Brexit, Customs Intermediaries and the New British Standard: What UK Traders Need to Know

Brexit changed the way goods move between the UK and the European Union, but its impact on customs went far beyond introducing additional paperwork.

The volume of customs declarations increased dramatically. Businesses that had never previously needed to complete import or export declarations suddenly had new customs responsibilities. More customs agents and brokers were needed, HMRC systems had to adapt and the customs intermediary sector expanded to meet unprecedented demand.

But rapid growth raised another important question:

How can traders be confident that the customs intermediary they choose is providing a consistently high-quality service?

In this episode of The Cargo Couch, Logicom Hub’s Sam Stretton is joined by Mark McGuire and Michael Pash from HM Revenue & Customs (HMRC) to discuss the impact of Brexit on UK Customs, the development of a new British Standard for customs intermediaries, proposed mandatory registration and what HMRC needs from industry as it looks towards the future.

How Did Brexit Change UK Customs?

Brexit represented a major change for UK Customs. Before leaving the European Union, much of the UK’s customs policy was determined at EU level. Following EU Exit, the UK needed to operate its own independent customs regime. That also meant a major increase in customs activity. Goods moving between the UK and EU that previously did not require the same import and export customs formalities now needed declarations.

Mark explains that this meant HMRC had to significantly increase its capacity while simultaneously developing new customs processes and systems. There was also the practical challenge of keeping goods moving through busy routes such as Dover-Calais, where traditional customs models were not suitable for the high volume of vehicles needing to move quickly through ports.

One response was the introduction of the Goods Vehicle Movement Service (GVMS) and the pre-lodgement model, allowing customs processes to take place without vehicles simply sitting at the border waiting for clearance. At the same time, HMRC was transitioning from the long-established CHIEF customs system to the Customs Declaration Service (CDS). Brexit did not create that system change, but it significantly increased the scale that the replacement system needed to accommodate.

Brexit Created Huge Demand for Customs Intermediaries

The changes did not only affect HMRC. Importers and exporters suddenly needed significantly more customs support. That created enormous demand for customs intermediaries.

The term covers organisations such as:

• customs agents;
• customs brokers;
• freight forwarders;
• express or fast-parcel operators; and
• other organisations submitting customs declarations on behalf of traders.

During the run-up to Brexit, government support was provided to help the sector increase its capacity, including funding to help intermediaries develop capability and recruit people to complete customs declarations. The capacity was needed. But once the immediate pressure of Brexit had begun to settle, attention increasingly turned from simply asking “Do we have enough customs intermediaries?” to asking “What quality of service are traders receiving?”

Why Did HMRC Start Looking at Customs Intermediary Standards?

Following the end of staged customs controls, HMRC carried out work to better understand the customs intermediary sector. A 2022 call for evidence found that, generally, businesses could find someone to help them move goods. The bigger concern was consistency.

While most intermediaries were providing a good service, HMRC found evidence of mixed quality and heard that some traders were struggling to identify high-quality customs intermediaries. That led to an important question: Could an agreed industry standard help traders recognise what good customs intermediary service should look like?

The result was the development of the Customs Intermediaries Standard.

What Is the Customs Intermediaries Standard?

The new standard is formally known as:

PAS 41201:2026 – Customs intermediaries: Preparation and submission of customs declarations — Specification. It was developed with the British Standards Institution (BSI), HMRC and representatives from the customs industry. Importantly, it is not an HMRC authorisation.

As Mark and Michael explain during the podcast, the intention was not for HMRC to simply write a set of rules and impose them on industry.

Instead, the standard was developed collaboratively with:

• customs intermediaries;
• traders that use intermediaries;
• trade associations;
• customs specialists; and
• other industry representatives.

HMRC participated in the process, but BSI led the development of the standard. That distinction matters. The government describes the standard as having been developed “by industry, for industry”, with the aim of improving quality and consistency and helping traders make better-informed decisions when selecting a customs intermediary.

What Does the Customs Intermediaries Standard Cover?

The standard looks at much more than whether somebody knows how to submit a customs declaration.

The podcast highlights areas including:

• customs knowledge;
• continued professional development;
• customer onboarding;
• due diligence;
• auditing;
• customer service;
• communication;
• correcting errors;
• checking supporting documentation; and
• maintaining appropriate procedures.

A good customs intermediary should not simply take information from a trader and submit it without question. They should understand the customer, review the information being supplied and ask appropriate questions where something needs clarification. That can benefit both parties. For intermediaries, it provides an agreed benchmark of professional practice. For traders, it provides a clearer idea of what they should expect from the organisation representing them to Customs. Official government guidance similarly highlights areas such as transparency, continued professional development and due diligence as key elements of the standard.

Why Does This Matter for Importers and Exporters?

Choosing a customs broker should not simply come down to price.

The intermediary may be handling declarations that affect:

• customs duty;
• import VAT;
• commodity classifications;
• customs procedures;
• origin information;
• licensing or restrictions; and
• the movement of goods across the border.

Errors can result in delays, additional costs and potentially HMRC compliance activity. The new standard gives importers and exporters another tool for assessing who they work with. During the podcast, Mark explains that larger traders are already beginning to refer to the standard when carrying out tender exercises for customs agents.

For traders, that could mean asking potential customs partners:

Do your procedures meet PAS 41201?

How do you demonstrate staff competence?

What due diligence do you carry out?

How do you correct errors?

What evidence can you provide that you meet the standard?

Those are useful questions regardless of whether the relationship is new or has existed for years.

Is the British Standard Mandatory?

No.

At present, PAS 41201:2026 is voluntary.

Customs intermediaries can review their processes against the standard and, where they meet all applicable requirements, state that they comply with it. The standard is publicly available, meaning traders can also review it and understand what they should expect from an intermediary. View the Customs Intermediaries Standard on GOV.UK

Can Customs Intermediaries Become Certified?

This is another important distinction. Publication of the standard is the first stage. A separate certification scheme is being developed to determine how organisations will formally demonstrate compliance. Once available, certification will be undertaken independently rather than by HMRC. Certification bodies will need to be appropriately accredited through the United Kingdom Accreditation Service (UKAS).

Until the certification framework is available, organisations can assess themselves against the standard and work towards compliance. But simply saying that a procedure exists is not enough. One of the points emphasised during the podcast is that the requirements need to be provable. If a trader wants evidence that an intermediary follows a particular part of the standard, the intermediary should be able to demonstrate how that requirement is actually being met in practice.

What Is the Difference Between PAS 41201 and AEO?

Another question discussed in the podcast is how the Customs Intermediaries Standard differs from Authorised Economic Operator (AEO) status. They are not the same thing. AEO is an internationally recognised customs authorisation, with requirements relating to areas such as customs controls, financial standing, record keeping and supply chain security. PAS 41201 has a different focus. It is more customer-facing, looking closely at the relationship between the customs intermediary and the trader.

That includes areas such as:

• customer service;
• transparency;
• onboarding;
• complaints and error handling;
• professional development; and
• service delivery.

Having AEO status therefore does not automatically make the British Standard unnecessary. As the podcast puts it, AEO can demonstrate compliance to HMRC, but that does not necessarily demonstrate the level of service a customer should expect. Government guidance also confirms that the standard does not replace AEO; the two serve different purposes.

Could Customs Intermediary Registration Become Mandatory?

Alongside the voluntary standard, HMRC is now considering another significant change: mandatory registration for customs intermediaries. The proposal would apply to intermediaries submitting customs declarations on behalf of traders.

HMRC has launched a consultation asking industry for views on:

• who should be included;
• who, if anyone, should be excluded;
• minimum registration requirements;
• checks that should take place;
• enforcement; and
• how any new system could be introduced proportionately.

The consultation is open until 21 September 2026. This means businesses still have an opportunity to influence what the future system may look like.

What Minimum Requirements Are Being Considered?

The proposals discussed during the podcast are intended to establish a basic minimum level for organisations wanting to operate as customs intermediaries.

Initial areas discussed include whether the intermediary:

• has its tax affairs in order;
• is financially fit to operate;
• has not been struck off by Companies House;
• has relevant unspent criminal convictions; or
• has a history of serious non-compliance.

The intention is not simply to create another administrative registration.

Who Should Respond to the Consultation?

You do not need to be a customs broker to have a view.

HMRC is specifically interested in hearing from the wider international trade community, including:

• customs agents and brokers;
• freight forwarders;
• importers;
• exporters;
• traders;
• trade associations;
• professional bodies;
• software providers; and
• other businesses involved in moving goods across borders.

During the podcast, Mark and Michael strongly encourage the industry to contribute because any future registration system needs to work for both those providing customs services and those relying on them. Respond to the mandatory registration consultation

What Does HMRC Need From Businesses in the Future?

The conversation does not stop at intermediary standards. Customs is continuing to change. Trade is becoming increasingly digital, supply chains are generating more data and businesses expect greater visibility throughout the movement of their goods. HMRC and HM Treasury are therefore also asking businesses for their views on the future of the UK customs regime.

The current Customs Modernisation call for evidence is looking at areas including:

1. how international trade is changing;
2. the future use of customs data; and
3. whether existing customs authorisations are suitable for an increasingly digital trading environment.

Mark and Michael explain that HMRC wants to understand whether customs systems are keeping pace with the way businesses now collect, store and use supply chain data.

Rather than assuming that today’s customs model will automatically work tomorrow, the question is whether it can evolve alongside modern trade. That includes asking whether the traditional process of submitting customs declarations remains the most efficient way to support compliant trade in an increasingly digital supply chain. The Customs Modernisation call for evidence remains open until 15 September 2026. Have your say on the future UK customs regime

What Should Importers and Exporters Do Now?

There are several practical actions businesses can take.

Review the Customs Intermediaries Standard.
Even if you are a trader rather than an intermediary, PAS 41201 can help you understand what good customs brokerage should look like.

Review your current customs partner.
Ask how they manage staff competence, due diligence, documentation, errors and customer communication.

Consider the standard when tendering for customs services.
It can provide a useful benchmark when comparing potential providers.

Respond to HMRC’s consultations.
Businesses have practical experience of the customs system that policymakers may not see from inside government.

Think about what you need from Customs in the future.
As technology, artificial intelligence, electronic trade documentation and supply chain data develop, consider what would make customs processes more efficient without weakening compliance.

Brexit Was the Beginning of a Bigger Customs Transformation

Brexit placed huge pressure on UK Customs and the customs intermediary sector. The immediate challenge was capacity: making sure there were enough people, systems and processes available to deal with a dramatically increased number of customs declarations. Now the conversation is evolving. The focus is increasingly on quality, consistency, professional standards and the future of the customs system itself.

PAS 41201:2026 represents an important step towards defining what good customs intermediary practice looks like. Proposals for mandatory registration could go further by establishing a minimum entry requirement for organisations acting on behalf of traders. And HMRC’s wider work on customs modernisation asks an even bigger question:

What should the UK customs system look like as international trade becomes increasingly digital?

The answers should not come from government alone.

Customs agents, freight forwarders, importers, exporters and businesses across the supply chain now have an opportunity to help shape what happens next.

Listen to The Cargo Couch

In this episode of The Cargo Couch, Sam Stretton speaks with Mark McGuire and Michael Pash from HMRC about Brexit, the rapid expansion of the customs intermediary sector, the development of the new British Standard and the future of UK Customs.

For anyone working in customs, freight forwarding, importing, exporting, logistics or international supply chains, it is an opportunity to understand not only what has changed since Brexit, but where the industry could be heading next.

Listen to the full episode of The Cargo Couch to hear the complete conversation.

Stay safe, stay compliant.

For more information on customs compliance, contact Logicom Hub:

Phone: 0330 912 5041 or 01608 692177
Email: [email protected]
Website: www.logicomhub.com