The UK’s Future Independent Customs Regime – A SIITACE Summary


The 2025 UK Border Strategy sets out the government’s vision for the UK border to be the most effective in the world. Central to this vision is an independent UK customs regime that is business-friendly and responsive to the needs of the wider border network. The government announced in April that no further import controls on EU goods would be introduced this year and committed to publishing a Target Operating Model (TOM) in due course. HMTreasury and HMRC published a Call for Evidence (CfE) in February 2022 that sought views from businesses and the wider border industry. This SIITACE summary of responses plays back some of the key insights and suggestions that stakeholders provided. SIITACE had made a detailed contribution and was one of the 85 stakeholders that replied. 

The government recognized that there are more opportunities to simplify, and improve the UK’s customs system beyond the areas covered in this CfE.

Customs Agents

Customs agents or representatives play a key part in the customs procedure for many merchants. Most of the responding firms were medium-sized (50-249 workers) or big (250+ employees). Most had over 10,000 foreign trades every year and 20 years of expertise. The intermediaries chapter asked about access, quality, and the sector’s future.

In general, stakeholders indicated that engaging an intermediary was cost-effective. Several mentioned cost differences between middlemen. Some parties proposed licensing or standards. Intermediaries cited several price issues. Two-thirds of respondents thought utilizing an intermediary is cost-effective.

A modest minority of respondents wanted to handle import declarations in-house. Overall, the assessment on intermediary services was divided.

Simplified Customs Declarations Process (SCDP)

The study assessed Simplified Customs Declarations knowledge and utilization (SCDP). SCDP received an excellent response. SMEs and bigger merchants have varying levels of SCDP knowledge. The SCDP application form was extensive and had a poor user interface. A high proportion of respondents wanted stronger authorization advice. Suggestions suggested automating the process by pre-filling data fields with HMRC information and allowing merchants to get approved for all streamlined processes based on one master authorization’ Simplified Declarations Procedure was preferred over Entry In Declarations Records (EIDR) for releasing commodities at the border. Most traders consider extra declarations should be due between the 7th and 15th of the following month.

Extending the deadline would offer dealers more time to make proper statements and share the burden. Smaller dealers were less likely to request an extension since they handle fewer items. They questioned respondents about the aggregation of supplemental declarations (SCDP), where merchants may minimize the number of HMRC disclosures by combining many consignments into one. A tiny percentage of respondents utilize aggregation and say it would be good to simplify it by requiring fewer fields or doing it periodically. Self-assessment and aggregation didn’t save participants money compared to optimal SCDP.

Most respondents didn’t utilize SCDP for exports since export declaration procedures are easier.


Several of the respondents said that the expenses of IT were a concern. These expenditures included software licensing and employee training. The necessity for a Customs Comprehensive Guarantee (CCG) was cited by almost all of the respondents as the factor that resulted in the highest expense for them. The respondents had limited knowledge of guarantee waivers and had a poor understanding of the legal dangers that may arise, including the potential of defaulting on a guarantee.


Half of the respondents used Transit for the purpose of exporting goods to the EU, while one third utilized it for the movement of groupage cargoes. Only a tiny fraction of respondents indicated that they would be willing to move products for third parties utilizing their consignor and consignee status. Other proposals were offered in response to feedback, such as making Transit paperless and enhancing NCTS to allow real-time monitoring of movement. Having the capacity to follow Transit movements in real time and reducing the amount of “dwell time” before products can be unloaded would be very beneficial to traders.

A Joined Up Approach

There was widespread agreement among respondents on the significance of coordinated communication between government departments responsible for border control and the need to provide a centralized access point for all customs data through a single online site. It has been brought to the attention of HM Revenue and Customs (also known as HMT and HMRC) that several stakeholders have provided comments.


A significant portion of the replies offered suggestions for ways in which the government may enhance the existing Authorized Economic Operator (AEO) service. There was agreement for expanding and extending the present offer made by the government to the dealers who are the most reputable and complying.

What comes next

Both HMT and HMRC are grateful for the thoughtful responses provided to the CfE. In the next weeks, this will have an effect on policy. They implement changes to processes and operations based on the suggestions provided by stakeholders. When it comes to policies, the opinions will be taken into consideration as part of the process, particularly in the autumn when the government will be outlining its strategy for a new worldwide border system. SIITACE will continue to offer guidance and support.