Research and analysis

Customs intermediaries wave 8: executive summary (2023)

Updated 29 January 2026

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This publication is available at https://www.gov.uk/government/publications/research-into-the-customs-intermediaries-sector-waves-3-to-5/customs-intermediaries-wave-8-executive-summary-2023

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

1. Background and methodology  

This report presents findings from the eighth wave of research with customs intermediaries, conducted on behalf of HM Revenue and Customs (HMRC), alongside a piece of follow-on qualitative research on the Bulk Import Reduced Data Set (BIRDS).  

Wave 8 of the survey examined intermediaries’ experiences of service provision, changing customs procedures, and challenges in the market. For findings covering a broader set of themes within the intermediary sector, please refer to wave 1, wave 2, and waves 3 to 5 of the research.  

The wave 8 survey took place between 5 October and 1 December 2023. In total, 493 interviews were conducted with intermediaries, including 252 who had taken part in earlier surveys. In addition, 20 interviews were conducted with 20 intermediaries between 10 January and 1 February 2024. 

2. Key findings from the wave 8 survey 

  1. Around 3 in 10 customs intermediaries reported that they had already transitioned to the Customs Declaration Service (CDS) for exports, an increase from wave 7 (from 3% to 28%). Among those who had not fully transitioned, 8 in 10 (81%) felt confident about doing this successfully.

  2. Almost half of customs intermediaries were registered with the Goods Vehicle Movement Service (GVMS), and of these 9 in 10 (92%) felt confident that the service would process declarations for goods moving through borders accurately and quickly. 

  3. Full customs import declarations generally took more time to complete than export declarations and safety and security entry summary declarations (ENS). Half of intermediaries (52%) noted that the type and complexity of declarations determined how much they charged for a declaration.

  4. Around 6 in 10 intermediaries (59%) had a supply chain management system in place, with half having a system for at least 5 years. A range of costs was given for implementing and operating the system among intermediaries who were able to provide an amount.

  5. Around a third of intermediaries (35%) felt there was at least one aspect of the sector that needed improvement. Among those who felt it was difficult to demonstrate the quality of service, 56% indicated that this was due to lots of competition within the market.

3. Key findings from the Bulk Import Reduced Data Set (BIRDS) research 

  1. BIRDS is primarily used for the movement of B2C goods from e-commerce sites such as Ebay, Amazon, Teemu, Shein, Alibaba and Tik Tok shop.

  2. Intermediaries tended to manage the submission of BIRDS declarations themselves, with some completing these declarations manually and others using automated systems. 

  3. Compliance checks for goods moved and cleared under BIRDS centred on whether goods met the £135 value limit, but intermediaries conducted these checks in different ways.

  4. Intermediaries generally liked the BIRDS system, with suggestions for improvement focused on increasing the £135 threshold and reducing uncertainty around compliance.

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