Insights

BREXIT : Declaration or Innovation

Written by Robert Hardy | Mar 19, 2026 8:55:43 AM
In the years leading up to Brexit, the UK logistics sector braced for what was widely described as an unprecedented customs shock. Around 145,000 traders were expected to complete customs paperwork for the first time, with early government estimates forecasting 200 million additional declarations annually.

The National Audit Office’s 2019 modelling illustrated the enormity of the task and triggered a scramble for customs capacity that simply didn’t exist at the time.

Before Brexit, the customs intermediary market had been flat for years, offering little incentive for brokers to invest in staff or systems, especially as Brexit deadlines repeatedly shifted and political uncertainty persisted. As 2020 progressed and freight forwarders were unable to secure reliable customs support, many began building their own in‑house solutions. Salaries for staff with even modest customs experience surged, and companies repurposed workers from entirely unrelated professions, hairdressers, bar staff, warehouse operatives, accountants, putting them through accelerated customs training programmes in preparation for “day one,” whenever it might arrive.

When Brexit finally took effect, HMRC initially adopted a “flow over control” approach, prioritising the uninterrupted movement of goods over strict compliance. Freight moved, mistakes were tolerated, and freight forwarders’ new customs operations reaped significant financial rewards. An additional £40–£50 per consignment transformed their margins, turning customs services into a lucrative, if risky, revenue stream during 2021.

However, the boom quickly stabilised. Forwarders largely chose to process customs only for the shipments they handled themselves rather than pursuing standalone customs agency models. Meanwhile, established customs brokers, who had survived the chaotic early phase began reclaiming market share, targeting traders that had initially dispersed their declarations across multiple forwarders simply to keep goods flowing.

By 2023–24, revenues for many freight forwarders had plateaued or begun to decline. The honeymoon was over.

 

Several factors explain the downturn

    • Growing trader sophistication with Incoterms

      Importers increasingly understand that under terms such as DAP, they are not the exporting shipper or the forwarder, they control who performs the import clearance. This has empowered buyers to consolidate their customs activity with specialist agents rather than rely on whichever forwarder is carrying the load.
    • Customs agents have regrouped and become aggressive

      The expected 200 million declarations never materialised, volumes are nowhere close, so specialist brokers have been actively reclaiming business from forwarders.
    • Compliance pressure has surged

      HMRC’s tightening posture, supported by new transparency through Trade Reporting & Extracting (TRE), has pushed traders to rationalise and centralise their customs processes. Multiple agents across multiple lanes now represent an unnecessary compliance risk.

As a result, many forwarders face shrinking customs revenue and are shifting from growth to cost control, with some even offshoring their customs functions. Yet liabilities have hardened: the era of “just file the form” is over, and significant penalties have exposed weak practices and inexperienced staff.

Many customs clerks who were once in short supply are now openly seeking work.

The question now for freight forwarders is whether to scale back or rethink.

For GB exports, forwarders are encouraged to retain control: the process is simpler, lower‑risk and operationally efficient. But for GB imports, where risk and complexity are higher, the message is clear: stop tying up resources on low‑value transactional work. Instead, collaborate with specialists and focus on value creation.

Finally, many multinational forwarders still rely on maritime‑style processes for EU–GB ro‑ro cargo. This, critics argue, is a fundamental mismatch: these fast‑moving, low‑duty flows more closely resemble parcel/e‑commerce traffic. Recasting them accordingly could reduce friction and prevent Brexit from being more cumbersome than necessary.

Five years after Brexit, the customs landscape continues to evolve. The companies that succeed may not be those doing the most declarations, but those redefining where the real value in customs expertise lies.