Research and analysis

Exploring smaller traders’ experiences of the customs onboarding process: full research report

Published 15 July 2025

Qualitative research with small traders based in Great Britain.

HM Revenue and Customs (HMRC) Research Report 766.

This research was commissioned under the Conservative administration (2010 to 2024), and was conducted by Ipsos between June and August 2023.

The findings in this report reflect the attitudes of participants at the time it was conducted. Prepared by Ipsos (Shahil Parmar and Amanda Stevens) for HMRC.

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

1. Glossary and abbreviations

Abbreviation or phrase	Description
Consignment	An arrangement where an exporter delivers goods to a distributor, who agrees to only pay the exporter once they have sold it. The exporter retains ownership of the goods until they are sold, but also carries all the financial burden and risk.
Customs Agent or Broker	Customs brokers complete declaration forms on behalf of traders importing or exporting goods. This helps 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 authorisation	Customs authorisations are certifications given by HM Revenue and Customs (HMRC) that allow traders to follow simplified customs processes. They also allow traders to follow customs procedures in specific circumstances (for example, the temporary admission of goods into the UK). In this report, authorisations are referred to as being ‘held’ by traders or by intermediaries.
Customs Declaration	The process required to notify HMRC of a particular assignment of goods being either exported out of the UK or imported into the UK.
Customs Declaration Service	The Customs Declaration Service supports making import and export declarations when moving goods into and out of the UK. From 30 March 2024, the Customs Declaration Service will be the UK’s single customs platform and all traders will need to declare goods through the service.
Customs Handling of Import and Export Freight	HMRC’s computer system for managing customs services. It is being phased out over the course of 2022 to 2023 and replaced by the Customs Declaration Service.
Customs Onboarding	The processes traders are required to undergo to enable them to trade internationally by complying with customs regulations.
Duty Deferment Account	This is an authorisation to defer the payment of duty. Traders that import regularly can defer customs or tax charges, including customs duty, excise duties, and import VAT, by applying for a duty deferment account. Traders can also apply to delay paying duties on goods released from an excise warehouse. A duty deferment account lets the importer (or someone representing them) make one payment a month through Direct Debit instead of paying for individual consignments.
EORI number	This stands for an Economic Operators Registration and Identification (EORI) number, which all traders need to be able to trade internationally.
Freight forwarder	Freight forwarders facilitate the movement of goods from between countries and can also be known as shipping agents. 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.
Haulier	Hauliers deal mainly with the physical transportation of goods.
Importing and exporting	The movement of goods or services from one country to another. This research focused purely on goods, as customs declarations are not required for services.
Intermediaries	Third-party businesses that provide services for traders to support them in importing and exporting goods. Types of intermediaries include freight forwarders, customs agents, brokers, hauliers, or express operators. The exact form of the services may vary from carrying out paperwork, to handling goods themselves and providing specialist transportation services.
Qualitative research	This involves collecting and analysing non-numerical data (for example, through an in-depth interview) to understand opinions or experiences.
Trader	A business which imports goods to the UK or exports to other countries. For the purposes of this report, traders are categorised by size according to the number of employees, as follows. Please note, only micro and small traders were included in the sample: small trader (10 to 49 employees), micro trader (one to 9 employees), sole trader or zero employees.

2. Executive Summary

2.1 Research background and aims

This research sought to explore the experiences that traders in Great Britain have of the customs onboarding process.

Customs onboarding describes a series of registration processes that businesses need to complete in order to trade internationally. These are:

• registering for a Government Gateway account
• registering for an EORI number
• subscribing to HMRC, Customs Declarations Systems
• some businesses may also apply for customs authorisations

This research explores how traders navigate the registration processes involved in customs onboarding. It seeks to understand the extent to which traders find these processes easy or difficult to complete.

The research also explores how traders seek information and guidance about customs onboarding. It examines the sources of information and guidance that traders used and how useful they perceive these to be.

The study also provides insights into the role that intermediaries play in supporting businesses that are new to customs processes. It examines the considerations that traders make in deciding to engage intermediaries.

Insights from this research will help to inform ways to enhance these processes. Ensuring a streamlined process for businesses that are new to customs can help to promote seamless cross-border trade. This aligns with the 2025 UK Border Strategy which aims to embrace innovation, simplify processes for traders and travellers and improve the security and biosecurity of the UK.

2.2 Methodology

The research used a qualitative methodology. A total of 33 semi-structured, in-depth interviews were conducted with smaller traders (up to 49 employees) based in Great Britain between June and August 2023. The traders recruited to take part in the research had completed the customs onboarding process between October 2021 and March 2023.

The interviews were conducted via Microsoft Teams or telephone and followed a topic guide developed by Ipsos and HMRC. The design of the topic guide allowed for open-ended questions and a detailed exploration of trader experiences. 

2.3 Overall experience of the customs onboarding process

Most participating traders found the customs onboarding process to be straightforward. However, occasionally some aspects could be more complicated or challenging. Whilst problems were not frequently encountered, traders shared a handful of occasional ‘pain points’ within the onboarding process.

2.4 Expectations of the customs onboarding process

Traders’ initial expectations of the customs onboarding process varied, often influenced by factors like business longevity and prior experiences with HMRC. Some anticipated a daunting, complex process, or expected bureaucratic delays and onerous tasks, often based on past experiences with HMRC or other government departments.

Those who were more comfortable with the process typically had extensive experience with administrative procedures like VAT registration and tax returns. They therefore anticipated a more straightforward process.

2.5 Seeking information and guidance on the customs onboarding process

HMRC webpages are part of GOV.UK. In the research, traders used GOV.UK and HMRC interchangeably. This report will use ‘GOV.UK’ to represent both, however, quotes from traders are taken as verbatim and may refer to either HMRC or GOV.UK.

Traders interviewed primarily used GOV.UK for guidance on the customs onboarding process, often using search engines to direct them to relevant pages. Many of these traders found the information on these platforms trustworthy and comprehensive. Others, meanwhile, found the web pages hard to navigate, overwhelming, or lacking in specificity for their business needs.

Some traders also sought information beyond government resources, accessing a range of online and offline sources. Third-party websites, industry forums, accountants, and intermediaries were common sources of informal, practical, or professional advice.

Despite the wide use of GOV.UK, recall of the step-by-step guidance pages on importing and exporting was low. Participants who were aware of them had mixed experiences, with some finding them useful and others wanting more detail within the guidance.

Most traders interviewed chose to complete the customs onboarding process independently rather than engaging with an intermediary, citing cost as a significant factor. Those who did use intermediaries did so for convenience or due to a lack of confidence in navigating the process independently.  

2.6 Registering for a Government Gateway account

Government Gateway is an online service where you can register to use a variety of online government services. HMRC uses the Government Gateway for access to many of their digital services. Most traders in this sample were aware of the requirement to register for a Government Gateway account to start the customs onboarding process.

Many traders already had an account for other business-related purposes such as VAT, PAYE, and Corporation Tax. For those unaware, they learned about its need through research or advice from intermediaries or accountants.

Registration experiences were generally positive, with most participating traders finding the process quick and simple. However, traders had several Government Gateway accounts which they used separately for other purposes (such as managing tax and National Insurance). Some traders found it confusing and frustrating to manage more than one Government Gateway account at the same time.

2.7 Registering for an EORI number

Awareness and experience of registering for an EORI number varied among traders. Some were aware from the outset, either through previous professional experience, advice from accountants, or their own research. Others became aware that they needed to register after learning that it is required to trade internationally. Some traders were informed that they needed to register for an EORI number by suppliers.

The majority of traders interviewed could not remember the specifics of the EORI registration process. For most traders, the overall experience of registering to obtain an EORI number was quick and straightforward. However, some traders had difficulties with some aspects, such as linking VAT and EORI numbers.

A very small number of traders registered for an EORI number without intending to trade internationally. Most of these had bought goods from overseas. They needed to apply for an EORI number to comply with customs regulations to import the goods they purchased into the UK. These businesses did not consider themselves to be trading internationally.

In addition, one business interviewed had not begun trading internationally but had registered for an EORI number. They did this to prepare for future trade activities.

Though the registration process was generally efficient, a handful of traders experienced delays in receiving an EORI number, leading to disruptions in business operations. Traders facing these issues typically waited for resolution rather than seeking help from HMRC or other sources.

2.8 Subscribing to HMRC Customs Declaration Systems

Many traders in the sample had difficulty recalling whether they were subscribed to the Customs Handling of Import and Export Freight system or the Customs Declaration Service. In some cases, they were confused about what these services were and, as a result, few were able to share their experiences.

In a few cases, traders attributed their lack of familiarity with subscription as something that was possibly taken care of by intermediaries.

2.9 Applying for customs authorisations

The understanding and use of customs authorisations varied. Most traders interviewed did not apply for authorisations due to a lack of awareness or the perception that their operations are too small to benefit.

The few traders who did apply for customs authorisations chose duty deferment accounts. The main motivations for applying were cost savings, cash-flow support, and avoiding administrative fees.

While the application process was seen as time-consuming, it was not viewed as overly complicated. However, changes in circumstances, such as needing to link a new EORI number with an existing duty deferment account, could complicate the process.

A few traders reported using authorisations through an intermediary for convenience, simplicity, and to handle potential complexities. This freed them to focus on their core business activities.

2.10 Seeking support with challenges during the customs onboarding process

While the customs onboarding process was generally straightforward for most traders in the sample, some challenges persisted. For some traders, linking EORI and VAT numbers was a confusing process. A few traders encountered temporary disruptions to their businesses due to delays in receiving an EORI number.

Generally, traders reported that the volume and complexity of information available from GOV.UK can be overwhelming, and navigating this site can be difficult.

Some traders found it challenging to reach support through HMRC’s helpline and online chat function, often mentioning extended wait times. Some felt HMRC’s guidance did not address their queries and were frustrated by this.  

2.11 Impacts arising from the customs onboarding process

Traders experienced a mix of positive and negative impacts from customs onboarding. On the positive side, most traders interviewed found the process to be straightforward and beneficial to them because it enabled them to trade internationally.

Some elements of the process, such as the Government Gateway and EORI registration, were less complex than anticipated, potentially boosting traders’ confidence in handling related tasks.

However, negative impacts were also reported. Some traders felt the time they spent on customs onboarding could have been better used on their regular business activities.

In some instances, the process incurred costs, such as buying new software systems for customs declarations and fees for intermediaries. A few traders experienced delays in receiving EORI numbers, leading to temporary operational changes and potential financial impacts.

3. Background and approach

3.1 Context

The UK government is committed to making cross-border trade both smooth and efficient for traders. The 2025 UK Border Strategy envisions a world-leading UK border that is not only innovative but also trader-friendly. By simplifying processes, government aims to facilitate seamless trading and bolster the security and biosecurity of the UK. This forward-thinking approach underpins the government’s commitment to optimising trade operations at the border.

For traders to be able to trade internationally they must understand customs requirements and how they apply to their own businesses.

Prior to this research there was limited insight on traders new to customs processes. In particular:

• their experiences of engaging with customs processes for the first time
• how they find information and guidance about these processes
• their experiences during registration

3.2 Research aims and objectives

This research sought to develop insight into the experiences that traders have when registering for and using customs processes for the first time. It explored:

• experiences of registering for specific customs processes and using these, including pain points and suggestions for improvement
• awareness and understanding of customs processes, including views on sources of information and guidance
• experiences of applying for and using authorisations and suggestions for improvement
• the role of intermediaries in customs onboarding and traders’ views on the service they receive from intermediaries

Findings from this research will support HMRC to ensure that the customs onboarding process is as straightforward as possible for traders. The findings will also help to support critical spending decisions on how to target resources for service improvements. Ensuring a streamlined process for traders that are new to customs can help to promote smooth cross-border trade. This aligns with HMRC’s strategic priorities as outlined in the 2025 UK Border Strategy.

3.3 Methodology

A qualitative methodology was used to undertake this research. This methodology was chosen to gather insight and explore the research aims because:

• it presents an opportunity to explore a range of experiences, attitudes, and opinions in detail
• it supports researchers to generate insight into how and why certain experiences occur and the reasons behind them

Ipsos conducted a total of 33 semi-structured, in-depth interviews with traders that had experienced the customs onboarding process between October 2021 and March 2023. Interviews took place between June and August 2023.

The interviews were conducted using either Microsoft Teams or telephone and each lasted 30 to 45 minutes. Interviews followed a topic guide (Annex B) that covered the key research questions and was developed collaboratively by Ipsos and HMRC.

Questions in interviews were typically open and allowed participants to talk in detail about their experiences. Interviewers guided and prompted participants where necessary to examine key topic areas.

3.4 Analysis     

Findings from the interviews were collated and analysed to draw out key themes throughout fieldwork. At the end of fieldwork, interview findings were filtered and further analysed across relevant subgroups and characteristics. This drew out insight into specific trader experiences of customs onboarding. It also drew out reasons for key differences by enquiry type and other factors such as business age and trading activity.

3.5 Sample and recruitment

A sample of 2,900 traders that had registered for an EORI number between October 2021 and March 2023 was supplied to Ipsos by HMRC. Recruitment was guided by a screening questionnaire which was used to ascertain eligibility for the research.

Interviews reflected a mix of traders in terms of trading activity and firmographics. All of those interviewed were smaller traders with up to 49 employees. All of those interviewed were based in Great Britain. A summary of the traders that took part in the qualitative research by their characteristics is outlined in Annex A.

3.6 Interpretation of qualitative data

This research is based on the findings of interviews with 33 traders, which is a small proportion of the number of those that have embarked on the customs onboarding process. Please treat the findings in this report as indicative and related to those interviewed. This research is not representative of all traders that have completed the onboarding process.

When considering these findings, it is important to keep in mind that qualitative research is descriptive, illustrative, and exploratory. It explores the range of experiences and opinions of participants in detail, providing insight into the key reasons underlying participants’ views. We sampled participants purposively to highlight a diverse range of business circumstances and experiences of customs onboarding.

Although the participants were able to provide a broad overview of their experiences with customs onboarding, low recall, (related to recency), posed a challenge. This made it difficult for participants when asked to break down the steps of the process and describe these in detail.

It is also important to mention that there was a lack of salience across the topics discussed. This further contributed to the difficulty participants faced in describing specific steps of the onboarding process. This issue was noted during the pilot stage of the research, and Ipsos and HMRC adapted the topic guide to respond to this issue. This revision made it easier for participants to give a clearer and more comprehensive overview of their experiences by adopting a broader perspective.

Throughout the report we have included verbatim quotes to illustrate findings. To protect participant anonymity, quotations have been attributed to key business characteristics.

4. Expectations of the customs onboarding process

Participants held a range of expectations on the customs onboarding process. There were no clear differences by business size, sector, or how long traders had been established. However, perceptions of dealing with HMRC appear to have influenced initial expectations.

Some traders initially thought the process would be difficult, daunting, and anticipated a lengthy or complex process. Others had concerns about making mistakes and the possible repercussions for their company including facing penalties. Negative perceptions were sometimes influenced by past experiences with HMRC, or other government departments.

“I thought it would be relatively complex, to be honest. I thought there would be a whole raft of forms to fill in, to get stamped. There was the expectation that if I missed one of the forms there would be a severe punishment involved. …For someone that’s not dealt with it before, it sort of, sends a shiver down your spine.” (Import only, Trades only with the EU, Consigned only)

“I thought it would be quite tricky because quite a lot of the processes with HMRC tend to be quite long winded. You have to jump through quite a few hoops, a lot of paperwork which we do quite a lot on a regular basis feels quite pointless, but there’s quite a huge amount of it.” (Import only, Trades only with the EU, Consigned only)

In some cases, traders embarked on the customs onboarding process without any expectations. They simply did not know what to anticipate because they had no prior experience with such procedures.

Traders who felt more comfortable with the customs onboarding process tended to have had more extensive previous experience of undertaking administrative procedures. Examples include registering for VAT and filing tax returns regularly. These traders tended to have more than 3 years of trading experience. As a result of this previous experience, they were more likely to anticipate a straightforward and quick process.

5. Seeking information and guidance on the customs onboarding process

5.1 Information and guidance from GOV.UK

HMRC’s webpages are currently part of the wider GOV.UK site. During the research, traders used GOV.UK and HMRC interchangeably to describe government sources of information and guidance that they accessed online. For clarity, this report will use ‘GOV.UK’ to represent both. However, quotes from traders have been used in verbatim to illustrate the findings, and therefore may refer to either HMRC or GOV.UK.

Most traders interviewed used GOV.UK to find information and guidance about customs onboarding. The majority used search engines to direct them to the right GOV.UK webpage. They described undertaking a broad online search using a search engine to then shortcut to the right page.

Traders described mixed experiences of using GOV.UK. Those who sought information and guidance on GOV.UK tended to trust this over other resources. They mentioned using these webpages to help verify their understanding of the onboarding process and of customs requirements more broadly. 

“It was mainly looking on HMRC’s website to understand what the recommendations and guidance are and what the compliance is, what we need to do to tick the legal boxes.” (Import only, Trades only with the EU, Consigned only)

Some traders appreciated GOV.UK for their detailed and clear information. The central coordination of these webpages enabled them to find official information in one place. This was particularly beneficial for those requiring broad knowledge about the process.

“I read quite a lot online on GOV.UK, it’s brilliant at making complex things simple. I think it is excellent. I would be able to find and understand absolutely everything on there.” (Import only, Trades with EU and Rest of World, Consigned only)

Amongst traders that reported challenges, some felt GOV.UK was difficult to navigate. Some users found the amount of information on GOV.UK to be overwhelming. There were also instances of users feeling ‘led in circles’ by hyperlinks, landing back on previously visited pages without finding the information desired.

Some traders in this sample felt that GOV.UK information and guidance was too generic and not suitably tailored to their specific needs. Some were unable to find any information that was aimed at traders new to customs processes. Others encountered unfamiliar terms and felt that information on GOV.UK assumes that users will already have a level of knowledge about customs and international trade.

“I think I needed more of a layman’s explanation and a step-by-step explanation of how things went, and I don’t think that’s the way I accessed information.” (Export only, Trades with EU and Rest of World, Consigned only)

5.2 Other sources of information and guidance

GOV.UK was generally widely used to find information and guidance on customs onboarding by traders. However, it was not always the first port of call.   

Some traders used a mix of online and offline sources to find information and guidance on the onboarding process. Many of these conducted broad online searches, using search engines as a starting point to find out what was needed to get their businesses ready for customs. These searches sometimes led traders to third-party websites which were praised for providing practical advice and information in simpler terms.

“HMRC’s guidance I find not very well written in, sort of, layman’s terms, for the average business advisor, or employee […] going to HMRC’s guidance is never my first port of call. It is very much Google to find in layman’s terms, ‘ What do I need to do if I want to import X, Y, and Z?” (Import only, Trades only with the EU, Consigned only)

Similarly, web-based resource libraries were felt to be helpful and accessible by traders who had used them. Online networks and forums were found to be useful for offering real-world insights from traders who had embarked on a similar journey.

The offline sources of information and guidance such as accountants and intermediaries that traders consulted were trusted advisors to them. Traders turned to these sources for more formal and professional advice, and to ensure they were being compliant throughout the onboarding process.

Other traders were passive rather than proactive in how they sourced information and guidance about customs onboarding. Rather than seeking out information or guidance, they found out about steps in the process unexpectedly. This was generally through conversations with other firms in their supply chain.

These tended to be traders who were unaware of the steps involved in the onboarding process, and only became aware after conversations with third parties. For example, some only realised they needed an EORI number to buy or sell goods overseas when informed by freight forwarders or fast parcel operators.

Networking and sharing experiences within the industry was also a significant source of information. Some traders gained insight into customs onboarding by speaking to colleagues and industry contacts who had already been through the process.

Some traders sometimes searched beyond national borders for guidance on customs onboarding. One trader, whose suppliers were in the Netherlands, felt the Dutch government’s website offered an alternate perspective on importing and exporting procedures. This trader also felt that it provided a broader understanding of trade processes.

Another trader spoke to their Mexican suppliers to help them source information on shipping and potentially recommend a customs agent to them for further support.

5.3 Comparing GOV.UK with other information and guidance

Traders found value in both GOV.UK as well as third-party sources when seeking information on the customs onboarding process. However, the 2 sources served different purposes and had different strengths.

For some traders, GOV.UK was their only go to source of information and guidance.

“I don’t know where Google would have led us other than to HMRC. I doubt [we] would have trusted anything else.” (Export only, Trades with Rest of World only, no active declarations)

Some traders used information from GOV.UK for a comprehensive overview of what they needed to start importing or exporting. They then looked for further guidance (often practical or industry specific) via third-party websites. The usefulness of each depended largely on the specific needs and context of each trader.

“The HMRC website is the skin and bones, it’s definitely what you need to start; [online forum] provided the personal, additional, human side… expectations of timelines and what could go wrong.” (Import only, Trades with Rest of World only, Consigned only)

The length of time a trader has been established may influence how they seek information and guidance on customs onboarding. Newer traders (established for 3 years or less) were more likely to shop around for information and guidance, seeking out multiple sources.

In comparison, traders who had been operating for longer tended to consult a smaller range of trusted sources. They were more likely to seek out official guidance from GOV.UK or to seek professional advice from an accountant or intermediary.

5.4 GOV.UK step-by-step guidance: Awareness and usage

GOV.UK provides step-by-step guidance on exporting and importing via 2 specific webpages. On each of these, a checklist of the key actions traders need to take when they are moving goods into and out of the UK is provided. A prompted recall exercise was incorporated into the interviews. Traders were shown screenshots of the pages to test familiarity.

Overall recall of the pages was low, with most traders interviewed stating that they had not previously seen or used them. Traders with no recall of the pages generally received them positively. They tended to express that they would have used the step-by-step pages if they had known about its existence.

The few traders who were familiar with the step-by-step pages had mixed views on how useful these were. Most were positive about their experiences of using the pages. They appreciated the layout of the information and felt the simple, ordered structure gave a clear outline of actions they would need to take to begin importing and exporting.

In comparison, a handful of traders acknowledged that whilst the pages provided direction, they were not detailed enough. These tended to be traders who were looking for guidance specific to their particular needs, or around the products they were seeking to trade.

5.5 Seeking support with the customs onboarding process from intermediaries

Most traders in the sample decided not to use an intermediary to support them with customs onboarding, choosing instead to complete the process independently. For the majority of cases, cost was a key influencing factor. These traders outlined that they preferred to avoid intermediary fees and handle the process themselves.

“I don’t really like paying other people money for stuff I can do myself.” (Import and Export, Trades with EU and Rest of World, Consigned only)

In many cases, traders felt confident enough to complete the necessary steps independently and felt there was no need to use an intermediary. In a very few instances, traders were unaware of intermediaries.

“There was no need – all the information is already there; we wouldn’t have wanted to spend money on a consultant telling them what we could find out ourselves. We knew that we would be operating on such a microscopic scale - we weren’t willing to spend money unnecessarily.” (Export only, Trades with Rest of World only, No active declaration)

A few traders used intermediaries to support them with customs onboarding. These traders tended to do so due to a lack of confidence in handling unfamiliar processes on their own. They found reassurance in the process being handled by an expert on their behalf.

Amongst traders that did use intermediaries to support with customs onboarding, convenience was a key factor that influenced their decision. For these, using an intermediary to handle the process enabled traders to dedicate time to their day-to-day business operations. For some traders, using an intermediary addressed concerns about compliance and reduced the risk of mistakes being made.

Traders that used intermediaries to support with customs onboarding frequently cited using accountants, freight forwarders, couriers, and fast parcel operators. A few traders mentioned using a customs agent to help with onboarding. Traders tended to find intermediaries through word of mouth and recommendations, or via their own research. A few were connected to intermediaries via customers and clients or via supplier agreements. 

Intermediaries generally provided gatekeeper support, ensuring the traders provided the correct information needed by HMRC. Traders did not feel that their understanding of the onboarding process was significantly enhanced by using an intermediary.

One or 2 traders suggested that the need for intermediaries could be reduced if information on GOV.UK was made more user-friendly.

6. Registering for a Government Gateway account

6.1 Registering for a Government Gateway account: Awareness

Most traders interviewed were aware that they needed to register for the Government Gateway to begin the customs onboarding process. Many already had a Government Gateway account for other trader related purposes such as VAT, PAYE, and Corporation Tax. Some traders mentioned that they found out about the requirement whilst setting up their company or while filing with Companies House.

Traders who were not registered tended to find out about the requirement through their own research or advice from intermediaries or accountants.

6.2 Registering for a Government Gateway account: Experience

Experiences of registering for a Government Gateway account were generally positive. In most cases, traders were unable to recall the specifics of the registration process, often because this had taken place some time ago. The process was felt to have been quick and simple as there were no problematic or challenging elements to registration that traders could report.

“I don’t recall any problems signing up.” (Import and Export, Trades only with EU, Consigned only)

“I think it was fairly simple, it required all of our company information. It was part of setting up the new company.” (Import and Export, Trades with EU and Rest of World, Consigned only)

Whilst registration itself was felt to be simple, a few traders highlighted that they had multiple Government Gateway accounts associated with different aspects of their company. They expressed that managing these at the same time could cause frustration and that they would like them to be combined into one account.

7. Registering for an EORI number

7.1 Registering for an EORI number: Awareness

Awareness of the need to register for an EORI number varied. Some traders were aware of the need to register for an EORI number from the start. In some cases, traders had discovered the need for an EORI number when setting their business up. For instance, when registering their company, they received information from HMRC stating that an EORI number would be required for international trade.

“I’m pretty sure that when we registered the company, HMRC sent a letter saying that if you were trading internationally, you would need an EORI number.” (Import and Export, Trades with EU and Rest of World, Consigned only)

In some cases, trader awareness stemmed from knowledge of international trade or from their colleagues’ previous professional experience. Other sources that informed awareness included advice from their accountants and discussions with industry peers.

Several traders discovered the need for an EORI number through online research. They often encountered this when they started exploring the possibility of international trade. The sources of this information varied, with some traders relying on official government resources like GOV.UK, while others relied on general internet searches.

One trader reported that they found out about the need for an EORI number whilst registering through the Government Gateway. When registering, there was a question which asked whether they had plans to import or export. The trader was directed to the EORI webform after selecting ‘yes’.

Some participants only learned that they needed an EORI number once they started trading internationally. Suppliers, manufacturers, or logistics firms usually brought this to their attention, explaining to them that an EORI number was essential.

“The first time I found that there would be a problem was when I first placed an order with a company with us for years to get flat bottles in Germany. And they just said, we can’t send it to you. Okay, you need to register and get your, your EORI… I didn’t even know what that was.” (Import only, Trades only with the EU, Consigned only)

These instances highlight that third parties involved in operations, including suppliers, manufacturers, customers, and logistics companies, play a crucial role sharing information. In particular, key requirements such as the need for an EORI number, especially to traders new to international trade.

7.2 Registering for an EORI number: Experience

As with registering for a Government Gateway account, most traders in the sample found it difficult to recall the EORI registration process in detail. Most felt that the process was straightforward as they were unable to pinpoint any particular challenges or problems with the process.

“I think there were one or 2 steps where I might have to read up just to confirm the choices I was making, but nothing that was confusing. It was relatively clear. There were enough instructions on the website, I just had to go back and work out how that applied to my business and what I was going to be doing. It probably could not have been made clearer.” (Import only, Trades only with the EU, Consigned only)

Traders found it easy to gather the information required to apply for an EORI number such as a Unique Taxpayer Reference number, VAT number and National Insurance number.

When registering for an EORI number, most traders completed the online form independently and within a few minutes.

“Very simple, very brief… The platform was easy to navigate.” (Import and Export, Trades only with the EU, Consigned only)

The time taken to receive an EORI number varied and, in most cases, arrived between 24 hours to a few days after applying. Applying for and receiving an EORI number generally met or exceeded traders’ expectations.

Having applied online, some traders expected the process to be quick and were satisfied with the outcome. Some anticipated a long wait, often due to perceived government bureaucracy and were pleasantly surprised by the simplicity and speed of the process.

“It was probably a bit more straightforward than what I thought it to be.” (Import only, Trades only with the EU, Consigned only)

While the majority of traders interviewed found the process of completing the EORI webform straightforward and clear, a handful encountered complexities. For example, one trader had difficulty linking their VAT and EORI number due to a change in their VAT registration status.

“Linking to VAT was problematic. I couldn’t do that myself.” (Import only, Trades only with Rest of World, Consigned only)

Another trader expressed frustration about the requirement to provide a Unique Taxpayer Reference during the EORI registration process. They felt that this was information that HMRC should already have and stressed a need for more ‘joined-up’ systems.

7.3 EORI registration amongst traders not engaging in international trade

Some traders that apply for EORI numbers are not trading internationally. There are 2 types of traders that fall into this category:

Some businesses apply for EORI numbers with no intention of trading internationally. When recruiting for the research we identified a small number of businesses that had an EORI number but did not consider themselves to be international traders. These were businesses that had bought goods from outside the UK and required an EORI to bring these goods into the UK. Whilst importing alone does require an EORI number as a function of international trade, these businesses were importing goods infrequently rather than regularly trading. 

These businesses were not eligible to take part in the research as they did not meet the criteria of having begun trading internationally. However, during the recruitment screening process their responses were recorded and noted. An example of this was a business that registered for an EORI number to enable the purchase of furniture from the EU on a one-off occasion. This business did not see themselves as having any tangible goods or services to trade and had no intentions to start trading internationally in the future.

Some businesses register for an EORI number ahead of time, to prepare for future trading activity. One interview participant was a business that applied for an EORI number but did not have immediate plans to trade internationally. They intended to export their products in the future and had applied for an EORI number in preparation for this. This finding is consistent with a HMRC hypothesis that a small number of customers are taking similar steps to plan and prepare their future trade activity.

Case study: The EORI registration process for a domestic trader

Trader profile: A small and medium-sized enterprise operating domestically for more than 10 years. They recently started thinking about widening their product range and targeting new markets (North America, Australia, New Zealand, and parts of the European Union). They do not envisage trading internationally for 6 to 12 months, whilst they get themselves ready.

EORI registration: They applied for an EORI in preparation to trade internationally. They already had a Government Gateway account set up for tax purposes but did not realise its link with customs. They were advised to get an EORI number by a fast parcel operator they have been speaking to.

Initial expectations: They did not know what to expect from the process. Unfamiliarity made the process feel as though it could be daunting. They anticipated it to be time-consuming and difficult.

Information and guidance: The fast parcel operator was on hand to advise them on the process. As a result, they did not feel the need to consult GOV.UK for information or guidance.

Overall impression: They were unable to recall the process in detail but put it down to being straightforward. The experience was quick and hassle-free. They were pleasantly surprised.

7.4 Costs and delays in EORI registration

Whilst the EORI registration process was generally felt to be efficient, unexpected issues occasionally arose which caused disruptions to business operations.

For example, one trader faced a significant delay while waiting to receive their EORI number. They reported experiencing a delay of approximately 2 to 3 weeks in obtaining their EORI number after applying. This resulted in them temporarily being unable to purchase containers for some of their products from a European supplier.

This trader outlined that this led to lost revenue alongside potential reputational damage with regular customers. The delay also forced the trader to temporarily alter its operations, relying on customers bringing their own containers until new stock arrived.

The few traders that experienced problems or delays with the EORI registration tended to wait for these to be resolved rather than seeking help from HMRC or other sources.

8. Subscribing to HMRC Customs Declaration Systems

8.1 Context: Changes to HMRC Customs Declaration Systems

The Customs Handling of Import and Export Freight system, which manages the movement and declaration of goods into and out of the UK, is being phased out by HMRC. In its place, the Customs Declaration Service has been introduced as the new UK customs platform, offering a fully digitised service. Since its introduction in 2018, the shift to the Customs Declaration Service has been executed in phases across imports and exports:

For imports: As of October 2022 onwards, import declarations are no longer managed in the Customs Handling of Import and Export Freight system. These have been moved to the new Customs Declaration Service system.

For exports: The introduction of the Customs Declaration Service for export declaration is being phased in. Some high-volume declarants moved Goods Vehicle Movement Service (GVMS) export declarations to the Customs Declaration Service for exports by 30 November 2023. All other traders should move to the Customs Declaration Service for exports by 30 March 2024. Migrations to the system are expected to start at the beginning of the year.

Traders who participated in this research may have used either the Customs Handling of Import and Export Freight system or the Customs Declaration Service. This is because traders that onboarded between 16 August 2018 and 30 September 2021 had the option to choose which system to subscribe to. Those that onboarded after 1 October 2022 have been automatically subscribed to the Customs Declaration Service.

8.2 Awareness and recall of the Customs Handling of Import and Export Freight system and the Customs Declaration Service 

There was a noticeable lack of awareness and recall of the Customs Handling of Import and Export Freight system and the Customs Declaration Service amongst traders. Traders generally had difficulty recalling the process of subscribing to HMRC’s customs declaration services and tended to be unfamiliar with them. Many traders interviewed were unsure if they were subscribed to one system or the other.

“I can’t recall… I just know I was involved with CHIEF (the Customs Handling of Import and Export Freight system), then something happened to get onto CDS (the Customs Declaration Service).” (Import only, Trades only with the EU, Consigned only)

The few traders who used intermediaries to support the customs onboarding process were unsure on what system they had subscribed to. They tended to assume this level of detail was handled by their intermediary.

“I think this level of detail is handled by [logistics provider] for us.” (Import and Export, Trades only with the EU, Consigned only)

A few traders wrongly thought they did not need to subscribe due to certain conditions, such as having a Free Trade Agreement or using a shipping and handling service. This lack of awareness poses a small but real risk of some traders being unintentionally non-compliant with customs regulations. It suggests a need for increased information and awareness-raising around the Customs Declaration Service.

8.3 Experiences of interacting with the Customs Handling of Import and Export Freight system or the Customs Declaration Service

Very few traders were able to clearly recall any interaction with the Customs Handling of Import and Export Freight system or the Customs Declaration Service. Amongst the few that were able to provide accounts, experiences varied.

One trader described setting themselves up on the Customs Handling of Import and Export Freight system as ‘very easy’. In comparison, another expressed frustration at having to purchase suitable software to use the Customs Declaration Service. For another trader, challenges with the Customs Handling of Import and Export Freight system and the Customs Declaration Service arose after changes in their trader status. 

Case study: Experiencing challenges with HMRC Customs Declarations Systems

Trader profile: A small and medium-sized enterprise in the horticulture sector that has been established for 3 years and imports products from the European Union. These products are sold on to UK customers.

As an experienced trader they previously completed the customs onboarding process with no issues or difficulties. As well as engagement with HMRC, the trader had been in contact with the Department for Environment Food and Rural Affairs (DEFRA) to obtain phytosanitary certification to enable it to bring its stock into the UK.

The Customs Handling of Import and Export Freight system and the Customs Declaration Service experience: The trader was previously set up as a sole trader in 2020. They had the choice of subscribing to either the Customs Handling of Import and Export Freight system or the Customs Declaration Service. The trader decided to use the Customs Handling of Import and Export Freight system.

In early 2022, after a period of growth, the trader took on staff and became a limited company. This change in status meant they had to register for a new Government Gateway ID and relink their accounts.

As part of the onboarding process the trader needed to re-register to the Customs Handling of Import and Export Freight system. However, it was unable to link its new Government Gateway account to the system. This left the trader at risk of potential delays in acquiring stock.

Resolution: The trader perceived the issue as stemming from HMRC systems. They requested support from DEFRA, who liaised with HMRC to verify the change in status and asked for the correct linkage to be set up. This approach resolved the issue.

9. Applying for customs authorisations

9.1 Awareness, understanding and use of customs authorisations

There were considerable differences in the understanding and application of customs authorisations amongst traders. Most participants interviewed indicated that they did not apply for customs authorisations. This tended to be due to a lack of awareness of authorisations and how they could benefit them. 

“I don’t think I have a clear idea of what these customs authorisations are.” (Import only, Trades only with the EU, No authorisations)

“I was unaware of the ones that were available…I guess if there was something that could’ve made it easier or simpler, then yes, we would’ve looked at it.” (Import only, Trades only with the EU, No authorisations)

In some cases, traders assumed that their operations were too small or not complex enough to benefit from customs authorisations. These traders tended to understand the benefits of authorisations but felt it did not make commercial sense to apply. This was due to the current scale of their operations and associated costs.

“No, I’m operating on too small a scale. Probably won’t do this.” (Import only, Trades only with the EU, No authorisations)

There was also some confusion as to what customs authorisations were, with some traders misunderstanding postponed VAT to be a type of customs authorisation.

9.2 Applying for customs authorisations

The few traders that applied for their own customs authorisations applied for duty deferment accounts. Cost savings and supporting cash-flow were mentioned as motivators for applying for a duty deferment account. Avoiding administrative fees charged by couriers and the financial advantages of deferring the payment of customs duties such as excise duty and import VAT were also a key driver for applying.

In general, it was felt that whilst applying for a duty deferment account was time-consuming, it was not seen as an overly complex process.

There were a handful of cases in which traders felt that the process of applying for customs authorisations could have been a little clearer.

“It was a little bit jargony. I had to look a lot of things up.” (Import only, Trades only with the EU, Consigned only)

“The process is a little bit difficult. They don’t exactly tell you what is required, it’s guesswork.” (Import only, Trades only with the EU, Consigned only)

Occasionally traders find there can be complications when applying for authorisations. For example, one trader found they were unable to link their existing duty deferment account to their new EORI number and reached out to HMRC for support. They were advised to close their old duty deferment account and open a new one under their new EORI number. This process turned out to be more complex than they had anticipated. As a result they stopped using their duty deferment account entirely.

9.3 Using customs authorisations through an intermediary

A handful of traders applied for customs authorisations through an intermediary. Convenience and simplicity were cited as the key factors that influenced their decision to do so. Using authorisations in this way means that any complexities that may arise are handled by intermediaries.

Using authorisations through an intermediary can also help to minimise potential delays or mistakes. This support allows traders to allocate more time to focus on the day-to-day running of their businesses.

10. Seeking support with challenges during the customs onboarding process

10.1 Challenges to completing the customs onboarding process

Most traders in the sample found the customs onboarding process to be straightforward. However, occasionally some aspects could be more complicated or challenging. Whilst problems were not frequently encountered, traders shared a handful of occasional ‘pain points’ within the onboarding process. These challenges are compiled from the findings from previous sections.

A few traders experienced challenges after becoming VAT registered, which required them to link their new VAT number to their EORI number. This tended to be difficult to do, causing some confusion and frustration. Whilst delays in receiving an EORI number were not common, this led to disruptions in operations for a handful of traders.

A handful of traders felt overwhelmed by the volume and complexity of information available from GOV.UK. They also tended to feel that navigation across GOV.UK was difficult. Many traders used search engines as a shortcut to direct them to the information they were looking for. This was rather than having to use the GOV.UK search function.

Many traders interviewed lacked awareness and knowledge of the Customs Declaration Service and customs authorisations. Some traders also felt that it can be slow and difficult to reach HMRC when seeking support with an onboarding problem or query. This may suggest the need for increased or more visible introductory information.

10.2 Seeking support with the customs onboarding process

Traders had mixed experiences of seeking support from HMRC when problems or queries arose during the onboarding process. A few traders got the help that they needed via GOV.UK or through their email and telephone customer service. More often, traders found interactions with HMRC (online and by phone) to be frustrating.

The advice given by HMRC was sometimes seen as unhelpful or not directly addressing the issue at hand. For example, as mentioned previously, one trader reported frustration with being advised to close their old duty deferment account and open a new one, a process they found complicated. This led them to cease using their duty deferment account altogether.

Difficulty reaching support was raised as key issue. Some traders reported facing very long wait times on HMRC’s helpline and online chat function. A few reported being unable to reach anyone who could help them. However, it is not clear which of the various helplines covering HMRC’s wide range of processes participants are referring to.

“When you email HMRC they are not very quick at replying. They have an online chat, but it always says it is too busy. I wanted to talk to someone, and I couldn’t get through… Then when you do get through, they don’t know what you are talking about. You just have to think, I have to sit and listen to this music for 2 hours.” (Import only, Trades only with the EU, Consigned only)

In addition, traders were typically unable to recall which helpline they contacted, perhaps highlighting that contact points could be made clearer.

Some traders described GOV.UK as challenging to navigate. This in turn made it difficult for them to find information to support them through the onboarding process.

A few traders expressed a desire for more tailored, personalised support from HMRC. A few mentioned being directed to generic information on the HMRC or GOV.UK webpages, which were unhelpful and lowered their satisfaction with HMRC. One or 2 suggested alternative solutions such as a trouble-shooting questionnaire or Artificial Intelligence systems that could provide advice based on their specific business needs.

Some traders decided against contacting HMRC for support based on the assumption that it would not be helpful to do so. Instead, they tended to find their own solutions. For some this was primarily through online research, whilst others consulted accountants.

Several participants reported turning to suppliers and shipping agents for advice. However, they noted that their guidance did not always resolve the issues they were facing.

11. Impacts arising from the customs onboarding process

Traders reported both positive and negative experiences of the customs onboarding process and its impact on their business.

11.1 Positive impacts arising from the customs onboarding process

Most traders found the customs onboarding process to be straightforward. They typically felt no adverse changes or impacts had resulted from going through the process.

The primary positive impact of the customs onboarding process was that it was a means of facilitating international trade. Having embarked on the process, traders had the necessary procedures, registration, and compliance measures in place to import or export as intended.

For the majority of traders in the sample, customs onboarding was a simpler than expected process. Some elements in particular (for example, Government Gateway and EORI registration) were felt to be less complex than initially anticipated.

11.2 Negative impacts of the customs onboarding process

A handful of traders, especially smaller ones with fewer resources, found the onboarding process time-consuming, diverting time from their core operations. Though necessary for international trade, the process temporarily consumed their time and shifts focus from other tasks they consider to be more important or pressing.

Some costs were also incurred by traders because of undertaking the process. Examples include the cost of new software systems to enable the use of customs declarations systems, and fees for engaging intermediaries.

Whilst intermediaries can support traders to streamline the customs onboarding process, using a third-party means introducing an extra layer of communication. This introduces a need for traders to liaise with the intermediary which can impact on traders’ time. In addition, whilst intermediaries can provide valuable support to traders, this comes at an additional financial cost.

In a very few cases, delays in receiving EORI numbers led traders to make temporary changes to their operations. This can be challenging if a delay means a trader cannot import goods to fulfil stock or orders and can have financial impacts. Delays in receiving EORI numbers are not commonplace. However, lack of awareness of the need to apply for an EORI number in the first instance means some traders are unprepared for potential delays and unable to plan ahead.

12. Conclusions

This report provides an exploration of traders’ experiences with the customs onboarding process. Whilst the process overall is generally perceived as straightforward, certain aspects present challenges.

12.1 Expectations of the customs onboarding process

Participants held a variety of expectations heading into the customs onboarding process, which were sometimes influenced by prior experiences with HMRC or other government departments.

Some anticipated a complex and time-consuming process, whereas others, especially those with more administrative experience, anticipated a more straightforward process. This suggests a possible need to review communication strategies on customs onboarding to reassure traders about the level of complexity involved in the process.

There were also differences in how prepared and equipped traders felt to deal with customs onboarding. Those with prior experience of trading internationally or more administrative expertise may be better equipped to navigate the process. This suggests a need for increased or simplified guidance on the customs onboarding. Increasing the visibility of the step-by-step guidance pages may help to address this issue.

12.2 Seeking information and guidance on the customs onboarding process

HMRC’s step-by-step guidance pages currently have low awareness amongst traders, however, those that have seen and used these resources found them to be user-friendly and helpful.

Traders have expressed that if they had known about these guidance pages, they would have used them. The positive feedback on the step-by-step guidance pages indicates that they are a valuable resource and that traders are open to using online resources. This could be leveraged in future initiatives. The low visibility of these pages indicates that targeted marketing or communication strategies may be needed to increase trader awareness.

Information on GOV.UK played a key role in guiding traders through the onboarding process, however, experiences with these platforms varied. Some traders found the information clear and helpful. Others described difficulties navigating the webpages or felt overwhelmed by the volume and complexity of the information.

This suggests a need to review and simplify the information on GOV.UK. This could involve breaking down complex information into simpler terms or providing a summary of key points. It also suggests a need to consider improving the navigability of GOV.UK to enhance user experience. This could involve reviewing the labelling of sections and search function to help users find information more easily.

12.3 Registering for a Government Gateway account

The majority of traders interviewed were aware of the need to register for a Government Gateway account to initiate the customs onboarding process.

Some already had an account for other business-related activities. Registration experiences were largely positive, which illustrated that the process is generally user-friendly. However, a few traders expressed frustration due to managing multiple Government Gateway accounts tied to different aspects of their business. This may suggest a need for a more streamlined system to allow traders to manage their different accounts more easily in one place.

12.4 Registering for an EORI number

Most traders in the sample felt that the EORI registration process was straightforward and efficient, however, some areas could be improved.

Some traders faced the challenge of being unable to link VAT and EORI numbers. Others did not know that they needed an EORI number to trade internationally. They only became aware when they experienced issues with orders and shipments or were advised by a third-party (such as a freight forwarder). Traders could benefit from clearer guidance on some topics related to EORI numbers (such as how to link a VAT account). There may also be a need to improve communication and information resources about the requirement for an EORI number among traders.

12.5 Subscribing to HMRC Customs Declaration Systems

There is a lack of clarity amongst participating traders regarding subscriptions to the Customs Handling of Import and Export Freight (CHIEF) system or the Customs Declaration Service (CDS).

Some traders could not recall their subscription status, while others were unsure about what these systems entail. Traders’ confusion or lack of memory about their subscription to CHIEF or CDS could mean that they are not fully leveraging these systems. This could lead to delays, increased costs, or even compliance issues. This finding suggests a need to improve and target communications about these systems and the importance of subscribing to them.

12.6 Applying for customs authorisations

The understanding and use of customs authorisations varies significantly amongst traders. Most traders interviewed did not apply for authorisations, due to lack of awareness or a perception that their operations are too small to benefit. Additionally, for some traders an expectation that applying for authorisations will be difficult and complex may deter take-up.

The few traders that did apply for customs authorisations chose duty deferment accounts for the benefits of cost savings, cash-flow support, and avoiding administrative fees. Amongst these, the application process was considered time-consuming but not overly complex. A very small number of traders chose to use authorisations through intermediaries for convenience and simplicity.  

These issues may suggest a need for more information and guidance about customs authorisations to help traders better understand them. Strategies to encourage take-up of authorisations could involve increasing educational materials, conducting workshops, or partnering with intermediaries to inform traders about the potential benefits.

12.7 Seeking support with challenges during the customs onboarding process

Traders highlighted that it is sometimes difficult to reach HMRC for support with queries or issues during the onboarding process.

This may point towards a need to review currently available contact and customer service channels. Providing additional support, such as introducing chatbots or Frequently Asked Questions sections on GOV.UK could reduce response times to common queries.

12.8 Impacts arising from the customs onboarding process

Whilst the customs onboarding process was positive for most traders, in a few cases it was accompanied by some unintended negative impacts.

On the positive side, the customs onboarding process was generally felt to be straightforward and enabled traders to reach their intended objectives of trading internationally. These findings suggest the processes involved in customs onboarding are well-designed and that for most traders the process works as intended.

However, a few traders also reported negative impacts. The administrative tasks and time spent on the process were seen by some as a diversion from their day-to-day operations.

Some additional costs were incurred, such as the need for new software systems for customs declarations and fees for intermediaries. Some traders also experienced delays in receiving EORI numbers, leading to temporary operational changes and potential financial impacts. Establishing a feedback loop where traders can share challenges and suggestions with HMRC could help avoid ‘pain points’ in the customs onboarding process.

13. Annex A: Key recruitment segments

Number of interviews by business age

Business age	Number of interviews
Less than one year	1
One to 3 years	17
3 to 5 years	4
More than 5 years	11
Total	33

Number of interviews by business size

Business size	Number of interviews
Sole trader or zero employees	4
Micro (1 to 9 employees)	26
Small (10 to 49 employees)	3
Total	33

Number of interviews by trading activity

Trading activity	Number of interviews
Import only	18
Export only	7
Both import and export	7
No activity	1
Total	33

Number of interviews by trading regions

Trading regions	Number of interviews
EU	13
EU and Rest of the World	8
Rest of the World	11
No activity	1
Total	33

Number of interviews by average consignments per month

Consignments per month	Number of interviews
Zero	1
Less than one every other month	7
At least one every other month but less than one every month	10
Between one and 5 per month	10
More than 5 per month	5
Total	33

Number of interviews by declarations

Trading regions	Number of interviews
Consigned only	30
Consigned and declared	1
No activity	2

14. Annex B: Topic Guide

Please see separate attachment for Annex B: Topic Guide.