While the context of the original Jurassic Park quote is somewhat more dramatic than customs declarations, we think the same principle can apply surprisingly well for businesses considering whether to self-file.
As customs becomes an increasingly important part of international supply chains, more businesses are considering whether they should bring their customs declarations in-house. Advances in customs software and greater availability of online guidance means that, from a technical perspective, it's entirely feasible for many businesses to submit their own import and export declarations without using a customs agent.
However, the fact that a business can self-file does not necessarily mean that they should. The decision requires consideration of much more than the ability to submit a declaration- businesses need to consider the knowledge, systems, resources and ongoing compliance responsibilities required to manage customs effectively.
Why Do Businesses Decide To Self-file?
There are several legitimate reasons why a business might choose to manage their customs declarations internally.
One of the biggest advantages is increased ownership and visibility of customs data by managing declarations in-house, businesses can have greater control over the information being submitted and can integrate customs data more closely with their own internal systems and processes. This can be particularly valuable for businesses with significant volumes, where customs data forms an important part of the wider supply chain and financial reporting.
Cost can also be a factor; for businesses with high and consistent customs volumes, bringing declarations in-house might provide an opportunity to reduce the cost per declaration compared to paying an agent to handle every shipment. This can be particularly relevant where the business already has systems, resources and expertise needed to manage customs internally.
These are all valid considerations and for some businesses self-filing will be the right approach. When considering whether to self-file, businesses need to look beyond the cost of individual declarations and consider the wider investment required to manage customs in-house.
Self-filing Is About More Than Having The Right Software
Having access to suitable customs software is an important part of self-filing, but it is only one part of what is required. Ongoing access to customs software can present a significant cost, particularly when the business needs to consider license fees, implementation, system support, ongoing maintenance and the training required to ensure staff can use the system effectively.
Even once the software is in place, it isn’t able to make the underlying customs decisions on behalf of the business. Someone still needs to determine the correct commodity code, consider the most accurate customs value, and assess the origin of the goods to determine whether a preferential duty rate can be claimed.
These decisions require an understanding of customs legislation and how it applies to the business's specific circumstances; a technically correct submission can still contain incorrect information if the person preparing it doesn't have the necessary customs knowledge. There is also an ongoing requirement to maintain and update that knowledge as customs legislation and border requirements continue to evolve.
There can also be additional costs associated with accessing the systems and locations needed to complete the customs process. For example, at inventory-linked ports, traders may need to purchase a badge to access the relevant inventory system and clear goods at each location. For businesses that only occasionally receive goods through a particular port, the cost of purchasing and maintaining access may not be justified by the volume of declarations being made there; using a customs agent that already has the necessary access can therefore provide a more practical and cost-effective solution.
Along with these direct costs, businesses also need to consider the potential financial and operational impact of errors when managing customs declarations internally. For example, an incorrect commodity code could result in the wrong duty rate being applied, a preferential claim could be invalid without the relevant supporting evidence, or the customs value could be incorrect; each of these could result in underpayment of customs duty and further post-clearance compliance action.
That isn't to say that using a customs agent completely eliminates these risks; ultimately, the importer is still responsible for the information provided to the customs authorities. However, working with an experienced agent can provide an additional layer of expertise and oversight.
The Value of A Customs Agent Goes Beyond Declaration Submission
The role of a customs agent can sometimes be seen as simply preparing and submitting customs declarations. While this is an important part of the service they offer, an experienced customs agent can often provide much wider support. For companies that don't have dedicated customs specialists, access to people who work with customs legislation,
changes and declarations every day can be valuable. An agent can help identify potential issues with classification, valuation, or origin and provide guidance when a shipment falls outside of normal process.
Where a customs agent holds the relevant authorisations and approvals under the Simplified Customs Declaration Process (SCDP), such as Simplified Declaration Procedure (SDP) or Entry in Declarant’s Records (EIDR), eligible businesses may be able to make use of these simplifications through the agent without having to obtain their own authorisation. This can be particularly valuable for businesses that would benefit from customs simplifications but don’t have the volume, resources or desire to establish and maintain their own authorisations. An experienced customs agent can assess whether these options are appropriate and help businesses understand how to incorporate them into their existing supply chain.
The important point is that these opportunities are not always obvious when looking at customs on a declaration-by-declaration basis. When customs is managed entirely in-house, the focus can sometimes fall entirely on ensuring each declaration is submitted correctly and efficiently; a customs agent is able to take a broader view of the business' customs activity and identify whether alternative procedures or simplifications could reduce cost, improve cash flow or make the movement of goods more efficient.
Choosing Between Self-filing and Using An Agent
Ultimately, there is no single correct approach that's right for every business.
For a large organisation with substantial and consistent customs movements, dedicated customs specialists, appropriate software and the resources to maintain their own compliance requirements, self-filing may provide significant benefits. Having direct control over customs data and the declaration process can be particularly valuable where customs is already integrated into the wider organisation.
For other businesses, the investment required to establish and maintain that capability may outweigh the benefits. Using a customs agent provides access to established systems and specialist knowledge without being required to build that infrastructure internally.
Businesses also do not have to choose between managing customs completely in-house and outsourcing all declarations. A hybrid approach can provide an alternative, allowing businesses to retain control over the customs declarations they choose while using an agent where specialist expertise, system access or authorisations make using an agent more practical.
A Hybrid Approach
The choice doesn't necessarily have to be all or nothing. A hybrid approach can allow businesses to retain the benefits of self-filing for straightforward, regular declarations, while using a customs agent for shipments that require specialist knowledge, additional system access, or particular customs procedures.
This approach can therefore balance control, cost, and access to specialist customs expertise. Rather than asking whether all declarations should be self-filed or all declarations should be handled by an agent, businesses can consider which approach makes the most sense for different parts of their business activity.
So, Can You Self-file?
Yes, but that isn't the only question to consider.
The decision to self-file should consider the volume and complexity of your customs activity, the level of internal expertise available, the investment required in systems and training, and the resources needed to maintain compliance.
For some businesses, bringing customs completely in-house will provide the greatest benefits; for others, using a customs agent may be the most practical and cost-effective option. A hybrid approach can also provide balance, allowing businesses to retain control of the declarations they choose while using an agent selectively where specialist expertise, systems access or authorisations are required.
The question shouldn't be 'Can't we just submit declarations ourselves?' but whether doing so is the most efficient, compliant, and commercially sensible approach for your business.