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A Voluntary Standard for Customs Brokers: Summary of Public Feedback

Introducing a voluntary standard for customs intermediaries - summary of responses from the consultation.


The UK government aims to create the most effective border in the world by simplifying processes for traders, improving security and biosecurity, and embracing innovation. Customs intermediaries assist traders in moving goods across borders and are crucial in facilitating trade. The government recognises their value but has received mixed feedback on the quality of service provided. Consultations have been held to encourage improvements in the quality and standards of the intermediary sector, including a voluntary standard that could distinguish between the quality of providers.


Overarching views

Respondents showed support for the government's plan to improve customs intermediary sector standards. Many agreed with introducing a voluntary standard to set a benchmark, drive good practice, and improve quality in the sector. Respondents highlighted the need to keep costs reasonable. A few suggested a mandatory regime, but most still endorsed a voluntary standard. Some tax stakeholders also supported a voluntary standard and recommended considering how it would interact with existing standards for tax agents.


Authorised Economic Operator (AEO) status

Authorised Economic Operator Customs Simplification (AEO(C)) is an authorization available to traders and customs intermediaries. AEO holders are fully tax compliant, keep good customs records, have financial solvency, and practical experience in customs matters. It offers faster application processes, a reduction in guarantees and deferment accounts, and fewer customs checks.

A voluntary standard for customs intermediaries would signify a mark of excellence, focused on providing clarity on best practices across essential areas, including customs knowledge, customer service, and staff development.

The government concludes that AEO(C) and a voluntary standard can work together, but a standard solely for customs intermediaries is necessary.


Objective of a voluntary standard

The survey respondents suggested that educating intermediaries and traders is important, and the standard should promote quality and consistency among customs intermediaries. The standard should be suitable for independent third-party certification to provide assurance, credibility, and consistency.

While some felt that HMRC should be responsible for certification, others disagreed due to the potential cost and the ability of certification bodies to assess the diverse intermediary population. The majority agreed that certification bodies should be independently assessed and accredited to ensure impartiality and consistency of certification.

Based on the feedback, the government believes that the standard's primary objective should be to promote quality and consistency. The standard should be designed to be suitable for independent confirmation that intermediaries meet it (certification), and UKAS should be responsible for assessing certification bodies.


Design and implementation

Most survey participants agreed a voluntary standard should be created through a credible and collaborative approach involving the government and stakeholders. However, some were skeptical about its effectiveness due to existing standards, varying business models, and ambiguity around the design process. Suggestions to encourage usage included promotion, guidance, training, and official recognition. Certification could confer privilege or incentive, and intermediaries who achieve certification could be publicly listed. Other suggestions included marketability, reliance on market forces, and distinguishing between the voluntary standard and existing standards. The government believes a credible and collaborative approach is necessary to design a standard that is freely accessible and achievable for all customs intermediaries providing a good-quality service.


Content

Most respondents supported the proposed content elements with the need for further clarification, refinement, and flexibility. Several existing standards were suggested for consideration. Suggestions for additional content included focusing on intermediaries’ error/correction ratios, supporting environmental sustainability, and a modular approach.

Other suggestions included a transparent fee structure, a recommended timeframe for correcting errors, staff retention rates, digital literacy, data privacy requirements, ethical practices, and collaboration with customs authorities.

Concerns were raised about the potential cost and burden of adhering to the standard, especially for smaller intermediaries. Questions were also raised on the practicality, levels and measurement of commitments to continuing professional development, and the type and availability of insurance cover that would be expected.



Training and educational offerings for the customs intermediary sector

Intermediaries use external training to keep up with changing trends and regulations, cover topics they can't facilitate in-house, and obtain customs qualifications. However, some find external training too general or costly. Most intermediaries provide internal training that is tailored to their business needs. While some prefer internal training, most find both internal and external training beneficial and suggest combining the two. There is no consensus on whether there are currently sufficient training offerings available, but most suggest ways to reference competency and education within a voluntary standard. The government intends to reflect the valuable and diverse types of training and educational offerings in the standard, incorporating both formal training and on-the-job experience.


Next steps

The government has decided to introduce a voluntary standard for customs intermediaries, considering the feedback received from stakeholders during the consultation. The government intends to work with the British Standards Institution to develop a strong and credible standard suitable for certification, in partnership with industry. The process will begin in Spring 2024 and will involve public consultation.

List of consultation questions

  1. Question 1: What type of business are you? (such as clothes retailer, car manufacturer, freight forwarder, fast parcel operator, haulier)

  2. Question 2: What is the size of your business? (Micro: 0 to 9 employees, small: 9 to 49 employees, medium: 50 to 249 employees, large: 250 or more employees)

  3. Question 3: If applicable, how many movements do you make per year? Are they imports, exports, or both?

  4. Question 4: If applicable, how long has your business been importing or exporting goods, or supporting traders to import/export if you are an intermediary?

  5. Question 5: Do you agree that the primary objective of a voluntary standard for customs intermediaries should be to promote quality and consistency among customs intermediaries with an indication of quality, rather than to predominantly inform and educate? If not, what do you consider should be its primary objective, and why?

  6. Question 6: Do you agree that a voluntary standard for customs intermediaries should be suitable for independent, third-party verification that the standard has been met, in other words, certification? If not, what alternative form do you think the standard should take, and why?

  7. Question 7: Do you think certification bodies that provide that external verification should themselves be checked to ensure they are capable of assessing conformity to the standard, in other words, accreditation? Please provide details to explain your answer.

  8. Question 8: Do you agree with the key principles for the design and implementation of a standard as set out above (in other words a credible, collaborative approach between government and stakeholders, freely and readily accessible, monitored for usage and effectiveness)?

  9. Question 9: In your view, how could usage of the standard be encouraged?

  10. Question 10: What are your views on the above suggested components of the voluntary standard? Please include any suggestions for potential specific requirements within these general areas.

  11. Question 11: Should any of the suggested components not be included?

  12. Question 12: Are there any areas missing that you feel should be included?

  13. Question 13: Do you anticipate any unintended consequences arising from including any of the suggested content?

  14. Question 14: Do you envisage any issues with measuring against these areas for the purposes of certifying intermediaries against this standard?

  15. Question 15: If you are an intermediary, do you or your organisation use external training offerings? Please provide details to explain why/why not.

  16. Question 16: If you are an intermediary, do you or your organisation provide internal training? Please provide details to explain why/why not.

  17. Question 17: If you answered ‘yes’ to Question 15 or Question 16, what aspects of your work do you use external and/or internal training for? If you use both external and internal training, please explain if you use them for different aspects of your work (such as external training on customs processes, but internal training on using CDS).

  18. Question 18: If you answered ‘yes’ to both Question 15 and Question 16, have you found either external or internal training to be more beneficial to your day-to-day work?

  19. Question 19: Do you think there are currently sufficient, adequate training offerings available to intermediaries? Please provide details to explain why/why not.

  20. Question 20: Considering the training and qualifications available to and undertaken by intermediaries, how do you think competence or education should be referenced within a voluntary standard? Please provide details to explain your answer.


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