Research and analysis

Qualitative research with customs intermediaries to better understand the Northern Ireland intermediary market (2022)

Published 15 July 2025

This report was commissioned under the Conservative administration (2010 to 2024), and conducted in 2022.

Research into intermediating trade with Northern Ireland

HMRC Research Report 817.

Qualitative research conducted by Ipsos between June and July 2022.

Prepared by Ipsos (Alice Stratton, Kathleen Bailey, and Shahil Parmar) for HMRC.

Acknowledgments: Ipsos would like to thank all the people who gave up their time to take part in the qualitative interviews and supported with report review.

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

Glossary and abbreviations

This report uses terminology and abbreviations that are explained below.

Term	Definition
‘At risk’ goods	‘At risk’ goods are those which could possibly move onwards from Northern Ireland into the EU. If goods are designated ‘at risk’, it means they are at risk of onward movement to the EU and customers will need to pay the applicable EU duty on them.
Customs broker/agent	A customs broker facilitates the import and export of goods, which are subject to customs inspection and restrictions.
Customs declaration	A form listing the details of goods being imported or exported. It is a legal requirement, although some countries or trading areas (for example, the European Union (EU)) have agreements in place which means they are not required.
Customs intermediary	These are businesses that help traders to move goods across borders. They offer a range of different services including providing or arranging transportation of goods, completing customs declarations, and paying tariffs or import duties. This research focused on those who currently make declarations on behalf of traders (either in-house or outsourced) or those who intended to do so once full customs declarations were required on all EU trade (in-house or outsourced).
Exporting	Selling goods or services to a customer in a different country. This research focused purely on goods, as customs declarations are not required for services.
Fast parcel/express operator	Fast parcel operators (for example, couriers or next-day parcels services) transport documents, parcels, and freight across the world in a specific time frame.
Freight forwarder	A company that organizes shipments for individuals or corporations to transport goods from the manufacturer or producer to a market, customer, or final point of distribution.
Haulier	Hauliers deal mainly with the physical transportation of goods.
Importing	Purchasing goods or services from sellers in a different country. This research focused purely on goods, as customs declarations are not required for services.
In-house	When customs intermediaries complete declarations themselves.
Large	Businesses with 250+ employees.
Medium	Businesses with 50 to 249 employees.
Micro	Businesses with 1 to 9 employees.
Northern Ireland Protocol	The Northern Ireland Protocol is the arrangement agreed between the United Kingdom (UK) and the EU regarding the movement of goods to and from Northern Ireland (NI). Under the Protocol, customs and Safety and Security declarations are required on goods entering Northern Ireland from the rest of the UK. No declarations and checks are required for goods moving between the Republic of Ireland and Northern Ireland. For more information, please visit The Northern Ireland Protocol.
‘Not at risk’ goods	Traders moving goods into Northern Ireland can declare them as ‘not at risk’ of moving to the EU so that EU duty will not be payable on those goods. When goods you bring into Northern Ireland are ‘not at risk’ due to the applicable duties. Goods brought into Northern Ireland from Great Britain are ‘not at risk’ if the applicable EU duty is zero. This is unless the goods are subject to processing and you do not meet the additional criteria to declare goods for processing ‘not at risk’ (for more information see ‘Notes….. at the end of this section).
Outsourcing	When customs intermediaries pay other customs intermediaries to complete their customs declarations for them.
Safety and security entry summary declaration (ENS)	The Entry Summary Declaration (ENS), or Safety and Security declaration, provides UK customs with pre-arrival information on goods, for safety and security purposes. The ENS declaration must be completed before any physical movement of goods.
Sanitary and phytosanitary (SPS)	Sanitary and Phytosanitary (SPS) measures refer to the EU controls to protect animal, plant, or public health. These checks are separate to processes operated by HMRC and Border Force.
Small	Businesses with 10 to 49 employees.
Trader	Businesses who import goods or services to the UK or export to other countries. This research focused purely on goods as customs declarations are not required for services.
The Trader Support Service (TSS)	The TSS assists companies with customs processes under the Northern Ireland Protocol for goods movements into and out of Northern Ireland. The service supports traders by submitting customs declarations on their behalf, in addition to educating traders on the requirements under the Protocol and maintaining a call centre to assist with queries.

Notes to ‘Not at risk’ goods

When goods you bring into Northern Ireland can be declared ‘not at risk’ under the UK Trader Scheme. Where the applicable EU duties are higher than the applicable UK duties (which are zero in the case of movements from Great Britain to Northern Ireland), goods brought into Northern Ireland can still be declared ‘not at risk’ when they are all of the following:

• for sale to, or final use by, end consumers located in Northern Ireland (and England, Wales and Scotland in the case of movements from Great Britain)
• declared by a trader authorised under the UK Trader Scheme
• not subject to an EU trade remedy

If the goods you bring into Northern Ireland will be subject to processing, you must meet additional criteria when applying for UK Trader Scheme authorisation before you can declare these goods ‘not at risk’.

1. Executive summary

1.1 Background

The Northern Ireland Protocol (referred to as the Protocol from here onwards) is part of the UK’s Withdrawal Agreement with the EU and set out special arrangements for Northern Ireland, so that the island of Ireland remained border-free. It came into force on 1 January 2021. Under the Protocol, goods coming into Northern Ireland (NI) from GB are now typically subject to customs declarations; official documents that list and give details of the goods that are being imported or exported.

To assist companies with customs processes under the Protocol when moving goods from GB to NI, the Trader Support Service (TSS) was introduced by the government on 1 January 2021.

HM Revenue and Customs (HMRC) needed to understand the NI customs intermediaries’ market in more detail alongside the impact and role of the TSS in its management of customs processes. More specifically, the research objectives were to explore experiences of customs intermediaries facilitating trade between GB and NI, perceptions of facilitating trade between GB and NI among those not doing so, and to understand customs intermediaries support needs and capacity to meet any increases in GB-NI demand.

1.2 Methodology

A total of 30 semi-structured in-depth interviews were conducted with customs intermediaries between 29 June and 28 July 2022. Interviews were conducted using either MS Teams or the telephone and lasted around 45 to 60 minutes. The interview followed a topic guide that covered key research questions that were developed collaboratively by Ipsos and HMRC.

1.3 Key findings

Customs intermediaries’ perceptions and experiences of facilitating GB-NI trade

Some customs intermediaries who were facilitating trade between GB and NI said they found the process more complex and time-consuming than before EU Exit. Some felt frustration at now having a trade border between GB and NI and the speed at which they had to adapt to the changes.

However, a small number of customs intermediaries reported their experience of facilitating GB-NI trade was now easier and, in some cases, felt the changes since January 2021 had been profitable for their business. It was also noted by several customs intermediaries that GB-NI trade had become easier over time, both for their own business and for their customers. So, whilst challenging at the outset, it was acknowledged they had been able to adapt to the new processes.

Some customs intermediaries who were not facilitating GB-NI trade expressed interest in tapping into the GB-NI market. However, on the whole, perceptions of declarations between GB and NI for this group of research participants, were that they constituted a complicated process that was not worth their time.

Challenges and barriers to facilitating GB-NI trade

For customs intermediaries already facilitating GB-NI trade, one of the biggest challenges was their customers not understanding the new border documentation requirements. This caused them extra work to explain the process or follow-up with their customers who had sent through wrong information, or sometimes no information at all. Another challenge for some was the complexity and time involved in having to input a high number of commodity codes per shipment. Several customs intermediaries also mentioned difficulties in employing skilled staff members and felt this was an industry-wide challenge.

Uncertainty around the future of the Protocol was seen as a challenge by some customs intermediaries because the rules could change at any time. They felt that this uncertainty had contributed to a lack of demand in trading between GB and NI.

Customs intermediaries, who were not facilitating GB-NI trade, explained that the most significant barriers to entry were perceived low demand and low profitability due to the expectation of extra time and cost being involved in facilitating this route. Other barriers mentioned included a lack of accessible information about GB-NI trade, difficulty building strong professional relationships with NI-based contacts, and the increased complexity of new trade regulations.

Role of the Trader Support Service

Some customs intermediaries were aware of the TSS, though their usage of it and views about the service varied. Among some of those who used it, the TSS was valued as the only free option available, and a few customs intermediaries had made the TSS an intrinsic part of their business processes. Some customs intermediaries, who used the TSS regularly, felt it was useful and, for some, their business would cease to operate without the TSS.

Some users highlighted issues they encountered: complications with TSS registration and security verification processes; experiences of inefficient customer service; a perceived lack of expertise within HMRC about GB-NI trade; and a sense that the TSS acted as a competitor to business in some cases.

Wider support in facilitating GB-NI trade

Whilst some customs intermediaries had not accessed any support in relation to customs declarations, some had accessed support outside of the TSS. Types of support accessed by customs intermediaries included training courses from approved private providers and HMRC guidance on GOV.UK.

Future support and improvements

Desire to expand the facilitation of GB-NI trade was limited, particularly among those not already facilitating GB-NI trade. Some customs intermediaries explained that they facilitated GB-NI trade for their existing customers but would not do so for any new ones. A barrier to expanding the facilitation of GB-NI trade for some was their uncertainty about how the market would evolve and whether there would be demand large enough to justify additional investment of time and resources.

There were several suggestions for future support that would encourage the expansion of the GB-NI market. These included: streamlining processes, communicating changes to requirements and processes more clearly and quickly, having a dedicated helpdesk with more specialist staff available to answer niche, technical queries with less signposting to other resources, providing targeted support or messaging directly to customs intermediaries’ customers, increasing the availability of information about NI customs intermediaries, and providing financial support.

2. Introduction

2.1 Background

The Northern Ireland Protocol came into force on 1 January 2021 and set out Northern Ireland’s post-EU Exit relationship with both the European Union (EU) and Great Britain (GB). The Protocol is part of the ‘Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community (2020)’. This is an international treaty between the UK and EU which set out how the UK’s exit from the EU would work.

The Protocol ensures there are no checks on goods that move between Northern Ireland (NI) and Ireland (and the rest of the EU). This is done by applying the EU’s Single Market rules for goods as well as customs rules to NI. Goods coming into NI from GB must be checked and/or have paperwork to show they are compliant with the EU regulations. Typically, goods now being moved from GB to NI are subject to customs declarations; official documents that list and give details of the goods that are being imported or exported. These declarations are required to account for any custom duty and Import VAT which could be levied on goods that are deemed ‘at risk’ of onward movement into the EU. Goods that move from NI to GB can generally do so without any customs declarations or checks, with some limited exceptions when an export declaration is required.

To support traders in complying with the new legal requirement to complete customs declarations when moving goods from GB to NI, the Trader Support Service (TSS) was introduced in January 2021. This government support service can raise customs declarations on behalf of traders, for free, for those moving goods between GB and NI. The TSS has had over 47,000 users sign up and 95% of the movements it facilitates are GB-NI goods movements.

HMRC needed to understand the NI customs intermediaries’ market in more detail. HMRC were interested in the experiences of those facilitating GB-NI trade, including any difficulties encountered, what worked well and the support that had been useful, or would be useful in the future. HMRC were also interested in those with the ability to facilitate trade between GB-NI but who were not doing so. This was to explore what support could be offered should the GB-NI market expand. Additionally, HMRC wished to better understand the impact and role of the TSS and its current support package.

2.2 Research objectives

The overall objective of this research study was to help HMRC understand the NI customs intermediaries market attitudes and behaviours and to explore perceptions of the TSS offer alongside considerations around future support. More specifically, the research aimed to explore the following themes:

• current experiences: perceptions and experiences of customs intermediaries facilitating trade with NI, particularly GB to NI, including the types of customers and processes they help to facilitate, and the barriers they have experienced
• support needed to implement change: useful support identified for previous customs changes, including experience or perceptions of using the TSS, and details of any additional support that would be useful in the event of further customs changes
• capacity of the NI market: the general supply and demand for customs intermediaries and the ability of various stakeholders to facilitate goods movements and preparations necessary to increase capacity

2.3 Methodology

Ipsos conducted research with customs intermediaries making customs declarations on behalf of traders (either in-house or via outsourcing). A total of 30 semi-structured in-depth interviews with customs intermediaries were conducted between 29 June and 28 July 2022. Interviews were conducted using either MS Teams or the telephone and each lasted around 45 to 60 minutes.

Interviews followed a topic guide that covered the key research questions and was developed collaboratively by Ipsos and HMRC. The semi-structured nature of the interviews with customs intermediaries meant that questions were typically open and allowed participants to talk in detail about their experiences. Additionally, interviewers guided and prompted participants where necessary to drill down into key topic areas.

Participants were offered an incentive to thank them for their participation. The incentive was £60 that could be taken as either a shopping voucher or donation to a charity of the participant’s choosing.

Those in-scope for the research

In this research, a customs intermediary is defined as a business, either based in NI or GB, facilitating customs declarations on behalf of traders (either in-house, through outsourcing to another customs intermediary, or a mix of both). This included the following type of customs intermediaries who made declarations for goods moving between GB and NI: 

• customs brokers/agents who completed declarations for businesses importing and or exporting goods to ensure that goods are accurately declared for customs, they do not primarily deal with the physical movement of goods
• express operators/fast parcel operators who specialised in moving goods very quickly (usually taking 5 to 7 days to move goods across borders)
• freight forwarders/shipping agents cover the movement of goods via different mediums: road, rail, air, and sea, and 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)
• hauliers who dealt mainly with the physical transportation of goods

Those who solely moved goods did not fall under our definition of a customs intermediary. This included hauliers and freight forwarders who did not make customs declarations on behalf of their customers or who did not outsource customs declarations to other customs intermediaries.

2.4 Notes on reporting

Interpretation of findings

The qualitative findings are intended to be illustrative of the range of views held by customs intermediaries, providing insight into their behaviours and perceptions. Although efforts were taken with sampling and recruitment to speak to a wide range of customs intermediaries, qualitative research is not designed to be statistically representative. The qualitative findings presented in this report reflect only the perspectives of those interviewed.

Verbatim quotes have been included in this report to illustrate key points and common themes. Where verbatim quotes are used, they have been anonymised and attributed with their business size and type. Attributions are not unique identifiers for each interview, so while some quotes may have identical attributions, this does not mean that they were said by the same participant. 

Abbreviations

Throughout the report the following abbreviations are used:

• ‘The Protocol’ is used to refer to The Northern Ireland Protocol
• ‘GB-NI’ is used to refer to trade between Great Britain and Northern Ireland in either direction
• the ‘TSS’ is used to refer to the Trader Support Service

Accessibility

This report complies with Government Digital Service standards on designing accessible content.

3. Customs intermediaries’ perceptions and experiences of facilitating GB-NI trade

This chapter explores experiences of GB-NI trade among those who were facilitating trade along this route and perceptions of GB-NI trade among those not facilitating trade along this route.

3.1 Customs Intermediaries experience of GB-NI trade

Some customs intermediaries, who were facilitating trade between GB and NI, said they had found the process more complex and time-consuming since EU Exit. Some felt frustration at now having a trade border between GB and NI and the speed at which they had to adapt to the changes.

“We had a Brexit deal announced on Christmas Eve that gave us one week to get ready for January when changes came in and everybody was on holiday for Christmas.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade through outsourcing, no NI presence)

A small number of customs intermediaries felt that facilitating GB-NI trade was easy and, in some cases, the changes after January 2021 had been profitable for their business because they could charge for customs declarations along an additional route. Customs intermediaries, that found it easy to facilitate trade between GB and NI, tended to be larger and better resourced companies that had been able to invest in training and new processes from the outset.

Several customs intermediaries said that, as time passed after EU Exit, GB-NI trade became easier. This was due to increased learning of and adaptation to the new processes, both for customs intermediaries and their customers.

“It has improved in leaps and bounds. It was really bad in the early days…The way it’s running now, it works. If you have the paperwork in order, there’s no issue.”

(Customs broker, 250+ employees, facilitates GB-NI trade through outsourcing, has NI presence)

3.2 Factors contributing to an easier GB-NI trade experience

There were four key factors that tended to contribute to customs intermediaries finding it easier to facilitate GB-NI trade. These factors can be summarised as:

• larger company size
• NI business base or HQ
• use of temporary arrangements for moving goods in parcels from GB to NI
• only trading in more ‘straightforward’ goods

Larger customs intermediaries tended to have more developed business and trade processes in place when it came to being compliant with the new requirements. They also tended to have more resources, expertise, and better-established processes for learning new systems, which meant they had found the new requirements easier to navigate. Smaller companies, in comparison, typically found it harder to accommodate the changes, given the increased resources involved in complying with new requirements.

“Bigger organisations are fairly well-informed, and they have the resources to give you the correct information, smaller customers don’t have the resources to help as much and they rely on us to provide guidance.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade through outsourcing, no NI presence)

Customs intermediaries with a business presence or headquarters in NI said they found it easier to facilitate trade between GB and NI. Firstly, they could consign goods to themselves from GB, which made the process more straightforward for them. Furthermore, they typically had more established relationships with other customs intermediaries on the ground in NI who could help facilitate their trading needs more quickly due to their local knowledge and expertise.

Several customs intermediaries also mentioned the role of the ‘UK Trader Scheme’, through which they thought it was possible to reduce complexity at the GB-NI border. This scheme is designed to allow traders to declare goods brought into Northern Ireland ‘not at risk’ of moving to the EU, so that EU duty will not be payable on those goods. Customs intermediaries with an NI base felt that this allowed for simplification of the commodity code process for them and was therefore, particularly relevant for those handling ‘not at risk’ goods.

“[The] UK Trader Scheme means we don’t have to iron out every single item, it’s just a blanket code per vehicle… [When it first came in, they were asking us to pick a line per commodity code.]”

(Fast parcel operator, 50 to 249 employees, facilitates GB-NI trade, has NI presence)

Several fast-parcel operators were operating under the ‘temporary arrangements for moving goods in parcels from GB to NI’. These temporary arrangements had drastically reduced the need for customs declarations to be filled out for items being moved between GB and NI. For this group, the reduction in complexity meant they found the current facilitation of trade between GB and NI fairly similar to before the changes were introduced.

Lastly, customs intermediaries, who solely dealt with goods that were not subject to extra health and safety checks or requirements, tended to find the process easier.

3.3 Perceptions of GB-NI trade among customs intermediaries not facilitating this route

Some customs intermediaries, who were not facilitating GB-NI trade at the time of fieldwork, expressed negative views about facilitating this trade route. Others had a more neutral attitude towards it. A few expressed some interest in tapping into the GB-NI market. However, on the whole, research participants perceived declarations between GB and NI to be a complicated process unworthy of their time.

Perceptions of facilitating trade between GB and NI tended to stem from three primary influences:

• previous work in facilitating GB-NI movements before EU Exit or immediately after EU Exit
• views on the Protocol and other changes brought about by EU Exit
• uncertainty over the future of the Protocol and caution around basing business decisions or changes upon it

Several customs intermediaries, who were not facilitating GB-NI trade at the time of the research, had previously done so. In these cases, their perceptions had come from personal experience trying to navigate the new requirements. Some had found it so challenging and time-consuming immediately after EU Exit that they opted against continuing business along that trade route. Some of these customs intermediaries also commented on having had a low volume of GB-NI trade. It was not their business focus. They were, therefore, not giving up a high proportion of their customers.

“I had a try [facilitating GB-NI trade] and I was not happy with the outcome at all. It was difficult to navigate the requirements. I remember it chewed up hours and, at the end of it, I said ‘no more.’”

(Customs broker, 1 to 9 employees, does not facilitate GB-NI trade, no NI presence)

Another influence on customs intermediaries’ perceptions of GB-NI trade was their political view as it related to the Protocol. Customs intermediaries’ views on GB-NI trade tended to be shaped by the extent of their agreement or disagreement with the Protocol.

In addition, some customs intermediaries expressed dissatisfaction with ongoing implications of EU Exit on UK trade more broadly. They gave examples such as increased documentation, and cost and time taken to trade with EU countries. They felt EU Exit had a large impact on GB-NI trade for similar reasons. This contributed to shaping their perceptions of the trade route being challenging to undertake.

Some customs intermediaries were concerned by the difficulty of predicting how the market demands and trade policy would change over time. These customs intermediaries said that they were not prepared to invest in NI trade when they could not be sure of what the future trading arrangements would be.

Some customs intermediaries also mentioned there was a lack of consistent, steadying messaging to either customs intermediaries or customers about how to facilitate this trade route effectively.

“We need a clearer statement […] people are weary of all the change.”

(Freight forwarder, 1 to 9 employees, does not facilitate GB-NI trade, no NI presence)

4. Challenges and barriers to facilitating GB-NI trade

This chapter provides an overview of the challenges and barriers to facilitating GB-NI trade, both for those customs intermediaries who were facilitating trade at the time of fieldwork and those who were not. For the purposes of this research:

• ‘challenges’ are problems which arose during the process of facilitating GB-NI trade for customs intermediaries who were facilitating this route at the time of fieldwork
• ‘barriers’ are problems which had stopped customs intermediaries from facilitating trade between GB and NI, or led to minimal experience of doing so since January 2021

Several similar themes came up across the spread of interviews. It was possible to draw out a few trends, views and experiences that were more specific to certain customs intermediary types. However, it was not possible to draw strong differential conclusions between the different types of customs intermediaries. As a result, this chapter discusses a few of the notable trends that were more specific to each type of customs intermediary (but are by no means exclusive).

4.1 Customs intermediaries facilitating GB-NI trade

For customs intermediaries who were facilitating GB-NI trade, one of the biggest challenges was their customers not understanding the new border documentation requirements. Other challenges mentioned included the complexity of having to input a high number of commodity codes per shipment, uncertainty around the future of the Protocol, staffing issues and low demand for GB-NI trade.

Customers’ lack of knowledge about border requirements

This challenge was raised by several customs intermediaries who were facilitating GB-NI trade. One of the impacts of this was the need for customs intermediaries to do extra work to explain the process to their customers who had sent through wrong or inadequate information. Several customs intermediaries, who raised this point, expressed frustration at the lack of awareness from their customers alongside frustration at the government for not educating traders on the new processes sufficiently.

“[The biggest challenge is] unprepared customers lacking knowledge and experience, who need to be taught how to do things and use systems.”

(Freight forwarder, 1 to 9 employees, facilitates GB-NI trade, no NI presence)

A few customs intermediaries found that their customers lacked knowledge of the difference between ‘at risk’ and ‘not at risk’ goods when it came to GB-NI trade. There are several factors traders must consider when determining whether their goods are ‘at risk’ or ‘not at risk’. This included the differentials between the UK and EU customs duties, and the intended end use of the goods in NI. Some customs intermediaries felt that, when their customers, who were often unaware of these requirements, found out about them, they were sometimes hesitant to take responsibility for their goods’ risk status. This resulted in increased costs, particularly in terms of time, and often led to delays in moving goods.

“Belfast are subject to an import declaration, ‘at risk’ or ‘not at risk’… that has been a challenge on the Northern Ireland side.”

(Customs broker, 250+ employees, facilitates GB-NI trade, has NI presence)

Complexity of commodity codes

Some customs intermediaries noted that there were challenges around the need to input a high number of commodity codes per lorry. This increased complexity resulted in extra time spent on declarations due to the level of detail required.

“Some customers may have 50 or 60 types of commodities, that could be a very big factor [for] customs intermediaries… it takes so much more time to clear multiple item lines.”

(Customs broker, 250+ employees, facilitates GB-NI trade, has NI presence)

However, this challenge did not affect all customs intermediaries. Those who only transported one or two different types of goods per shipment, or who were part of the ‘UK Trader Scheme’, were less affected by this. Some also used the ‘temporary arrangements for moving goods in parcels’ to reduce their administration requirements.

Uncertainty around the future of the Protocol

Uncertainty around the future of the GB-NI trading relationship was raised by customs intermediaries as an ongoing concern. Because they felt that the rules could change at any time, there was a sense that facilitating trade with NI, in a context that lacked political certainty, was not an attractive prospect.

“It is still up in the air with Northern Ireland and it’s impossible for a business to plan without knowing what the future is going to be.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

Low demand and low profitability

The challenge of low demand and low profitability were often seen as interconnected. Several customs intermediaries indicated that they did not facilitate much GB-NI trade at all; it accounted for a very low percentage of their business; and/or it was mostly not a priority for them. In some cases, trade with NI had significantly decreased since January 2021. These intermediaries felt that this may be because businesses decided that exporting to NI was not worth their time due to the increased cost and time involved in completing declarations. As a result of this low demand, some customs intermediaries felt it was not particularly profitable to facilitate GB-NI trade.

“A truck going to Northern Ireland does not bring the same revenue as a pallet to America. So, for me, my profit is in deep sea shipments rather than short sea…”

(Freight forwarder, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

Some customs intermediaries did facilitate GB-NI trade, despite the low profitability, because their customers requested it. However, it was often seen as a high-risk, low-reward prospect. Customs intermediaries often said they would decide whether to facilitate GB-NI trade on a case-by-case basis. They did not have any strict rules about taking on the GB-NI trade work. Typically, they felt they did not receive many enquiries and would be overall more hesitant to take it on for new customers with whom they had not worked with previously in other markets.

Staffing issues

Several customs intermediaries mentioned difficulties in employing skilled staff members. This was felt to be an industry-wide challenge affecting most companies, but particularly the smaller ones. It could affect both their internal processes (slowing them down) and external work capacity (fewer employees to undertake tasks). Some customs intermediaries explained that these staffing issues were partly due to new work permit regulations. Furthermore, they mentioned needing to employ more staff to deal with the additional administrative burden of the new requirements and reduce pressure on existing staff.

“Every freight agent is looking for qualified staff, the amount of people available in Belfast is just not there.”

(Fast parcel operator, 250+ employees, facilitates GB-NI trade, has NI presence)

Several customs intermediaries felt it was difficult to train existing staff in new procedures. For example, a couple of customs intermediaries noted that lorry drivers were not used to dealing with documentation requirements at the GB-NI border, and some struggled to use smartphones. There was a sense that this type of situation increased costs for companies. One customs intermediary noted that they had hired an extra staff member to manage the lorry drivers making sure they understood everything and had the correct documentation.

“Pre-Brexit, drivers drove lorries. But now, drivers have to become almost administrators as well… lorry drivers just want to drive lorries, [they] don’t want to look at paperwork… [It’s a] change in mindset for 250 lorry drivers.”

(Fast parcel operator, 250+ employees, facilitates GB-NI trade, has NI presence)

4.2 Overcoming some of the challenges

Customs intermediaries who facilitated GB-NI trade spoke about overcoming these challenges through two main routes, which were:

• outsourcing declarations: some customs intermediaries went through hauliers, who conducted the whole shipping process on their behalf and others worked with large international shipping companies who had more expansive knowledge of the processes
• being part of the UK Trader Scheme or using temporary arrangements for moving goods in parcels

Outsourcing

Customs intermediaries, who outsourced declarations, tended to see it in a positive light, albeit tinged with frustration that they were unable to provide the service in-house. Several customs intermediaries recognised that outsourcing reduced internal costs as they no longer had to hire and train full-time staff for it. They felt outsourcing kept them more in control of the process because they did not have to understand the new requirements in-depth. However, some felt frustrated that the process could be slower at times than providing the service in-house.

“We are quite fortunate because of [company outsourced to], they have their avenues and lanes. Otherwise, we would have to get ferries.”

(Customs broker, 50 to 249 employees, facilitates GB-NI trade through outsourcing, no NI presence)

“We’ve had to outsource or get a platform to enable us to be more in control of the job, but there are so many layers before you can even get something moving now.”

(Freight forwarder, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

The ‘UK Trader Scheme’

Some customs intermediaries said that the ‘UK Trader Scheme’ made it possible for them to reduce complexity at the GB-NI border. They said that it allowed them to simplify the commodity code process for ‘not at risk’ goods. It was reported that this hugely reduced the burden on customs intermediaries, in terms of cost and time spent undertaking declarations. They said that they no longer had to input each commodity code per shipment. One customs intermediary who was part of the scheme indicated it had a positive impact on their organisation, and, without it, they would not be able to undertake GB-NI trade at all because it would be too expensive and time-consuming.

“When [the Protocol] first came in, they were asking us to pick a line per commodity code. But then, with the UK Trader Scheme, [it’s the] line that is used most per vehicle […] took us three months to get it, that was a game changer.”

(Fast parcel operator, 50 to 249 employees, facilitates GB-NI trade, has NI presence)

However, to take advantage of this scheme, customs intermediaries had to meet certain requirements:

• be established in or have a fixed place of business in NI
• be declaring ‘not at risk’ goods and give details of records, systems and controls that allowed them to accurately declare this
• turnover for most recent financial year being below £500,000
• be bringing goods into NI for the following purposes:
  • food for sale to end consumers
  • construction, must be a permanent part of a structure in NI

As a result, not all customs intermediaries were eligible to apply for the ‘UK Trader Scheme’ and could, therefore, not take advantage of its benefits. They expressed frustration at the ongoing complexity and said that it was not cost-effective to provide a service facilitating GB-NI trade as a result.

“It’s not cost effective to offer the service unless [we are] part of the trusted Trader Scheme. But it’s currently only available to firms with a Northern Ireland presence, which we don’t have.”

(Customs broker, 1 to 9 employees, facilitates GB-NI trade, no NI presence)

Temporary arrangements for moving goods in parcels

Some customs intermediaries used temporary arrangements to reduce the volume of parcels that needed customs declarations completing. Collecting enough data from individuals sending parcels to fulfil the level of detail required for customs declarations could present a significant challenge for these customs intermediaries. Some said this could lead to significant hold-ups at the border. Without the temporary arrangements in place, these challenges may require significant investment to increase staff numbers to deal with the additional workload.

“If the rules change for NI, then we’ll need to start working out what’s B2B and B2C. It’s going to be a real problem as there is no way we can capture that data […] It will be a lot more work, like starting again for the EU stuff from Brexit. We’ll need more people.”

(Fast parcel operator, 250+ employees, facilitates GB-NI trade, has NI presence)

4.3 Customs intermediaries not facilitating GB-NI trade

For customs intermediaries who were not facilitating GB-NI trade, the most noteworthy barriers to servicing this trade route were low demand and reduced profitability. Other barriers included a lack of accessible information about GB-NI trade, difficulty building strong professional relationships with NI-based contacts, and the increased complexity of the new trade regulations. These barriers typically affected smaller companies more than larger ones, mainly due to tighter resource constraints.

Low demand in NI

Low demand was seen by some as a critical issue for those not facilitating GB-NI trade. Some customs intermediaries explained that a few trucks every now and again, would not be worth the investment needed to facilitate shipments. Some noted that, they would take on GB-NI work, if their existing customers asked for it, or if they were approached by new customers wanting to trade with NI. However, they felt it was not likely to happen or had not happened much so far. Typically, smaller organisations did not feel like they had the client base or interest in NI that would encourage them to pursue it as a business prospect. As a result, they did not focus their efforts there.

“I could count on one hand the number of shipments we deal with involving Northern Ireland. We’ve never focused on it.”

(Freight forwarder, 1 to 9 employees, does not facilitate GB-NI trade, no NI presence)

Extra time and cost of facilitating GB-NI trade

When asked what was stopping them from facilitating GB-NI trade, some customs intermediaries responded that it was not profitable enough due to the extra time taken and increased costs of learning about and processing declarations. Some customs intermediaries felt they could not always charge enough to cover these increased costs and this de-incentivised them from pursuing GB-NI trade, particularly if they were a smaller company.

“No incentive to get involved. Complex work and can’t charge enough for it, especially as a small business not focussed on GB-NI route. Also, a lack of demand from customers [for that route].”

(Freight forwarder, 1 to 9 employees, does not facilitate GB-NI trade, no NI presence)

The increased complexity of the new requirements was also a reason for the increased time needed to complete declarations. A few were frustrated with the implementation of new rules meaning that NI was perceived to be treated differently to the rest of the UK.

“[I can move] low value e-commerce goods under £135 without paying duty… all day long in GB… why can’t I hand over the same parcels to a vendor in NI? They are cleared in the UK and now we have to do another set of declarations to get them into NI.”

(Customs broker, 10 to 49 employees, does not facilitate GB-NI trade, no NI presence)

Lack of accessible information

Some customs intermediaries thought there was a lack of accessible information available from government bodies such as HMRC. Although the information was available online, some customs intermediaries found it difficult to understand and navigate. This made it harder to know what to do and when.

“HMRC’s view of info is that they just pile it on. As long as it’s there, they’ve done their job… the thing is, you can’t … find [the information you need].”

(Freight forwarder, 1 to 9 employees, does not facilitate GB-NI trade, no NI presence)

Difficulty building strong professional relationships with NI based customs contacts

A few GB-based customs intermediaries said they had struggled to find NI-based contacts with the required expertise to clear the goods in NI. They mentioned problems around reliability and availability of NI-based customs contacts, which meant it was difficult to build strong professional relationships which would help them facilitate GB-NI trade in the longer term.

5. Role of the Trader Support Service

This chapter provides insight on customs intermediaries’ experiences and perceptions of the Trader Support Service (TSS).

5.1 Customs intermediaries who were unaware of the TSS

Only a small number of customs intermediaries spoken to were unaware of the TSS. On hearing a description of it, they cautiously expressed that it could be a useful service for hauliers or companies with a base in NI. They appreciated that it was a free service that was relevant to their needs, although they noted that the customer base for it was not significant. Some were keen to try the TSS, even if a few expressed scepticisms that it would truly be useful.

“Might use it, would depend how good it was. Would probably try it, and if people didn’t know what they were talking about… [I would stop].”

(Freight forwarder, 1 to 9 employees, does not facilitate GB-NI trade, no NI presence)

5.2 Customs intermediaries who were aware of the TSS

Overall customs intermediaries were aware of the TSS, though their usage of it and views about the service varied considerably. Customs intermediaries had learned about the TSS mainly through HMRC emails and government notifications or bulletins.

Customs intermediaries who used the TSS regularly

The TSS was valued by some as the only free option available for customs intermediaries and their customers. A few customs intermediaries had made the TSS an intrinsic part of their business processes. Some customs intermediaries who used the TSS regularly felt it was useful. However, there was a sense of more general need for support, in addition to the TSS, in facilitating GB-NI trade. One customs intermediary gave the example of having a centralised system enabling people to ask questions without seeking a paid service. For some customs intermediaries, their business would cease to operate without the TSS.

“The only option to carry on running our business was to use the TSS.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

“Once we got our heads round that, in fairness the TSS is fine, don’t have any problems with it.”

(Freight forwarder, 250+ employees, facilitates GB-NI trade, has NI presence)

Customs intermediaries who used the TSS in the past

Some customs intermediaries had used the TSS in the past but had since stopped using it. These tended to have only used the TSS infrequently on an ad-hoc basis and had mostly stopped using it due to a low volume of GB-NI trade. This group of customs intermediaries now, either tended to outsource the few declarations they could have used the TSS for, or continued to use the TSS for those few declarations on a very infrequent basis.

“Do not use [the TSS] consistently because we don’t do much trade between NI and GB and where we do, we outsource that part.”

(Freight forwarder, 50 to 249 employees, facilitates GB-NI trade, no NI presence)

Some customs intermediaries who used the TSS on an ad-hoc basis still found it to be a useful platform for their needs, mainly for the reasons mentioned above. A few noted they had used the TSS at the start of January 2021, either once or a few times, but they had stopped using it because it was “clunky” or because their knowledge of the processes had increased over time, and they did not need it as much.

“Currently not using the TSS very often…as there is no need for its use daily. We use [it] once a month, couple of times a month. The TSS is only used as an alternative when support is needed on goods, whether it is registering the company or finding out rules and regulations and any changes… the TSS was mainly used in the start when the company could not understand the rules and data.”

(Freight forwarder, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

Customs intermediaries using alternatives to the TSS

It was easier for some customs intermediaries to use their internal software to facilitate the end-to-end journey for customers. As a result, they chose not to use the TSS because their own systems did it in an effective and integrated manner already. In these cases, the TSS felt like ‘extra paperwork’.

“We’ve got our own system, so we’d be able to facilitate the movement. We wouldn’t use the TSS, we would use our own system anyway.”

(Customs broker, 250+ employees, facilitates GB-NI trade, has NI presence)

5.3 Feedback from customs intermediaries

After asking customs intermediaries on their experience of using TSS and what could improve, several customs intermediaries raised issues relating to TSS registration and security verification processes, customer service, the TSS technical expertise and the potential for TSS to act as a competitor.

TSS registration and security verification processes

Some customs intermediaries raised concerns about the registration and security ID verification process for the TSS. They felt it was overly long and complex, with few benefits for them.

“The TSS calls all start with identity verification. It’s painful and time consuming! I have to speak to them 10 times in a day, there’s 5 minutes going through verification with them.”

(Freight forwarder, 1 to 9 employees, facilitates GB-NI trade, no NI presence)

Some customs intermediaries felt that the system was slow. It was a time-consuming process to complete customs declarations on a large scale. Some felt that, while this had improved from when the service was first launched, the process could still be made quicker. Some customs intermediaries also said they found the tasks involved in using the TSS labour-intensive and tedious, particularly when tracking declarations made by different parties in their supply chain.

“At the beginning of January last year, it was purely a manual process putting things onto the TSS and we were sending 2000-3000 consignments a day so we’d have to manually input [these] customs entries which took all day…. The system was very clunky, very slow… I mean, it’s working better now.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

Customer service

Some customs intermediaries spoke about very long call-centre wait times and lack of responses to queries, which they felt made the service inefficient.

“You’ve got to be able to speak on the phone to people. Sending an email and getting a response 24 hours later… you can’t have drivers waiting there.”

Customs broker, 10 to 49 employees, does not facilitate GB-NI trade, no NI presence

Technical expertise

In comparison to their own organisation, some customs intermediaries felt there was a lack of technical expertise in GB-NI trade amongst staff at the TSS. They felt they could facilitate customs declarations more effectively for customers than the TSS could. Despite this feeling, these customs intermediaries used the TSS occasionally because it was available and sometimes the only option in their work context. One customs intermediary said that they had redone customers’ declarations after their unsuccessful experiences with TSS.

“We felt we have more expertise and knowledge than the people running the TSS had. We pick up clients from people who have gone the TSS route and have got stuck or found it too cumbersome. We can do customs declarations much more quickly and easily.”

(Haulier, 50 to 249 employees, facilitates GB-NI trade, no NI presence)

Another customs intermediary felt the TSS was not nuanced enough for controlled goods. The specialist knowledge needed about additional checks was not readily available, either by phone or email communication. There were also some limitations to TSS system functionality for these controlled goods.

“The only option of our goods in the controlled goods section on the TSS is weapons, but our goods are not weapons, they are explosives for mining, for fireworks companies’ things like that, but we must declare them as weapons which then asks a whole series of questions which are not relevant to our goods.”

(Freight forwarder, 1 to 9 employees, facilitates GB-NI trade, no NI presence)

The TSS was perceived to act as a competitor by a small number of customs intermediaries

Some customs intermediaries felt the TSS devalued their work: customers could access, for free, a similar service to what customs intermediaries provided. This meant that some customers would go to the TSS first and would come to customs intermediaries afterwards, sometimes with lower expectations of price.

“It takes away potential business from us: firms go to the TSS rather than using us.”

Customs broker, 1 to 9 employees, facilitates GB-NI trade, no NI presence

6. Wider support in facilitating GB-NI trade

This chapter provides insight on support used by customs intermediaries facilitating and not facilitating GB-NI trade, outside of the TSS.

6.1 Wider support used for facilitating GB-NI trade

Aside from the TSS, types of support accessed by customs intermediaries included the UK Customs Academy (UKCA), HMRC guidance on GOV.UK, other companies in the same industry, the Northern Ireland Customs Trading Academy (NICTA), trade bodies and local HMRC representatives.

The Customs Declaration Service (CDS) / UK Customs Academy / HMRC GOV.UK

The most common types of support that customs intermediaries reported using were CDS, approved training providers and HMRC GOV.UK.

Several customs intermediaries felt that the general navigation on the CDS and HMRC GOV.UK website was not intuitive or user-friendly. Some felt that Information was “scattered” throughout the website and could be generic, unclear, and not relating to the specific goods being moved. This resulted in some customs intermediaries spending considerable time looking for information relevant to them and speaking to help-desk staff relating to goods they moved.

Whilst there was appreciation for the fact that customs training was available via approved training providers, feedback on the training was mixed. Some customs intermediaries felt that training courses were too theoretical without examples of real-life scenarios, something they considered to be important. They believed that the theory did not always translate to real life scenarios.

“One of our staff went on a course and it was theoretical: it was an HMRC publication that was being taught. It didn’t get into real life scenarios.”

(Customs broker, 1 to 9 employees, facilitates GB-NI trade, no NI presence)

Other companies in the same industry

Some customs intermediaries revealed there was an informal network of information sharing between those who were involved in GB-NI trade. Larger international parcel delivery companies with well-established processes, or hauliers, were used for outsourcing. There were examples of customs intermediaries’ partners sharing training and knowledge with them openly to make the trading process smoother.

Northern Ireland Customs Trading Academy (NICTA)

Awareness of NICTA was low but, those that had heard of NICTA and used the platform or attended the webinars, reported that it had been helpful to a certain extent.

Trade bodies / Local HMRC representatives

Less frequently mentioned wider support used by customs intermediaries included information and materials provided by trade bodies. Customs intermediaries who received information and material from trade bodies typically received this via email.

Some customs intermediaries reported that information and material received from their trade bodies was user friendly but not always very precise. Information provided was more generic and not specific to the goods they moved.

Local HMRC or trade representatives

Support from local HMRC representatives or trade representatives on the ground was also mentioned by some customs intermediaries. For example, one customs broker with an NI presence revealed that they had a line of communication with local HMRC representatives in NI.

“Everyone knows everyone in NI. Whenever something goes wrong, veterinary staff / port staff are sitting down with them to explain what they need to do.”

(Customs broker, 250+ employees, facilitates GB-NI trade, has NI presence)

7. Future support and improvements

This chapter explores the desire to expand GB-NI operations and provides insight on a range of future support that could help with doing so. It also looks at improvements in facilitating GB-NI trade suggested by customs intermediaries participating in the research study.

7.1 Desire to expand by those facilitating and not facilitating GB-NI trade

Desire to expand the facilitation of GB-NI trade was limited, particularly among those not currently doing so. Those who were keen to facilitate more GB-NI trade tended to be larger companies already well set-up to deal with it. Some other customs intermediaries were keen to expand, in theory, but thought there would be very limited demand.

Some customs intermediaries explained that they currently only facilitated GB-NI trade for their existing customers but would not do so for any new ones in order to keep hold of existing customers and not risk losing them whilst having no active interest in pursuing further GB-NI business.

A key barrier for customs intermediaries was uncertainty around how the market would evolve and whether there would be large enough demand to warrant additional investment of time and resources. Caution from customs intermediaries meant they were unprepared to invest in staff, systems and processes that were subject to changing in the immediate future.

“Yes… we want more business but until we get some clarity on the political situation, it’s difficult to know how to invest and where to invest.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade, no NI presence) 

As a result of EU Exit and Coronavirus (COVID-19), several customs intermediaries seemed to have enough work and, therefore, sought to address predictable and anticipated needs elsewhere, not often in the GB-NI trade market.

Where expansion of facilitation of GB-NI was appealing, the typical approach seemed to be via organic growth and following where customers wanted to trade goods.

7.2 Support needed to improve capacity and ability of customs intermediaries to increase facilitation of GB-NI trade

Streamlining processes

Reducing or streamlining some processes in NI was mentioned by several customs intermediaries as the way to increase the facilitation of GB-NI trade. The main benefits of this could be moving goods to and from NI more easily, which could lead to saving time and money.

“It would speed things up with it giving more time to get on with other jobs. Less man hours would be spent reducing cost as less time is spent which costs money with the company.”

(Freight forwarder, 10 to 49 employees, facilitates GB-NI trade, no NI presence) 

Customs intermediaries suggested this could be done through the following:

• removing some inspections on goods going to NI
• having a system that does not involve declarations for each individual parcel
• having ‘red’ and ‘green’ channels for ‘at risk’ verses ‘not at risk’ goods

“Green channel for goods requiring no controls, would be domestic and like it is now. Red for ones that required declaration. If [we had to use the] red channel we’d be able to facilitate using own system. As long as it’s all clear, that would be a clear route to go down.”

(Fast parcel operator, 250+ employees, facilitates GB-NI trade, has NI presence) 

• having an online portal where customs intermediaries can generate documentation themselves instead of having their often-inexperienced customers do this
• having an online system where one can pre-approve shipment details with no issues on the other end

“Pre-clearance, online, digital, full visibility. If a shipment does not get preapproved, it does not get shipped and, that way, I do not need to worry about it once it has gone. You can close the file; it is done and it is dusted.” 

(Freight forwarder, 10 to 49 employees, facilitates GB-NI trade, no NI presence) 

• ability to print declarations at place of loading and registering on trailer number instead of truck number which makes the processes quicker
• having more information and help available to drivers to reduce the need for them to search for information

Communicating changes to requirements and processes more clearly and quickly

Several customs intermediaries felt that, communicating any changes to requirements and processes more clearly as soon as possible, would improve their capacity and ability to increase the facilitation of GB-NI trade. Some felt this could give them the time to prepare and plan for any forthcoming changes, in turn saving them time and money.

“The political situation with Northern Ireland… there’s no one answer. I would just like to know one way or other so I can plan.”

(Haulier, 10 to 49 employees, facilitates GB-NI trade, no NI presence)

Dedicated government helpdesk with increased staffing

Some customs intermediaries felt that having a dedicated government helpdesk with increased resource could save them time and money when calling; improving their capacity and ability to increase facilitation of GB-NI trade. In particular, some customs intermediaries noted that it would be useful:

• to have help-desk staff who could answer questions without being redirected to the TSS, HMRC and GOV.UK websites
• to have provision of ad-hoc, personalised phone support to answer specific queries relating to the movement of goods. This was particularly important for customs intermediaries moving niche goods such as military goods and explosives

“Need ability to field ad-hoc, specific questions requiring expert customs knowledge to resolve. HMRC are not currently providing this and just signpost to web resources if contacted.”

(Customs broker, 1 to 9 employees, facilitates GB-NI trade, no NI presence) 

Targeted support or messaging directly to customs intermediaries’ customers

Some felt that targeted support or messaging sent directly to their customers could speed up customs intermediaries’ requests for information required. This could also lead to their customers having a better understanding of GB-NI trade, which, in turn, would reduce the amount of time customs intermediaries spent guiding their customers through these requirements.

This could improve customs intermediaries’ capacity and ability to increase facilitation of GB-NI trade. Some felt that key messages could contain more information on basic requirements for moving goods, an outline of the process of moving goods, where available information could be found and contact details for further support.

“Some sort of campaign to say: ‘this is now possible. In this area, you can do this very easily and here’s how.’ It’s about knowing that it can be done and here is the process. Here are the basic routes, here is what you need to move goods from UK.”

(Customs broker, 250+ employees, facilitates GB-NI trade, has NI presence) 

Greater availability and accessibility of NI customs intermediary / agent details

Some felt that increasing the availability and accessibility of information about GB-NI trade could encourage customs intermediaries to expand into the GB-NI market.

Some felt that a directory of contact details for GB-based and NI-based customs intermediary companies could encourage customs intermediaries to expand to the GB-NI market. This was because it could enable professional relationships to be built more easily across the nations and to have someone on the ground across the border in turn saving time and money.

“Introduction service between agents GB and NI… A directory which makes introductions between companies in GB and NI.”

(Customs broker, 10 to 49 employees, does not facilitate GB-NI trade, no NI presence) 

Financial Support

Financial support was welcomed as a way to encourage expansion into the GB-NI market, particularly for smaller companies. Specific suggestions included possible subsidies, recruitment assistance or financial support for those facilitating more challenging freight.

“Some kind of financial assistance to make it attractive for us to expand. If they were to offer another grant to acquire more staff, a bit for IT perhaps.”

(Freight forwarder, 1 to 9 employees, facilitates GB-NI trade, no NI presence) 

8. Technical Appendix

Sample and recruitment

Sample for this research came from three sources:

• sample provided by HMRC. This included customs intermediaries that were based in GB and NI that had submitted Customs Handling of Import and Export Freight (CHIEF) declarations to HMRC and some customs intermediaries that had been extracted from the TSS records. After sample cleaning and de-duplication this sample comprised of 89 records
• sample provided by Ipsos that was made up of customs intermediaries who had taken part in HMRC’s Customs Intermediaries capacity and sizing survey (and agreed to be re-contacted for other similar research). After sample cleaning, de-duplication, and filtering on relevant records this sample comprised of 161 records
• free-find sample taken from publicly available sources such as register of customs agents and fast parcel operators on GOV.UK

Criteria Research, a specialist recruitment supplier, undertook the recruitment of interviews using the sample supplied. Target quotas were set on characteristics such as customs intermediary type, size, and location of business presence, to ensure that interviews were achieved with a range of different types of customs intermediaries.

Ahead of recruitment, all leads from HMRC and Ipsos were sent an advance email or letter informing them about the research and giving them the opportunity to opt in or opt out. To encourage participation, we reassured participants about confidentiality and provided clear information about the research and the importance of taking part. An email address was also included to get in touch with Ipsos, in the event of any questions.

Recruitment was guided by a screening questionnaire agreed with HMRC, to ascertain eligibility and confirm which quota group the customs intermediary fell into. Customs intermediaries that were eligible and willing to take part in an interview were liaised with by Criteria Research to agree on the most suitable time for the interview to take place. Ipsos were flexible when booking appointments (for example Ipsos offered evening interviews or early morning interviews where necessary) so that appointment slots suited participants and encouraged participation.

Once interviews were confirmed by Criteria Research, an interviewer from Ipsos would be assigned the interview and would send them a confirmation email and calendar invite for when the interview was due to take place. Criteria Research also sent a reminder about the interview to all participants 24 hours prior to when the interview was scheduled to take place.

Interview profile

A breakdown of the customs intermediaries that took part in the qualitative research is shown below.

Table 7.1: Number of interviews by type of customs intermediary

Customs intermediary type	Total
Customs broker/agent	10
Express operator/fast parcel operator	4
Freight forwarder/shipping agent	13
Haulier	3

Base: All customs intermediaries (30)

Table 7.2: Number of interviews by role in relation to GB-NI trade

Customs intermediary role	Total
Currently submitting declarations between GB-NI (in-house or a mix of in-house and outsourcing)	14
Currently facilitating declarations between GB-NI (outsourcing only for this trade route)	2
Able to submit or facilitate declarations but not currently doing so between GB-NI	14

Base: All customs intermediaries (30)

Table 7.3: Number of interviews by size of customs intermediary

Customs intermediary size	Total
0 to 9 employees	13
10 to 49 employees	8
50 to 249 employees	5
250+ employees	4

Base: All customs intermediaries (30)

Table 7.4: Number of interviews by whether customs intermediary has a business base in NI

Customs intermediary size	Total
Has a business base in NI	9
Does not have a business base in NI (based in GB)	21

Base: All customs intermediaries (30)

Key research questions

With these objectives in mind, the key research questions were:

• what are the overall perceptions and experiences of customs intermediaries facilitating trade with NI, and particularly GB to NI?
• what barriers have they experienced in carrying out or expanding their services of facilitating trade between NI and GB and in particular for trade from GB to NI?
• what existing support or guidance do customs intermediaries use to facilitate / submit customs declarations?
• what additional support, or guidance would help customs intermediaries to increase capacity for NI to GB trade, or expand their service offer to cover NI to GB trade if not already doing so?
• what have been the experiences of customs intermediaries who use the TSS? For those who do not currently use it, what is their impression / perception of the TSS?
• without or aside from the TSS, what innovations or opportunities could customs intermediaries identify to expand and reinforce their capacity to facilitate trade between GB and NI?

Depth interview topics

The 45 to 60-minute depth interviews explored the following topics:

• background: overview of the business including number of employees, location of business bases, customs intermediary role, type of declarations being made / processes facilitated, and type of customer base
• perceptions and experiences of GB-NI trade: First things that came to mind when thinking about facilitating GB-NI trade, why this was, whether other customs intermediaries held the same view, experience of facilitating GB-NI trade since January 2021 (if they were currently doing so), how easy or difficult it was, whether support was needed in doing so, key things that enabled facilitation of trade between GB-NI and what would help them in facilitating more GB-NI trade
• barriers or challenges in GB-NI trade: Why those who do not currently facilitate GB-NI trade do not do so, what demand for this service was like, what the main barriers were in doing so, what challenges were faced by those currently facilitating GB-NI declarations and whether there were any barriers that were preventing them from expanding their GB-NI facilitation function
• current support used: What trading and declarations support customs intermediaries were aware of in relation to NI trade, whether they had used any trading and declarations support to help in relation to GB-NI trade and how useful this was
• the Trader Support Service: Whether customs intermediaries had heard of the TSS, what their first thoughts were about it, their experience of using it (if they had used it), including when they started using it, how frequently they used it and the impact it had on their business, and for those that had not used it, why they had not
• additional support or guidance to increase capacity or expand service offer: whether their company was interested in expanding operations to facilitate GB-NI trade, whether they would need support to do so and what type of support that would be

Analysis

Our approach to analysis of the interviews included:

• creating thematic analysis grid: An Excel data grid which covered the key question areas in the discussion guide and allowed interviewers to write up a comprehensive set of coded field notes for each interview
• field notes and analysis grid: For each interview, the researcher wrote a detailed set of notes in the Excel analysis grid, including key characteristics about the participant (collected at recruitment stage) and their responses to each question area. Interviews included both summarised responses to different question areas and verbatim comments where these were useful and possible
• data analysis: Once fieldwork and all field notes were complete, the project team analysed the data in the analysis grid, with rolling analysis taking place after each interview, splitting findings into the broad topics and themes of interest. The field team met during the fieldwork period to talk through interviews and discuss themes and findings for the research. A joint analysis session was held with HMRC in attendance to discuss top line findings and provide a verbal overview of the latest emerging findings from the interviews part way through fieldwork
• final analysis session: After the fieldwork period, the team met again for a final analysis session. The session focused on findings in relation to the research objectives rather than discussing specific cases