Research and analysis

HMRC Customs Administrative Burden: Qualitative research report (2023)

Published 15 July 2025

This report was commissioned under the Conservative administration (2010 to 2024), and conducted in 2023.

HMRC Research Report 807.

Prepared by Ipsos (Amrita Sood, Kath Bailey and Jacob Bellamy) for HMRC.

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

1. Executive summary

1.1 Background

Ipsos was commissioned by HMRC to undertake a survey to update HMRC’s Customs Administrative (Admin) Burden (CAB) estimates. The quantitative survey explored the time and cost burden associated with submitting 15 different declaration types.

This qualitative follow-up research, involving 30 participants from the survey, further explored five key areas:

• comparison between EU and Rest of World (RoW) trade

• seniority of staff handling declarations

• understanding border delays

• differences between simplified and full declarations

• disparities between import and export declarations

Findings from these interviews are presented in this report. Please note that the views expressed by participants may not be reflective of the wider trader population.

Key findings

• businesses were reliant on intermediaries to submit declarations, and as a result did not have a detailed knowledge of the processes involved in submitting declarations
• businesses’ use of intermediaries meant they did not perceive a significant difference in burden between EU declarations and rest of world declarations
• the burden of trading with the EU was high in the initial transition period, but was felt to have fallen broadly in-line with the burden for the rest of world trade
• senior staff were often involved in submitting declarations in smaller businesses due to necessity, and the perceived risk of getting things wrong
• delays at the border were not attributable to HMRC, and businesses felt they did not receive clear information on the types and nature of delays
• businesses did not understand the differences between full and simplified declarations, and tended to pass the same information to their intermediaries regardless of declaration type
• it was easier to import or export goods when businesses understood the processes, did them regularly, and had good relationships with intermediaries and customs agents

2. Research context, aims and methodology

2.1 The Customs Admin Burden survey

Ipsos was commissioned by HMRC to undertake a quantitative survey to update HMRC’s CAB estimates. The survey ran between 24 January and 3 March 2023 and qualitative fieldwork took place in October 2023. The qualitative research described in this report was conducted as a follow-up to the CAB survey. The quantitative survey explored the time and cost for businesses to submit 15 different customs declaration types and obligations, involving:

• breaking down activities associated with submitting declarations, such as preparing information, into six categories

• asking traders to estimate the time spent on each of these activities

• adding together time spent on these six activities to estimate total time burden

• conversion to a cost burden via wage data from the Annual Survey of Hourly Earnings (ASHE)

The aim of the survey was to estimate the burden on traders associated with submitting declarations. It did not aim to produce estimates on the total time taken to submit different declarations. For example, if a trader spent 30 minutes collecting information to submit to an intermediary, who then took 20 minutes to submit a declaration, only the first 30 minutes was recorded in the survey. This was to understand how easy or difficult it was for traders to handle declarations with the tools and services currently available to them, which includes intermediaries.

2.2 Aims of the qualitative research

The qualitative follow-up involved in-depth interviews with 30 traders who had taken part in the quantitative survey. It aimed to deepen the understanding of five areas from the survey, and help refine any future waves of the CAB research:

Comparing EU and RoW trade

In the quantitative CAB survey, around a quarter of traders felt the time taken for preparing information for customs declarations was longer when moving goods to the EU than rest of the world. The qualitative interviews included businesses that had answered in this way, to explore the reasons behind their experiences.

The seniority of staff who are completing declarations

The survey found a high proportion of senior employees responsible for working with declarations. The qualitative research looked in more detail at the job roles and titles of those submitting declarations or working with intermediaries.

Understanding border delays

More than eight in ten traders experienced some kind of delay when clearing customs. The qualitative research examined the nature of delays and their impact.

Differences between simplified declarations and full declarations

The survey did not find large differences between the burden of simplified declarations and full declarations. The qualitative research explored what business’s perceived as the key differences between them.

Import and export declarations

The qualitative research aimed to explore in more detail the differences between working with import and export declarations.

2.3 Sample framework and interview methodology

The sample framework was drawn from respondents who took part in the survey and agreed to be recontacted. These were then filtered by the five topic areas of interest. Businesses had to meet at least one of the following five characteristics, based on survey responses:

• responded that EU declarations took longer to submit than RoW declarations
• employed at least some senior staff to work with declarations
• experienced delays at the border
• worked with both simplified and full declarations
• worked with both import and export declarations

This produced a total sample frame of 419 unique leads. These could be broken down into the areas of interest as follows (split out by declaration volume):

Table 1.1: Sample frame across areas of interest by total number of custom declaration volume*

	Low (<300 per annum)	Medium (between 300 and 3,000 per annum)	High (>3,000 per annum)	Don’t know	Prefer not to say	Total
Comparison between EU and RoW	50	12	1	0	1	64
Staff seniority	85	2	0	0	0	87
Delays at the border	231	55	11	6	1	304
Differences between simplified and full declarations	56	25	4	0	0	85
Disparities between import and export declarations	66	20	5	0	1	92

*Please note that businesses could fulfil multiple areas of interest, hence the above table shows leads greater than the total unique leads (419).

Businesses that met more criteria were targeted before moving on to those that only met one or two criteria of interest. A quota was applied for a minimum of 6 interviews across each topic area, with an emphasis on high-volume declarants. However, these were difficult to target, as they made up a small portion of the sample frame (see Table 1.1).

In total, 30 interviews were conducted. These were split as per Table 1.2. There was variation in business sector across the interviews, including chemicals, bathroom goods, hardware, food and beverages and waste management services. In total 6 businesses with more than 250 employees were interviewed, although larger businesses did not always have the highest declaration volumes. One large firm submitted just 250 declarations per year.

Table 1.2 Achieved interviews*

Topic area	Low declaration volume (<300 per annum)	Medium declaration volume (between 300 and 3,000 per annum)	High declaration volume (>3,000 per annum)	Total interviews
EU vs RoW trade	3	2	0	5
Staff seniority	4	1	0	5
Border delays	3	4	1	8
Supplementary vs full decs	1	2	3	6
Import vs Export decs	3	2	1	6
TOTAL	14	11	5	30

*Please note that though most businesses were interviewed across multiple areas of interest, they have been assigned just one for the purposes of the quota.

2.4 Limitations to the findings

Participants were allocated to topic areas according to their survey responses. However, in some cases participants’ knowledge of the relevant topic was low, and they were unable to answer all of the questions.

The achieved interviews reflect the quota for which the participant was interviewed. However, some participants were asked about other topic areas where their level of knowledge on the one for which they recruited was low.

Due to low level of understanding surrounding types of declarations, we cannot be certain that participants understood the differences between these declaration types.

More broadly, the qualitative research found that participants were unable to provide more detail on some answers from the survey. The implications of this are discussed further throughout the report.

As this was qualitative research, the views expressed by participants may not be reflective of the wider trader population.

2.5 Note on the analysis

As some participants had a low understanding of some topic areas and declarations discussed in the interviews, the findings in this report are presented as participants understood them.    

Where participants did not have direct evidence of a reported experience, this has been analysed as speculative and indicated through terminology such as ‘participants thought that…’ or ‘businesses felt that…’. Participant speculation was more common in the context of:

• Understanding the difference between simplified and full declarations.
• Delays at the border, where participants made assumptions about what was causing these delays.

This has been flagged at the start of the relevant section.

3. EU vs Rest of World declarations

3.1 Summary

The key findings in this section are:

• businesses’ reliance on intermediaries meant they did not perceive a significant difference in burden between EU declarations and RoW declarations
• however, they did perceive a difference in the overall time and difficulty of trading with the EU compared to the RoW
• businesses felt that the time taken to trade with EU countries, including time spent on declarations, would not reduce significantly in the future
• businesses had taken action to try and reduce the burden of EU trade, including the set-up of entities based in the EU

In the quantitative survey, around a third of participants felt that it took longer to submit declarations to the EU than RoW.[1] These businesses made up the sample frame for the section of qualitative research looking at potential causes. Importantly, these businesses had described themselves in the survey as submitting at least some declarations in-house.

The qualitative research found that businesses felt that the difference in burden between declarations for the EU and RoW was broadly similar. In many instances, this was because businesses were reliant on the use of intermediaries to manage declarations for them. This was even among businesses describing themselves as working with declarations in-house. It meant they were unable to answer questions on the distinctions between declarations for one trading area and another with confidence or accuracy.

3.2 There was some common sentiment that overall time taken to trade with the EU was longer than the RoW, although this was not universal

Businesses noted that the difference in declaration burden was not significant between the EU and RoW. However, they did perceive a difference in the overall time and difficulty of trading with the EU compared to the RoW. Some businesses, usually micro or small-sized businesses, thought this extra time taken was because the EU required extra customs detail that RoW countries did not require.

“There’s got to be ‘i’s dotted and ‘t’s crossed (…) it takes forever to get the template together for everything you need (in the EU).”
Participant, micro business.

Other businesses reported that EU imports and exports were more likely to result in delays compared to RoW imports and exports. One explanation was the existence of a ‘funnel point’ through France to send goods via road into all EU countries, compared to sending to RoW where they could travel directly.

“If you’re shipping to the rest of the world, say Canada, you’re going direct.  If you’re shipping to Belgium it goes to a border in France… It’s the sheer volume of goods coming from the UK through one or two points.”
Participant, micro business.

While businesses felt that the burden associated with EU declarations was not dissimilar to the rest of the world, they noted that burden had been lower before the UK’s exit from the EU. Businesses found this increase in the burden of EU trade frustrating, while the burden of RoW trade had not changed. The perception of the burden of EU declarations was therefore felt to be greater by comparison with pre- EU Exit rules, not by the current RoW burden.

“Before Brexit, you’d just stick it on a truck and send it across. You didn’t have to worry about paperwork. Sending stuff to Ireland or France is now the same as sending stuff to China or the US – you’ve got to have a commercial invoice, commodity codes, VAT numbers, EORI numbers… The other thing about Brexit is that it was not only a massive learning curve for people in the UK, but we’ve had to educate our customers overseas. They just don’t want to know.”
Participant, medium business.

3.3 Businesses thought that time taken to trade with EU countries would not reduce in future

Businesses thought there had been a reduction in time taken to trade with the EU over the past 18 months, but that any further reductions were unlikely. The main reason for this was increased business knowledge of new trading and customs processes, which had been acquired through a ‘trial-and-error’ approach.

“I am not convinced it got easier over time, I think we adapted and have understood how the French/Dutch operates and I have adapted our paperwork to their way… Typically what happens, you have to try it first, work out your problem, fix those problems and the second load will be fine, the third load will be better. Once you have done three or four loads it will be fine.”
Participant, large business.

This was not just within participants’ own businesses, as some participants noted that intermediaries also had better knowledge and more streamlined processes. As a result, the time taken to gather information for declarations had reduced but was not as low as before the EU exit. It was also not expected to reduce significantly with additional time.

“It is better than it was.  (During) Brexit there weren’t enough people who understood the process… it was incredibly difficult for forwarders, even they would freely admit they didn’t understand what was needed.  Now there are more agents in place.”
Participant, medium business.

“The process is (now) as streamlined as possible and staff are trained up in it. So after the first 6 months of getting used to it, (it will) continue as is for the foreseeable future.”
Participant, small business.

3.4 Businesses had acted to try and reduce the burden of EU trade

The extent of these actions varied, but businesses felt they had to take steps to reduce the burden of EU trade. This might involve:

• informing customers about increased risks of delays and longer lead times for receiving products
• in-house training, including researching how to fill in forms online, streamlining internal processes for choosing commodity codes, and creating step-by-step guides for staff
• developing new systems to liaise more effectively with intermediaries
• establishing relationships with EU-based warehousing agents or other customs agents
• looking into setting up a business entity in an EU country to circumvent administrative and customs burdens

One business outlined how it was setting up entities in the EU to remain competitive:

“We’ve lost quite a lot of our EU exports, and we’re trying to get those back. The way to get those back is to set up entities in Europe. We’ll be more competitive in Europe in the future, but it’s quite a lot of extra admin. We’ve got multiple bank accounts, multiple service accounts… there’s just an extra cost associated with working with the EU.”
Participant, medium business.

One business noted that it invested in agents in countries they exported to:

“(We) now have in-board agents in place in the receiving country and have established very close relationships with the bonded warehouses… the only other thing (we) can do is give people longer lead times and prepare the documents in advance.”
Participant, micro business.

4. Staff seniority

4.1 Summary

The key findings in this section are:

• senior staff in smaller businesses tended to handle declarations due to low employee numbers
• senior staff thought that specific knowledge of customs processes was necessary to work with declarations, to mitigate risk and ensure consistency

4.2 In smaller businesses, senior staff tended to handle declarations due to low employee numbers

In the quantitative survey, there was a larger proportion of senior staff working with declarations than might have been expected. Around 3 in 10 (31%) of staff working on simplified frontier declarations were senior staff. This qualitative research targeted businesses where senior staff worked with declarations.  

In smaller businesses, many director-level employees handled declarations themselves. This was often out of necessity, with no junior or administrative staff available. In these types of businesses, there was less scope for specialisation within roles. Senior staff managed their clients and suppliers, as well as performing the basic administrative tasks. One business, composed of just a father and son, had the father doing all the importing and his son focused on the practical parts of the job.

“(My son) wouldn’t have a clue! He’s never worked in an office, he’s always been on the tools. Show him an invoice and he wouldn’t know whether to look on the back or the front!”
Participant, micro business.

Businesses felt that getting trading documentation correct was very important as it made up a large portion of their costs or earnings. As a result, even in larger businesses, more senior staff tended to handle declarations and intermediaries to lower risk and take responsibility.

“I think it’s a senior level thing because you’re dealing with quite a lot of money.”
Participant, micro business.

“I think also there’s the accountability element of it. If we do it and it’s wrong, it’s our fault. You delegate to somebody else they get it wrong, it then becomes a training issue.”
Participant, micro business.

Even in businesses where senior staff might not be directly involved in pulling together information for declarations, they typically had some involvement in sign-off or review.

4.3 Senior staff also felt that specific knowledge of customs processes was necessary to work with declarations

Participants felt that there was some specific, important knowledge needed when handling trading arrangements, and the declarations involved with them. This was associated with the type of goods being traded, such as knowledge about their commodity codes, working with suppliers, or characteristics of individual countries. This knowledge was felt to accumulate through experience, and as such more senior staff would work on trade. Senior participants also had existing relationships with suppliers, particularly for importing, built up over years in their respective industry. As a result, they tried to manage declarations themselves.

“For instance I could rattle off all the commodity codes that we need to use off the top of my head. So until that feed works correctly I’m reticent to involve other staff so that they have to ensure accuracy.”
Participant, micro business.

However, while traders acknowledged the importance of information involved in submitting declarations, opinions differed on its complexity. Some traders felt that the information intermediaries asked for was manual and complicated, while others felt it was simple. This was dependent on the type of good the company worked with and the systems in place for the trader to interact with the intermediary.

Vignette 1: business with an existing relationship with a supplier

This business was an importer and distributor of manufactured goods, predominantly from Asia. The participant was very experienced in the industry, and had built strong, reliable relationships with suppliers, customers and sourcing managers.

They handled all import and contact work with Asia themselves, while another member of the team handled UK-based logistics and the small amount of work they did with the EU. The overall number of staff was very low with just four staff in the UK and a few managers and Quality Assurance staff in Asia employed as contractors.

The business handled all work associated with imports, including declarations, owing to company size and existing relationships. Their supplier in Asia had previously helped the participant set up shipping in the United States, and they had maintained contact.

“I do the China ones because I’ve known the sourcing manager for years. We’ve tried to break up the company into areas where I deal with the goods before they get here. If it’s in the building it’s not me, outside the building it’s me (who) handles the rest.”
Participant, micro business

The participant described the import element of their business as the ‘cornerstone of the business’. Getting declaration information wrong would prove costly.

5. Delays at the border

5.1 Summary

The key findings in this section are:

• border delays were influenced by a range of factors, including business size, business knowledge of commodity codes and the types or volumes of goods traded
• businesses thought that EU Exit had increased delays in the short term, but that these had improved over time
• delays at the border were not attributable to HMRC, and businesses felt they did not receive clear information on the nature of delays, leading to them making assumptions about the cause
• there were a few small differences reported between UK and EU border delays

5.2 Border delays were influenced by a range of factors

In the quantitative survey, the majority of traders said they experienced delays at the border when importing or exporting. In the qualitative research, a key finding was that border delays were influenced by a range of factors. These included the size of the business, the business’ knowledge of commodity codes and the types or volumes of goods traded.

For example, smaller businesses experienced border delays more acutely. Reasons for this included:

• having a less well-established customer base abroad
• working with less developed data management systems
• a lack of knowledge about the detail required to fill in customs declarations

Smaller businesses reported having a more ad-hoc and less well-established customer base abroad. These smaller businesses felt their less well-established customer base was more likely to look elsewhere for business in the event of delays. They noted that delays affected the extent to which their customers trusted them and would continue buying from them in future. Longer delays resulted in less customer trust, which over time resulted in lower trade.

“(For) customers we get certain dates given and then unexpected delays… we have to explain to them it’s not our fault, it’s out of our hands… (they) lose trust in dealing with UK companies.”
Participant, micro business.

For smaller businesses it was common for information-gathering processes, such as those required for customs, to be done manually. This was more likely to result in errors and needed more staff time to complete. It also meant that border delays took longer to resolve as information about products was more difficult to access.

Smaller businesses were more likely to have less detailed knowledge about customs declarations, such as commodity codes. This was often due to a lack of staff or a lack of specialist customs staff. It meant they were more likely to experience delays at the border due to the submission of incorrect product information.

Regardless of business size, border delays were more likely to occur when products had additional checks, for example dangerous goods or sanitary and phytosanitary goods.

Businesses that traded in larger volumes of a single product, or a low number of products, tended to experience fewer delays due to less variety in the detail required for declarations.

5.3 Businesses thought that EU Exit had increased delays in the short-term, but these had improved over time 

Many businesses reported that border delays had increased around EU Exit and the COVID-19 pandemic, but they had reduced again over the past 18 months. The main reasons given by businesses for this recent reduction in delays were:

• an increase in trained border staff
• business adaptations and learning about customs processes
• an increase in available lorry drivers
• As one business noted:

“(Trading with the EU) was easier during transition period, then got bad overnight (after EU Exit). It has got better within the past year.”
Participant, micro business

Businesses that had been trading with RoW countries pre-EU Exit often found it easier to transition to trading with EU countries post-EU Exit. They reported fewer border delays as a result. This was because they already had a good understanding of how customs worked with countries that were not subject to free movement of goods and services. They were then able to adapt their knowledge more easily for trade with the EU.

In addition, businesses did not think that trading with any particular EU or RoW country was more likely to result in delays.

Vignette 2: business used an agent and very rarely experienced delays in 2023

A prosthetics business said they found it difficult to explain exactly why delays happened because they used an agent. They thought an improvement in UK customs delays had taken place over the past year because:

• the COVID-19 pandemic had ended
• both businesses and customs officials had adapted to the new rules post-EU Exit

| When this business did experience a delay, it was mostly due to extra detail being required on commercial invoices that they were not aware of. They said it was usually simple and quick to make these changes, and they had altered their systems to streamline the process. | | :– |

“Things queuing up during Brexit— that’s improved. UK side has improved immensely (regarding) queues… generally we’re seeing that the goods are clearing UK customs very quickly… usually when we’ve had a delay with UK customs it’s because someone at the other side has messed up… they want more information on commercial invoices (so) we’ve altered our systems.”
Participant, large business.

Vignette 3: business exporting to EU to assemble products and re-importing to UK for final export

A small business assembled their products in Poland, with most of the components manufactured in the UK. They had to export to a Polish assembly company initially, and then re-import back to the UK so their products were considered a ‘temporary import’ at Polish customs.

They experienced difficulties at Polish customs when exporting their products to be assembled. This was because they had to itemise and account for every piece of material that was temporarily being imported to Poland, which was time consuming. They said the difficulties were particularly acute in the immediate time post-EU Exit, because customs regulations between the UK and Poland changed so suddenly.

“Our Polish assembly line company’s view was that Polish customs weren’t being very cooperative or helpful… (they) were understaffed, I think even in storing, going through customs, waiting for inspection… (they) weren’t ready for it. They thought it was (the British) problem anyway”
Participant, small business.

Exporting their final product from the UK was a less significant issue as this business was used to exporting with commodity codes to the RoW.

“Exporting (our) final product was less of a problem. We’re used to exporting with commodity codes”
Participant, small business.

Vignette 4: business experienced delays at US customs using a courier

A micro business trading in vinyl records experienced significant delays shipping to the US with a courier company. They thought the main reason for this was difficulties with communication and not having a named contact to reach out to.

They also felt there was a global customs trend towards customs declarations becoming increasingly more specific and detailed for each country.

“This year I had a… problem shipping to the US with FedEx. They got to America and were being held by American customs… nobody was communicating with anybody, and I couldn’t phone them… something going on out there, not just Brexit… had shipped with this company before with no issues.”
Participant, micro business.

5.4 Businesses found it difficult to explain where delays happened and why they lasted so long

Many businesses made assumptions about where delays were happening and the reasons for them. This was because they did not always have detailed information at each stage of the trading process. It was common for businesses to report that they could contact or query their couriers in the event of a border delay. When they did this, they would receive a generic response such as ‘awaiting customs clearance’.

Businesses who found it more difficult to explain delays were usually micro or small businesses. They did not always have advanced data-sharing systems for gathering information and submitting it to their intermediaries.

“(I feel) it is about paperwork and backlogs… It’s more streamlined now, but there are still backlogs at certain times of the year, like in August… and with unexpected charges… I don’t know why - we were told there weren’t supposed to be any.”
Participant, micro business.

Vignette 5: business using ‘trial and error’ approach for commodity codes

A manufacturing business used intermediaries for import and export, each making up 50% of their trade. The business had focused on reducing delays through ‘trial and error’ with commodity codes, but there were still unexpected delays when exporting around the world.

The courier used by the business did not give much explanation about what caused delays and where they were happening. They felt that EU countries interpreted commodity codes differently.

“I would like clarity and consistency… if you had one set of rules that you could stick to… there are too many grey areas. Currently EU countries are treating commodity codes differently… there can be differences in interpretation.”
Participant, micro business.

5.5 There were a few small differences reported between UK and EU border delays

For the sample of businesses interviewed in the qualitative research, EU border delays affected more exports whilst UK border delays affected more imports. However, due to the small sample size this is not statistically significant and should not be interpreted as such. The following sub-section describes businesses’ experiences with UK and EU border delays and details some contextual reasons for any differences.

Where businesses reported that goods were ‘held at customs’ in the EU, this was sometimes because customers needed to pay for the goods in the particular EU country, such as through Delivered At Place (DAP) terms.

A few businesses thought EU countries interpreted commodity codes differently. This led to challenges around choosing the correct code and increased the likelihood of delays, especially to new markets.

““It varies from country to country… this is the frustrating thing with the customs… it completely depends on what officer they get. I know into the Netherlands it’s quite straightforward, whereas if you look at somewhere like Greece, off the top of my head it’s £150.”
Participant, small business

Business felt that UK border officials had been more lenient immediately post-EU Exit with goods coming into the UK from the EU. They thought this had changed in recent months, so imports were taking longer to pass through UK customs.

Other reasons given for delays at the UK border specifically were:

• a lack of border staff
• a caseload backlog which had built up through the COVID-19 pandemic and had been exacerbated by uncertainty through the EU Exit transition

6. Simplified vs full declarations

6.1 Summary

The key findings in this section are:

• businesses gave the same amount of information to their intermediaries regardless of declaration type
• businesses were generally unaware of the differences between declaration types
• businesses made assumptions about declaration types based on their interpretation of the name of the declaration or obligation

6.2 Businesses gave the same amount of information to intermediaries regardless of the trading context

As traders did not know what types of declarations intermediaries were submitting, time and cost associated with submitting different declarations did not vary significantly. This may account for the low variance in burden between declaration types seen in the survey.

Vignette 6: participant who gave all information to their intermediary

One business, a large manufacturer of medical equipment, said that that they gave all the information necessary to their agent to submit a full declaration. However, the decision as to which declaration was submitted lay with the agent. The participant noted that they used to do simplified declarations for some imports up until February 2023, but then stopped those as most products they imported were zero duty. This meant there was no benefit of using a customs warehouse, which was needed for a simple declaration.

The business felt incentivised to give full information for two reasons:

• they thought that their intermediary would do ‘bare minimum’ to get it through customs
• the intermediary charged a fixed rate by shipment, not by declaration type, so there was no financial incentive to ask for simplified declarations

The participant also noted that the process had been easier with CHIEF than CDS, as the latter asked for more information.

“We have to provide all the details anyway at some stage, because we want to make sure that the goods are cleared correctly.”
Participant, micro business

6.3 Businesses struggled to understand the differences between declaration types

In the quantitative survey, there was little difference in the burden on businesses working with simplified declarations and those working with full declarations. The qualitative interviews selected a sample of respondents who worked with both types of declarations and found that traders struggled to distinguish between declaration types. These uncertainties were driven by reliance on the use of intermediaries, even for traders who claimed to do some of the work in-house. As a result, traders tended not to directly complete declaration forms themselves. There was also a sense that declarations were complex and difficult to complete, with specialist knowledge required to understand customs arrangements.  Businesses also felt that requirements were regularly changing, and that it was difficult to keep up.

Vignette 7: business who thought the difference between simplified and full declarations centred on risk

One participant was the commercial director for a retail goods business trading regularly with the EU and Asia.

They employed a shipping agent to do the vast majority of declarations on the business’s behalf. They also worked with a few different agents depending on the product and region. Deep sea shipping and air freight involved different intermediaries. The participant asserted that the business mostly dealt with simplified import procedures.

The participant understood the difference between simplified and full import declarations to be based on the type of good being imported. Some good categories, predominantly those with associated risk, required more information, more checks and thus a full declaration.

“Only really done it once or twice, and that was during covid when we were shipping hand sanitizer. Hand sanitizer has a relatively low flash point, thus classified as a flammable liquid. Because of that during covid we have problems shipping and importing it. That was the only product we had that was high risk.”
Participant, medium business

“If you’re a meat exporter, you’ve got a lot more hurdles to jump through. If you’re exporting paper carrier bags, they don’t have any supplementary risks. They’re a simple commodity code.”
Participant, medium business

In terms of burden, this meant that the quantity of information that had to be loaded for the intermediary was higher for full import declarations, and thus it took longer. However, the participant felt that the quantity of information needed was high for both simple and full declarations, meaning that the relative difference in burden was small.

“The problem is the sheer amount of info you have to load. … If there was a much simpler way of uploading all that info automatically, it would be easier. One of our key frustrations is the costs of doing a fairly simple declarations for a good leaving or entering the company.”
Participant, medium business

6.4 Businesses tended to make assumptions about the differences between types of declaration based on their name

For example, traders made assumptions about the nature of simplified declarations based on the word ‘simplified’. Businesses also made assumptions based on whether they felt the amount of information given was a lot or a little. As a result, the accuracy of information in the survey relating to declaration types may be low.

Vignette 8: participant who was unsure what type of declarations they submitted

One participant, trading in alcoholic drinks, reported that the declarations process was a joint one between themselves, the bonded warehouse and the freight forwarder.

They did not know what specific types of declaration they submitted, but assumed that they were not simplified based on their perceived complexity. They also suggested that working in the alcohol industry was likely to mean that they had to use full declarations.

“A lot of the declarations I see are not particularly simple because they run to 4 or 5 pages.”
Participant, micro business

After being prompted with a read-out on the declaration process, the participant reaffirmed their belief that they submitted full declarations. They also highlighted where the goods they imported were being stored.

“I believe that because our goods are not just in a standard warehouse (…) I think that changes it.”
Participant, micro business

Vignette 10: participant who made assumptions about the difference between declaration based on their name

This trader was a sports retailer trading in several countries. They were heavily reliant on the use of intermediaries, and delegated responsibility for communicating with these intermediaries to administrative staff.

The participant initially noted that they use both full and simplified declarations. However, upon probing, this transpired to mean that most declarations are simple processes, unless their intermediary calls for more information.

“We would not know if it was simplified or full… I wouldn’t be able to advise you on that.”
Participant, small business.

They presumed that the full declaration might be needed for a new product and new commodity code, as this was a more complex procedure. The business also presumed that most of their declarations were simplified because they were automated. They thought the intermediary would not be able to process full declarations so quickly. 

“(I assume) the full one would have to be manually done, you would never get a 5-minute turnaround.”
Participant, small business.

7. Import and export declarations

7.1 Summary

The key findings in this section are:

• businesses found importing and exporting easier when they were familiar with the processes
• effective systems for data sharing and the ability to choose intermediaries for export were two factors that affected businesses’ control over the trading process

7.2 Businesses reported finding importing or exporting easier when they were familiar with the processes

Businesses tended to say that providing import information and export information to their intermediaries took a similar amount of time. However, this was somewhat dependent on how often they had to gather and process information for one or more of the declaration types. For example, businesses who imported products more regularly were more familiar with the import process. The same was true for businesses who exported products more regularly.

“(We) fill in 10 boxes on different screens… a huge amount of the data is already there for us… it’s a matter of minutes to prepare… We get a message back from the forwarder when they have sent (us) the entry… and if a forwarder doesn’t complete a step we will get an automated message back from CHIEF… We can just monitor a mailbox and these things are done for us.”
Participant, large business.

7.3 Businesses said that effective systems for data sharing and the ability to choose intermediaries for export made the process easier

A few businesses completed their export declarations in-house instead of using intermediaries. They reported finding those declarations easier than for import because:

• they knew what products they were sending and all the required information for the declaration was easy to access and input
• they had more control over how to send their products, for example having a choice of intermediary or going to the Post Office
• the transition to CDS had already happened for import declarations and it was taking longer to use this platform

“I receive the paperwork with all the info (required)… a lot more information is needed compared to export… I’m not sure why, I think it’s the transition to CDS.”
Participant, medium business.

8. Summary

The qualitative research found that traders had a low understanding of the details of customs declarations. This was because they were rarely directly involved in the customs process, even when synthesising large amounts of information themselves. As a result, participants tended to make assumptions about the nature of trade. This included, but was not limited to, differences between declaration types, what was causing delays when importing and exporting, and the technical differences in the customs processes between EU and non-EU countries.

Beyond this knowledge gap, it was felt that:

• businesses were reliant on intermediaries to submit declarations, and as a result did not have a detailed knowledge of the processes involved in submitting declarations
• businesses’ use of intermediaries meant they did not perceive a significant difference in burden between EU declarations and rest of world declarations
• the burden of trading with the EU was high in the initial transition period, but was felt to have fallen broadly in-line with the burden for the rest of world trade
• in smaller businesses, senior staff often found themselves involved in the submission of declarations, driven by necessity and desire to control risk
• delays at the border were not attributable to HMRC, and businesses felt they did not receive clear information on the types and nature of delays from intermediaries
• businesses reported finding importing or exporting easier when they were used to the processes, aided by effective data sharing systems with intermediaries

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[1] This was only among the three declaration types with sufficient base size: full import, full export and submission of proofs of origin.