temporary waiver for safety and security controls on EU imports.

Safety and security import requirements for goods from the EU (and some other territories) were due to be implemented from 1 July 2022. This was delayed until 31 October 2024 to enable the introduction of a new model for imports into Great Britain under the Border Target Operating Model. The implementation date was further extended from 31 October 2024 to 31 January 2025, to allow HMRC more time to support businesses to prepare for the changes.

In addition to the new safety and security declaration requirements, HMRC introduced a reduced dataset for Entry Summary Declarations, applicable to both EU and rest of the world imports. This aimed to ensure that those already set up to make Entry Summary Declarations would not need to modify their existing systems or procedures if they preferred not to.

Although carriers can pass the requirement of completing safety and security declarations to intermediaries or agents, they have the ultimate legal responsibility to ensure they are submitted.

HMRC commissioned Ipsos to undertake research to examine intermediaries’ and carriers’ preparedness for changes to safety and security declaration requirements. This research took place before the implementation date was extended to 31 January 2025, and therefore covers intermediaries’ and carriers’ preparedness for the 31 October 2024 implementation.

3.2 Research aims

The aims of this research were to:

• investigate awareness and understanding of safety and security declaration changes

• explore preparedness for adapting to safety and security declaration changes

• identify challenges encountered in adapting to safety and security declaration changes

• evaluate the accessibility, effectiveness, and gaps in available help and guidance regarding safety and security declaration changes

3.3 Methodology

Ipsos conducted 40 qualitative in-depth interviews between the 8 February to the 21 March 2024 with different types of intermediaries and carriers.

Participants were recruited from past survey data where they had agreed to be recontacted, via Ipsos desk research, and HMRC networks. Eleven participants had access to a dedicated HMRC Customer Manager and were recruited via this connection. Participants interviewed had responsibility for managing customs declarations, international sales, or trading abroad within their business.

A recruitment screener was used to ensure eligibility for the research and a spread of intermediary and carrier types:

• size (0 to 249 employees)

• type (freight forwarder, haulier, courier, logistics, or customs warehouses, agents, or brokers)

• region currently imported from (EU only or EU and rest of the world)

• completion of safety and security declarations in-house or outsourced

• awareness of new safety and security requirements from 31 October 2024

• mode of transport (sea, aircraft, road or train)

• volume of safety and security declarations per year (0 to more than 100)

• region of Great Britain

A discussion guide was developed by Ipsos and HMRC. It used a deliberative approach involving gradually providing information on the new safety and security requirements to participants. The deliberative approach was used to test awareness and knowledge, as well as to gauge participants’ reactions.

Interviews lasted between 45 and 60 minutes and were mainly conducted via Microsoft Teams, though some were also conducted via telephone.

Please refer to Annex 1 to see a detailed breakdown of the sample composition.

3.4 How to read this report

Please see the Glossary and Abbreviations section for full details of the terminology used in this report.

The terms ‘intermediaries’ and ‘carriers’ are used in the research to describe participants based on their roles in the safety and security declaration process. It is important to note that these terms were not always used in the same way by research participants themselves.

During the recruitment process, some participants initially described themselves as intermediaries, however during screening they were later categorised as carriers.

This aligns with findings in this and other similar research conducted by Ipsos, where definitions may not always match precisely with the way that participants identify themselves, or with actual operational roles. For the purposes of this report, these terms serve as convenient descriptors rather than rigid classifications.

Direct quotes have been included in this report to illustrate and highlight key points and common themes. Where direct quotes are used, they have been anonymised and attributed with the following characteristics:

• intermediary and carrier type

• volume of safety and security declarations per year

• intermediary and carrier size

• trading routes including EU only or EU and rest of the world

Please note that 2 or more participants may have the same information in the attributions for their quotes.

The findings in this report are intended to provide a rich and detailed understanding of different intermediary and carrier views and experiences, not to determine the prevalence of these views and experiences amongst the populations of interest.

Where the report indicates that ‘few’, ‘some’, or ‘many’ participants experienced or felt something, this is in relation to the research participants only. Findings cannot be considered representative of the intermediary and carrier population.

4. Levels of awareness and understanding around safety and security declaration changes

Chapter summary

This chapter discusses how aware participants were of changes to safety and security declarations, as well as specific levels of understanding of the upcoming changes. This section also details the sources of information used by participants to learn about the upcoming changes, and which types of businesses were felt to be responsible for implementing changes.

4.1 Levels of awareness of upcoming safety and security declaration changes

Interviews revealed a mixed level of awareness and understanding among participants regarding the upcoming safety and security declaration changes. Participants’ knowledge and awareness of the changes could be categorised as follows:

• those with no awareness of safety and security declaration changes

• awareness of an upcoming change to customs processes but not specifically to safety and security declarations

• those with greater awareness of safety and security declaration changes

Those with no awareness of safety and security declaration changes

Some participants lacked any awareness of the planned changes to safety and security declarations. For example, some participants had initially assumed that forthcoming changes were related to other recently announced regulatory updates. For instance, new Sanitary and Phytosanitary controls delivered by the Department for Environment, Food and Rural Affairs. 

Despite their lack of knowledge, they expected to experience change in the course of their work. Their experiences since EU Exit meant they anticipated frequent modifications and updates to various customs processes and procedures. As a result, they were not concerned about the changes and expected to be able to adapt as needed.

Awareness of an upcoming change to customs processes

Some participants were aware of future changes to safety and security declarations, but lacked awareness of details or timings. Their awareness was limited to a general understanding that changes were forthcoming, without any clear details of the scope or implementation timeline of these changes.

Within this group, some participants expressed uncertainty regarding the specific processes or declarations that would be impacted. For example, a few participants mistakenly assumed that the changes would affect customs declarations or simplified declarations, rather than the safety and security declarations themselves.

Those with greater awareness of safety and security declaration changes

Some participants had a more detailed awareness and expected changes to safety and security declarations in October 2024. However, even within this group, knowledge was not always complete or accurate.

For example, some lacked specific details regarding the nature of the changes or the practical implications for their operations. Others had a general understanding of the changes but were uncertain about the specific requirements for submitting the declarations, or the steps needed to prepare for the changes.

4.2 Themes identified in participants’ awareness of safety and security declaration changes

Several themes were identified that led to the varying levels of awareness among participants of the upcoming safety and security declaration changes and reduced dataset for Entry Summary Declarations. These are as follows:

• claimed versus actual understanding

• lack of clear guidance and communication

• scepticism due to previous delays to introduction of new customs processes

• potential complexities in the new safety and security requirements

Claimed versus actual understanding of safety and security declaration changes

Some participants initially claimed to have a deep understanding of the forthcoming changes. However, upon further probing and discussion during the interview, it became evident that their knowledge was not as comprehensive or accurate as initially stated.

Lack of clear guidance and communication of safety and security declaration changes

Participants who lacked awareness of the safety and security declaration changes emphasised a need for clear, concise, and easily accessible guidance and communication from HMRC. They expressed a desire for straightforward explanations of the changes, their implications, and the specific actions required to ensure compliance.

“It’s one where the guidance isn’t really there, guidance tends to come a month in advance, and deadlines get moved, so it’s hard to plan for anyway.” (Customs agent, more than 100 declarations, 10 to 49 employees, rest of the world and EU)

Scepticism due to previous delays to introduction of new customs processes

Delays in implementing previously scheduled changes to borders and customs processes had contributed to a sense of scepticism among some regarding deadlines provided by HMRC.

This scepticism often stemmed from past experiences where changes which had been announced were postponed or rescheduled. This led to doubts about the certainty of the October 2024 implementation timeline.

As a result of this scepticism, some participants adopted a more cautious approach, delaying their preparations until they received definitive guidance that the changes would go ahead.

While they acknowledged the potential need for action, they remained comfortable with this uncertainty. They assumed that the relevant guidance would be provided by HMRC when needed to allow for timely preparation closer to the October deadline.

Potential for complexity in new safety and security declaration requirements

Some participants speculated about how the changes to safety and security declarations might link to their current processes. Expectations varied dependent on which systems and processes they were currently using, such as the Goods Vehicle Movement Service and the Customs Declarations Service.

Without specific guidance on how changes to safety and security declarations might affect other declaration processes, some participants were unsure how to plan effectively.

“We’re aware there are changes, and we’re trying to understand what those changes would do and what impact there will be. Will the new declaration changes tie into (Goods Vehicle Movement Service) GVMS? I am thinking ‘Do we need to do anything different? What’s different? How do we do it? Who’s going to do it? Is there going to be a cost implication?” (Freight forwarder, more than 100 declarations, 10 to 49 employees, rest of the world and EU)

4.3 Depth of understanding about upcoming safety and security declaration changes

Participants had a limited understanding of safety and security declaration changes. While awareness of the forthcoming changes varied, specific knowledge and comprehension of the details remained superficial.

Participants expressed a keen interest in understanding the practical implications of safety and security declaration changes including new requirements. This knowledge would enable them to start preparations and plan any necessary changes to their processes. Specifically, they sought clarity on the following aspects:

• declaration format

• information requirements

• implications for workload and costs

Understanding the safety and security declaration format

Participants expressed a desire to understand the format and structure of the new safety and security declaration, as this would inform the adjustments required to their existing systems and procedures.

Knowing and understanding information requirements for safety and security declarations

Clarity about specific data elements and information needed for the new safety and security declaration was a key requirement for participants. Understanding these requirements would allow them to assess the impact on their current data collection and submission processes and plan accordingly.

Implications for workload and costs as a result of safety and security declaration changes

Most participants assumed that safety and security declaration changes would not be overly burdensome or time intensive. However, some participants were concerned about disruption to their current workflows. A few participants were particularly worried about finding the time and resources necessary to adjust to these changes.

Participants were uncertain on several points including how long it would take to get up to speed, whether additional staff would be needed, the extent to which business operations would be affected during implementation, and if the changes would be integrated into their existing software packages. Each of these considerations were important because they carried potential cost implications.

“We will have to be reactive - we’ll start when Entry Summary Declarations comes in, see how long it takes. If it turns out it takes a long time we will have to get more staff in. It’s all a cost so rates to customers will have to increase.” (Logistics, more than 100 declarations, 50 to 249 employees, rest of the world and EU)

“The problem will be getting the safety and security declared in time, particularly where they are leaving depots close to Calais … It’s going to be a challenge on the Service Level Agreements, that’s for sure … if we miss those SLAs, our supplier can penalise us financially … It’s revenue-hitting if we get it wrong.” (Freight forwarder, more than 100 declarations, 50 to 249 employees, rest of the world and EU)

4.4 Impact of business size on awareness and understanding on safety and security declaration changes

Distinct patterns emerged in the levels of awareness and understanding of the upcoming changes to safety and security declarations among intermediaries and carriers of different sizes.

Small and micro businesses had more limited awareness and understanding about safety and security declaration changes

Smaller businesses, which included micro and niche intermediaries in the sample, generally lacked awareness or demonstrated a limited understanding of safety and security declaration changes. Several factors contributed to this.

Niche operations: some intermediaries operated in niche markets, specialising in the movement of specific types of goods with complex customs documentation requirements. Examples included the movement of live animals and items of cultural value. These niche intermediaries tended to be highly informed about specific changes which affected their own markets.

This high level of awareness was typically facilitated through close personal networks with other intermediaries who also operated in similar niche markets. However, these intermediaries tended to be less engaged with broader HMRC guidance and communications which affected the wider industry. Therefore, these intermediaries tended to be less aware of upcoming safety and security declaration changes.

Time and resource constraints: smaller intermediaries and carriers often faced greater time and resource constraints. This limited their capacity to research and comprehend the details of safety and security declaration changes. They frequently voiced concerns about the lack of time and resources available to dedicate to understanding the new requirements and necessary adjustments to their workflows.

Budgetary limitations: smaller intermediaries and carriers often lacked financial access to private consultants or personalised resources that could help them navigate and prepare more easily. Respondents gave examples such as information tailored to their business on ways to improve in-house systems. Instead, smaller intermediaries relied on information from trade bodies, associations, and industry networks. Examples included information from the British International Freight Association and the Irish Road Hauliers Association.

Larger businesses had higher levels of awareness and understanding about safety and security declaration changes

Larger businesses typically had more knowledge and understanding regarding safety and security declarations. Several factors contributed to this.

Access to information networks: larger businesses often had access to broader information networks and specialised support. This contributed to their heightened awareness and understanding of changes.

Established relationships and direct contacts: some medium-sized and larger intermediaries and carriers had personal relationships with HMRC and benefitted from direct contacts such as HMRC customer managers. These relationships facilitated more effective access to relevant information and guidance.

Dedicated resources and expertise: larger businesses tended to have more resources available to dedicate to researching and understanding new customs requirements. They often employed customs specialists or individuals with prior experience navigating similar regulatory changes in the customs and borders space, which enhanced their awareness and preparedness.

Industry networks and personal contacts were key influencing factors in awareness and understanding

Across business sizes, industry networks and personal relationships played a crucial role in sharing information and fostering awareness of safety and security declaration changes.

Smaller intermediaries and carriers often relied on close relationships with each other and contacts through personal networks to stay informed about regulatory updates. This was because they tended not to have access to broader industry networks and other intermediaries and agents.

In contrast, larger businesses worked with other intermediaries and agents to gather information and gain deeper understanding of safety and security declaration changes. Larger businesses also use broader industry networks such as trade bodies and associations to gain knowledge and build understanding of changes.

4.5 Impact of business type on awareness and understanding of the safety and security declaration changes

There were varying levels of understanding regarding which intermediaries and carriers would be responsible for implementing the upcoming safety and security declaration changes. Participants often based their assumptions on their own roles within the supply chain.

There were generally no differences in awareness and understanding between those who only imported from the EU, for whom safety and security declaration changes are expected to be the biggest, and participants who imported from the rest of the world and the EU. Instead, business type and size tended to have a bigger impact on awareness and understanding.

Participants whose primary operations were focussed on the transportation of goods were generally less aware of changes compared to other types of intermediaries. These businesses included hauliers, logistics firms, and couriers. These businesses focussed solely on the transportation of goods and did not carry out other intermediary services, such as customs brokerage.

Some haulage, courier, and logistics businesses included in the research also carried out other services such as brokerage, and as a result were more likely to be informed. This is because they had more involvement in customs processes including declarations.

Haulage firms, which primarily provided transportation and logistics services, faced several challenges that contributed to their more limited awareness and understanding of safety and security declaration changes. They tended to report a lack of access to essential information regarding changes.

Even after the safety and security declaration changes were explained to these businesses, their understanding remained limited. While they speculated about how the new declarations might interact with existing processes such as the Entry Summary Declarations and Goods Vehicle Movement Service, they sought further clarification from HMRC to fully comprehend the practical implications and requirements.

One of the key factors contributing to the limited awareness and understanding among hauliers, logistics firms and couriers was their lack of access to established information networks. These networks, which were more prevalent among other types of intermediaries, played a crucial role in disseminating information, sharing best practices, and facilitating the exchange of knowledge and resources.

4.6 Awareness of the reduced dataset

To simplify the new safety and security requirements, HMRC is introducing a reduced dataset for Entry Summary Declarations. This will be available for both EU and rest of the world imports. This change will be implemented so that those already set up to make Entry Summary Declarations do not need to make any changes to existing systems or procedures if they do not want to.

Many participants lacked knowledge and awareness of the reduced dataset. This was the case even among those with more thorough understanding of upcoming safety and security declaration changes.

On the whole, participants were unaware that there would be a reduced dataset, and also lacked awareness of what a reduced dataset would involve. When asked specifically about their understanding of a reduced dataset for Entry Summary Declarations, participants expressed a range of views regarding what this could involve.

Some participants anticipated that a reduced dataset for Entry Summary Declarations could lead to a reduction in workload and make the process easier for them. This perspective was tied to an assumption that a streamlined dataset would require less information input and potentially less duplication of efforts.

Others did not perceive the reduced dataset to be particularly relevant or beneficial to their operations. They expressed concerns that it could potentially create additional work, as their systems had been set up with a full dataset in mind. This included concern about potentially needing to provide the same information multiple times.

Participants expressed a desire for more detailed information on how this change might impact their specific business processes and operations. Participants generally reported that the information sources they relied upon, including HMRC, GOV.UK, and third-party sources, had not yet informed them about the reduced dataset for Entry Summary Declarations.

This lack of information contributed to the limited understanding observed across the sample. Participants often voiced the need for better communication about the reduced dataset to allow them to make appropriate preparations.

“If I’m honest I haven’t heard of this one, what does the reduced dataset include? I don’t see the point of a reduced dataset when the information they are going to ask for is given in other declarations.” (Customs agent, more than 100 declarations, 0 to 9 employees, rest of the world and EU)

“Anything that makes the job easier is good.” (Freight forwarder, more than 100 declarations, 50 to 249 employees, EU only)

4.7 Awareness of the Single Trade Window

At the time of the research, government had an active programme to develop a Single Trade Window. This intended to provide a gateway between businesses and all UK border processes and systems, allowing users to meet their import, export and transit obligations by submitting information once, and in one place.

Following Autumn Budget 2024, the programme was paused from 2025 to 2026. The government made this decision as part of overall affordability considerations. This pause will give the government an opportunity to take stock and further engage with traders, ports, software developers and other key stakeholders to better understand their needs for the future of operating at the UK border. The government will provide a further update as part of the next phase of the Spending Review.

To find out about participant awareness and views towards the proposed introduction of the Single Trade Window at the time of research, the topic guide included specific questions exploring this.

Awareness of the introduction of the Single Trade Window was generally limited among participants. Knowledge of the Single Trade Window was also therefore low, and participants did not tend to associate it with the safety and security declaration changes.

Awareness of the Single Trade Window across participants typically fell into 3 categories, as set out below.

No awareness of the Single Trade Window: some participants had no knowledge of the Single Trade Window and were unfamiliar with the term. They could not provide an educated guess about its meaning.

Limited awareness of Single Trade Window: many participants had heard of the Single Trade Window before, but their understanding of the Single Trade Window was vague and incomplete, with large gaps in knowledge.

In-depth awareness of Single Trade Window: a few participants had a more thorough understanding of the Single Trade Window. These participants had a better grasp of its purpose and the impact it could have on the efficiency of processing and moving goods.

Participants had varying views on the Single Trade Window. Some participants were optimistic about the introduction of it, while others were more sceptical. The mixed views included:

Scepticism about its introduction: overall, there was a perception that the goals of the Single Trade Window were optimistic. Participants believed the introduction of the Single Trade Window would be a major change in the customs space, however there were some concerns about potential delays to its introduction.

Potential to reduce workload: some understood that the Single Trade Window aimed to reduce workload and streamline processes. They were optimistic that a system integrating information across all declaration documents could create considerable efficiencies.

Additional work: some expressed concerns that the Single Trade Window could create additional work and administrative burden. Participants cited previous changes, such as the transition from Customs Handling of Import and Export Freight System (CHIEF) to Customs Declaration Service, and how these changes disrupted their business. This led them to feel that the transition to the Single Trade Window would be similar.

Relevance to business: some believed the Single Trade Window might not be relevant to their business or would not make a significant difference.

“It’s a good thing to aim for but not realistic in the short term … HMRC should continue to work towards it … But it should be fully fledged before it’s released.” (Customs agent, more than 100 declarations, 10 to 49 employees, rest of the world and EU)

5. Current readiness for safety and security declaration changes

Chapter summary

This section will cover participants’ perspectives on their preparedness for safety and security declaration changes. It details the key steps taken to prepare for forthcoming changes and the challenges faced in this process. As noted previously, this research took place before the implementation date was extended to 31 January 2025 and therefore covers intermediaries’ and carriers’ preparedness for the 31 October 2024 implementation.

5.1 Levels of readiness

Only a small proportion of those interviewed had made any preparations for the upcoming safety and security declaration changes.

Most participants had generally not taken steps to prepare yet and anticipated they would prepare closer to October when they expected clearer information to be available. Most did not anticipate issues with being able to prepare ahead of the introduction of changes

5.2 Impact of uncertainty

For those with awareness of the upcoming safety and security declaration changes, reluctance to prepare was most often due to the perceived absence of confirmation from HMRC that changes would take place, as well as a lack of detail on what changes would look like.

Scepticism about planned timescales

Many participants expressed scepticism about the timing of the planned safety and security declaration changes. They cited multiple past postponements as a barrier to preparation. Participants had previously prepared for changes that did not materialise, causing frustration and wasted time and resources.

Delayed preparation for safety and security declaration changes

Participants generally planned to wait to prepare closer to 31 October 2024 due to uncertainty about whether changes would be postponed again.

Cost and time concerns about safety and security declarations

Some smaller businesses were particularly concerned about the investment of time and cost to implement the changes. They noted that preparing for the changes would disrupt current workflows and likely result in training or software costs. Consequently, they preferred to wait until closer to the 31 October deadline to receive full confirmation from HMRC before starting their preparations.

“There’s a huge element of me that just doesn’t trust it will happen … because it’s been delayed and postponed so many times … I just have no faith it will happen.” (Freight forwarder, more than 100 declarations, sole trader, EU only)

“It’s just a matter of being patient and waiting for the information to come over.” (Freight forwarder, 0 declarations, 50-249 employees, rest of the world and EU)

5.3 Impact of knowledge gaps about safety and security declaration changes

A lack of knowledge among some participants had impacted their efforts to prepare for safety and security declaration changes effectively. Several themes relating to knowledge gaps were identified within interviews.

Lack of clarity about safety and security declaration changes

There was a lack of clarity around changes, particularly on the precise details of what the changes would include. Participants desired further confirmation from HMRC about the nature of the changes.

Uncertainty about the specific changes

The volume of time, resource and cost associated with adapting to the upcoming changes was unknown due to the absence of specific details about the new requirements. Participants indicated that once HMRC confirmed these details, they would be able to prepare accordingly within their business.

Dependence on software providers

Participants expected to discuss changes with their software providers. However, only a few had done so, as most had not yet engaged with providers due to uncertainty about the upcoming changes.

Desire to improve understanding

Participants emphasised that their immediate priority was to gain a complete understanding of changes before acting. They planned to conduct further research on GOV.UK and consult additional sources, including British International Freight Association, industry forums, private consultants, software providers, and trade bodies. Some planned to do this because taking part in this research prompted them to consider safety and security declaration changes.

“We are making some preparations, mainly just attending the HMRC webinars… And sometimes Department for Environment Food and Rural Affairs, Animal and Plant Health Agency’s… But although we do try to engage with these, it does seem a lot of it is ‘to be decided’, a lot of the information that we would rely on when creating procedures or any kind of action plan to tackle these upcoming changes. It’s just not there yet.” (Customs warehouse, more than 100 declarations, 10-49 employees, rest of the world and EU)

5.4 Key steps taken and importance of software providers

A few participants had already taken steps towards preparing for safety and security declaration changes. These focussed mainly on software changes and updating communications with current and potential clients.

Some participants had informed clients about the upcoming changes. Some questioned whether the changes would affect their value to clients. Meanwhile, a few saw potential commercial benefits by offering safety and security declarations as part of their service. They had started to advertise their businesses’ use of safety and security declarations because of this.

Participants who had prepared also emphasised the importance of informing their software providers, whether external or in-house, to ensure compatibility with the changes. Participants described several themes related to how software systems and providers would be important in adapting to new requirements, as follows.

Heavy reliance on software systems for their operations: participants relied heavily on their software systems. They emphasised that if their API and software were compatible with safety and security declaration system changes, they would be able to manage changes more effectively. Customs agents were more likely to have already begun communication with software providers about the changes, compared to other intermediary and carrier types.

Medium-sized, high-volume, and well-established customs agents particularly highlighted the efficiency that APIs and systems brought to their processes.

“We rely so heavily on our API systems. It is imperative that we communicate the changes with our software provider. If the systems comply with the changes, it saves so much manpower when it is all automated. That was our first step in preparing.” (Customs broker, more than 100 declarations, 10-49 employees, rest of the world and EU)

“We signed a couple of contracts when we previously thought the changes would come into place. I have been talking to staff that we need to get some contracts signed and advertise that we are doing safety and security declarations so hopefully it will be a benefit for the business and encourage more work.” (Customs agent, more than 100 declarations, 10 to 49 employees, EU only)

Reliance on software providers for information: Some participants relied on their software providers to stay informed about changes in safety and security declarations and their implementation. Participants described how these software providers often provided bulletins or newsletters around system changes which reflected updates in regulation and processes.

Training from software providers: Participants also described provision of training on customs changes as part of their service packages, covering topics such as regulatory updates, software adjustments, and best practices for compliance. This was in addition to ongoing support which helped to ensure smooth implementation of the changes and minimise operational disruption.

5.5 Expectations surrounding safety and security declaration changes

Although most participants had not yet taken any steps to prepare for safety and security declaration changes, they did not anticipate significant difficulty doing this closer to October. Confidence stemmed from their extensive experience with customs changes after the UK’s exit from the EU and collaboration with software providers to adapt to new requirements.

Many participants felt they used technologically advanced systems and APIs and, as a result, anticipated smooth integration of upcoming safety and security declaration changes.

Many participants also commented on being encouraged by their proven ability to implement other HMRC changes, including those seen as more complex, such as the transition to Customs Declaration Service. This increased their confidence towards managing upcoming safety and security declaration changes.

Smaller businesses adopted a more agile mindset, despite being less aware of safety and security declaration changes and facing more budget and time constraints. These participants expressed confidence in their ability to adapt to changes due to their previous experiences of customs changes and being used to learning through adapting.

Larger businesses tended to rely more heavily on their technological systems and software providers to ensure compliance.

Overall, participants displayed a cautious yet optimistic outlook regarding their preparedness for safety and security declaration changes.

6. Support and communications around safety and security declaration changes

Chapter summary

This chapter discusses sources of information and support used by participants, as well as specific communication needs around changes to safety and security declarations. The section also outlines the role of HMRC, trade bodies, associations and networks, private consultants, and software providers.

6.1 Sources of information about safety and security declaration changes

For participants who had awareness or understanding about the changes, they tended to have learned about the changes via direct HMRC contacts (relationships with HMRC customer managers), GOV.UK, or third parties, such as a trade bodies, associations and networks.

6.2 The role of third parties

Participants generally viewed and used HMRC support. However, it was not always the first port of call. Alongside HMRC support, trade bodies, associations, and networks were important sources of advice and guidance.

Participants relied on trade bodies, associations, and networks due to their expertise and record of providing support and communication about previous changes.

The role of software providers

Software providers were seen as key to enabling participants to embed safety and security declaration changes. There was a general expectation that software providers would be proactive in implementing any required safety and security declaration changes to their software and systems.

Participants expected to rely on the information and training these organisations would provide alongside software updates.

“We’ll have an update and we’ll be able to do it on our system but it’s not there now. I’m just waiting for the software provider to do an update… It’s governed by our software provider.” (Freight forwarder, more than 100 declarations, 50 to 249 employees, EU only)

The role of trade bodies and associations

Some participants learned about safety and security declaration changes through trade bodies and trade associations including the British International Freight Association.

Relevant information was typically shared through communications, such as newsletters they had subscribed to, as well as events. Those unaware of changes expected to access specific advice, guidance, and support from trade bodies and trade associations.

“I’m aware of it [safety and security declaration changes] because I go to British International Freight Association events and I’m a member of certain networks.” (Freight forwarder, more than 100 declarations, 50 to 249 employees, rest of the world and EU)

The role of private consultants

A small number of participants mentioned accessing specific advice, guidance, and support about declaration changes from private consultants. These consultants were typically other intermediaries employed to support and advise on customs processes.

6.3 Experience interacting with HMRC engagement channels, forums, and communications

Some participants had engaged with HMRC engagement channels, forums, and communication channels to varying degrees whilst others had not. Examples of engagement included attending Customs Declaration Service and Single Trade Window forums, receiving Customs Intermediary emails, and having a HMRC customer manager.

Participants’ experiences of interacting with HMRC engagement channels, forums and communication channels were mixed.

A few participants had positive views of interacting with HMRC engagement channels, forums, and communication channels. These participants described HMRC forums as informative due to the attendance of experienced and knowledgeable Customs and Border Force Officers who answered questions.

Participants who received HMRC Customs Intermediary emails felt they provided detailed and accurate information which was helpful and useful. One participant that received support from a HMRC customer manager described receiving quick and tailored answers which were seen as useful.

However, some participants were more critical, in particular about information on GOV.UK related to broader customs and border changes. These intermediaries described language used on GOV.UK as difficult to understand and navigate, impacting their ability to absorb and digest new guidance.

Some participants also expressed a perception that information on GOV.UK was not always up to date or was not tailored to their intermediary and carrier type. For example, some freight forwarders felt that information and guidance on GOV.UK was not specific enough for freight forwarding.

“Sometimes you can go on the [GOV.UK] website and there will be old information that’s on there that may not be relevant anymore.” (Customs agent, more than100 declarations,10 to 49 employees, rest of the world and EU)

6.4 The expected role of HMRC in communicating safety and security declaration changes

Participants felt that HMRC’s initial role would be to confirm safety and security declaration changes would be taking place. They expected that this would be followed by HMRC setting out new safety and security declaration guidance and clarifying expectations with practical step-by-step guidance.

Participants generally expressed a desire for HMRC safety and security declaration guidance to be as specific as possible, avoiding any ambiguity. A few participants expressed a desire for HMRC to provide this over the summer of 2024 because this is when they expected to start to prepare.

“I think it would be helpful to have written information on GOV.UK? So that we’ve got something that we can refer to and discuss and get plans [into place].” (Customs agent, more than 100 declarations, 50 to 249 employees)

Some participants also expected specific advice, guidance, and support about safety and security declaration changes to come from HMRC staff that they had relationships with. For example, relationships with HMRC’s customer managers.

6.5 Common queries from participants regarding the safety and security declaration changes

As outlined in section 1 and section 3.3, participants had several common queries regarding safety and security declaration changes which they wanted clarification from HMRC on. These queries were as follows:

• clarity on who would be responsible for completing safety and security declarations

• details of the updated procedure to complete safety and security declarations, including highlighting what was different to the previous procedure

• specific types of information required to complete updated safety and security declarations

• whether safety and security declarations would become part of an import entry, or whether it would be an additional procedure

• details of any similarities or differences to other systems and processes in the borders and customs space such as the Customs Declaration Service and Goods Vehicle Movement Service

• whether safety and security declarations changes would be part of the Single Trade Window

“We need to know what fields are required… Does the import Customs Declaration Service have to tie up exactly with the safety and security declaration? Or are we going to be able to upload multiples on both instances and be done with it?” (Agent, more than 100 declarations, 50 to 249 employees, EU only)

Respondents generally felt that receiving answers to their queries would help instruct preparations for safety and security declaration changes. There was a strong desire for guidance to be in accessible and digestible formats online on GOV.UK as soon as possible. However, it was also important that intermediaries and carriers were confident that information on GOV.UK was up-to-date, concise, clear, practical, and easy to understand.

Some participants expressed desire for more tailored support about safety and security declaration changes. This would be based on their intermediary or carrier type, the specific customs process being handled, or the trade route facilitated.

For example, freight forwarders wanted information and guidance specifically for freight forwarding whilst hauliers wanted information and guidance for hauliers. This was because participants did not want to have to assess which guidance was relevant to them and which was not.

In terms of specific information formats, the strongest desires were for flowcharts, step-by-step information, training guides and videos about safety and security declaration changes. Information presented in this way was felt to be easier to understand and digest. Some participants also desired mock-ups of completed safety and security declaration forms with clear information about what was different from the previous version.

Participants also expressed a desire for HMRC webinars and seminars about safety and security declaration changes. They reported that the interactive nature allowed attendees to ask questions and receive tailored and immediate answers from experts.

It was important to participants that webinars and seminars should be delivered by experts. This was because they felt that this would ensure that they had accurate information provided by HMRC and could trust in the guidance given. Previous experience of finding HMRC webinars and seminars valuable also contributed to their preference for such formats.

One participant mentioned that HMRC could attend webinars such as those held by trade bodies and associations.

“I would like to see them [HMRC] doing more webinars, maybe in-person conferences, bang on the doors of the freight forwarders. We want meetings and conversations, not just HMRC sending instructions and asking us to work it out.” (Freight forwarder, more than 100 declarations, 50 to 249 employees, rest of the world and EU)

7. Conclusions

The aim of this research was to explore the understanding and preparedness amongst intermediaries and carriers based in Great Britain for the introduction of new safety and security declaration requirements for EU imports due to be implemented on the 31 October 2024.

Participants’ awareness and understanding of safety and security declaration changes:

• awareness of safety and security declaration changes was uneven, with knowledge and understanding generally low and superficial across participants

• smaller and more niche intermediaries and carriers in particular often lacked awareness and knowledge and they faced time, resource, and budgetary limitations

Participants’ preparedness, and the challenges of adapting to safety and security declaration changes:

• participants were often hesitant to prepare for upcoming changes due to uncertainty based on past experiences of postponed changes to borders and customs regulations

• while a small number of participants had proactively prepared for changes, most preferred to wait for clearer information from HMRC before acting

• those who had taken steps to prepare for the changes emphasised the importance of communication with software providers, whether in-house or external, as participants heavily relied on systems and APIs to create efficiencies with customs processes

• many participants expressed reliance on their external software provider to implement safety and security declaration changes to their software and provide training about changes

Accessibility, effectiveness, and gaps in available help and guidance regarding safety and security declaration changes:

• third-parties such as trade bodies, associations and networks, private consultants, and software providers in particular were a source of information and support regarding safety and security declaration changes

7.1 Participants’ support and guidance needs from HMRC

Participants were asked what HMRC could do to facilitate a smooth process and ensure understanding and preparation for safety and security declaration changes. They suggested:

• confirmation from HMRC that changes will be taking place on schedule as this will help them to plan and prepare for changes

• clear and specific guidance from HMRC regarding changes, tailored to intermediary and carrier type

• practical guidance such as step-by-step instructions and examples of completed forms, as well as clarification of expectations for changes to safety and security declarations