Research and analysis

Ipsos Survey Executive Summary (2023)

Published 15 July 2025

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

HM Revenue and Customs (HMRC) Research Report 808.

HM Revenue and Customs (HMRC) commissioned Ipsos to conduct research among businesses based in Great Britain (GB) that trade internationally to understand the processes involved and the administrative cost of complying with customs obligations. The data from this research will be used to inform updates to HMRC’s customs admin burden estimates. Please note that the following report presents analysis of the data from the survey conducted by Ipsos, and is separate to the work produced independently by HMRC which uses different segmentations and calculation methods, as well as additional data sources. In total, 1,003 interviews were conducted by telephone, based on a random probability sampling design, between 24 January and 3 March 2023.

The survey focused on the individual declarations completed, with each trader asked about up to 2 declaration types or obligations relating to declarations. This included the amount of time to gather and submit information to HMRC to complete the declaration or obligation, the staff involved, as well as the use of intermediaries and associated costs. The survey also examined other areas that may contribute additional costs, including training on how to submit customs declarations, software used to complete declarations, use of customs warehouses for storing goods and experience of delays when clearing customs.

1. Trader overview

The majority of businesses taking part in the survey used an agent or intermediary only to complete customs declarations (78%). In the survey, 11% completed their customs declarations in-house and 9% completed their declarations both in-house and using an agent. The most commonly used intermediaries were freight forwarders (44%), express operators (32%) and customs agents/brokers (26%).

Most traders in the survey (80%) completed a small volume of declarations per year (i.e. fewer than 300) and 3% completed more than 3,000 declarations per year.

The most common declarations traders reported dealing with were submission of proof of origin, full import and full export declarations (each being completed by around 30% of traders). By contrast, merchandise in baggage declarations and the Bulk Import Reduced Dataset were completed by a very small proportion of traders (approximately 2%).

2. Cost of completing individual declarations

For this survey, businesses were asked about the time taken to complete a series of activities involved with completing their customs declarations, as well as the seniority of the person mostly responsible for preparing these declarations. Using this data, along with data matched from the Annual Survey of Household Earning (ASHE), an internal staff cost was estimated for each participating business.

The survey showed the median total internal staff cost per declaration was highest for simplified frontier declarations, with a median cost of £29 per declaration. For the other types of declaration, the median total internal staff cost per declaration was between £12 (for a full export declaration) and £25 (for local clearance procedures). The most frequently completed declarations, such as full export and import declarations, did not have the highest internal staff cost and time for traders.

The time spent per declaration was also highest for simplified frontier declarations, which took 114 minutes per declaration on average among surveyed businesses. For the other types of declaration, the average amount of time spent per declaration ranged from 72 minutes (simplified export declaration procedure) to 108 minutes (for local clearance procedures).

For the declarations with the largest internal staff cost and time, businesses in the survey were most likely to use a third party agent. Local clearance procedures and import C21 forms were outsourced by 64% and 74% of traders respectively, while simplified export declarations, which took less time, were outsourced by around four in ten (42%). More traders in the survey spent time gathering relevant figures and information and making or settling payments such as taxes or charges compared to the other activities, while the median time taken across different activity categories was generally between 15 and 30 minutes.

Most often intermediaries were used to complete full import declarations (75%) and C21 forms for imports (74%). By contrast, agents were least likely to be used for simplified export declaration procedures (42%). Across all declarations, the type of agent used varied by declaration and were typically customs brokers, freight forwarders and express operators.

Traders in the survey largely reported that preparing and providing the information for declarations was very or fairly easy, even amongst those declarations with the greatest internal staff time and cost 61% of those asked about local clearance procedures found the information easy or very easy to prepare, with the same proportion for C21 export forms.

Manager level staff were most commonly responsible for preparing the information required for all the declarations covered in the survey (ranging from 20% of staff mainly responsible for preparing information for full export declarations being managers, through to 36% of the staff preparing information for import unique consignment numbers being managers). Along with managers, many traders reported that more senior staff also had a role in preparing and providing information for submitting customs declarations (ranging from 15% for local clearance procedures through to 31% for simplified frontier declarations).

The survey also collected data on the cost to traders of using a third party or agent where applicable. Across declarations with sufficient sample size (C21 import forms, local clearance procedures, full import declarations, full export declarations and submission of proof of origin forms) the median cost for a single declaration was around £50.

3. Additional costs of completing customs declarations

The survey covered several other costs associated with submitting customs declarations and found that 10% of traders used customs warehouses, where goods can be stored without paying duties for a fixed time period. Training on submitting customs declarations, either in-house or delivered by an external organisation, was undertaken by a small proportion of traders (25%).

Traders were asked how they submitted the information to complete their customs declarations, and were able to select multiple responses. Overall, most respondents submitted information online. Among those that handled all or some declarations in-house, 53% said they submitted the information to complete their customs declarations online via software. For those that outsourced all declarations, 18% provided information to intermediaries online via software and 66% online without software (including email), while 22% said that an intermediary dealt with all the paperwork for them.

Most traders reported experiencing delays when clearing customs (12% said they never experienced delays) which may present additional costs to the sector and individual businesses. The survey did not ascertain the reason for the delays, and they may not be directly attributable to HMRC.