Written by Marika Majewska, Customs Specialist, ChamberCustoms

With the release of PAS 41201:2026, developed with input from ChamberCustoms and other industry experts, the UK has taken a significant step towards raising standards across the customs intermediary sector.

The PAS sets out a clear benchmark for how customs intermediaries should operate.

Getting customs right relies on both intermediaries and the businesses they represent.

Why best practice matters

Customs intermediaries play a critical role in facilitating the movement of goods across borders, from preparing declarations through to managing duties and taxes.

When processes are strong, trade flows smoothly. When they’re not, delays, penalties and compliance risks quickly follow.

In practice, standards matter because traders often remain liable for what is declared on their behalf. A customs declaration is a legal submission, and even where an intermediary completes the process, the business must be comfortable that the information provided is accurate, complete and capable of being evidenced later.

PAS 41201 aims to bring consistency, transparency and accountability – all of which are essential in today’s increasingly complex trade environment.

What best practice looks like for intermediaries

The standard sets out clear expectations across several key areas:

1 Robust processes and controls +

Intermediaries are expected to implement:

Documented standard operating procedures
Regular internal audits (both systems and declarations)
Clear record-keeping, including instructions and supporting documents

This creates consistency, reduces error rates and strengthens audit readiness.

2 Clear instructions and accountability +

A cornerstone of best practice is working strictly to the principal’s instructions.

This includes:

Obtaining formal authorisation before acting
Confirming the type of representation and associated liability
Challenging incomplete or potentially non-compliant information

A good intermediary should also have a clear process for dealing with missing or unclear information. If key details such as weights, values, commodity codes, packaging or procedure codes are not provided, they should ask questions rather than fill gaps by assumption. Ideally, those exchanges should take place in writing or through a system that leaves an audit trail.

3 Strong due diligence +

Due diligence isn’t a one-off exercise; it’s ongoing and risk based.

Intermediaries should:

Verify relevant business and identification details
Understand the principal’s business activities
Keep principal information under review
Cross-check supporting documentation for consistency

This helps identify risks early and maintain compliance throughout the relationship.

Due diligence should also include practical questions about capability. For example, does the intermediary act as the customs agent, or do they broker the work to another party? Do they hold access to the ports, airports or RoRo locations your goods use? If work is subcontracted, businesses should understand how information is passed on, how accuracy is controlled and who appears on the declaration.

4 Skilled, knowledgeable teams +

The standard reinforces the importance of:

Structured training on induction
Ongoing CPD and knowledge updates
Awareness of legislative and procedural changes

This keeps teams up to date in a fast-moving customs landscape and supports accurate declarations.

This is particularly important because PAS 41201 applies at an organisational rather than individual level. Customs agents are not currently required to hold a mandatory individual qualification before submitting declarations. Voluntary standards and industry qualifications therefore provide useful evidence that an intermediary is investing in both sound processes and competent people.

5 Transparency and communication +

Best practice also means being clear and open with customers:

Providing evidence of declaration submission and visibility of status
Setting clear hours of service and contact points
Being upfront about pricing and additional charges

This builds trust and ensures principals understand how their declarations are being handled.

Transparency should extend to costs as well as communication. Businesses should understand what is included in a declaration fee, how additional lines are charged, and how port, storage, examination, handling or disbursement costs will be passed on. Cheapest is not always best if the service does not provide the visibility, audit support or control needed to stay compliant.

But here’s the key point: intermediaries can’t do it alone

While PAS 41201 sets out what intermediaries should do, it also highlights something equally important:

The quality of a customs declaration is only as good as the data provided.

That’s where importers and exporters come in.

What importers and exporters need to do

1 Provide accurate, complete data +

At the heart of every declaration is the information supplied by the business. This includes:

Commodity codes
Values and pricing
Origin and preference claims
Supporting documentation

Accurate data is essential to ensure declarations are compliant and goods flow without disruption.

For imports, this data can be more extensive than many businesses expect. Alongside the commercial invoice and packing list, intermediaries may need details such as valuation method, delivery terms, currency, transport information, procedure being used, gross and net weights, commodity descriptions and the reason for import. If the business has not supplied the information, it should be clear where the intermediary obtained it.

2 Hold the right evidence +

If you’re claiming something on a declaration, you need to be able to back it up.

That means:

Proof of origin for preferential claims
Accurate commercial invoices
Evidence supporting valuation

Without the right evidence, claims can be challenged, leading to delays or financial exposure.

A simple but effective approach is to keep a complete file for each movement. This could include the invoice, packing list, instructions given to the agent, declaration copy, MRN, proof of origin, correspondence and any post-clearance corrections. A clear filing system makes it much easier to respond if HMRC raises a query later.

Businesses should also regularly review the customs declaration data submitted in their name.

3 Engage proactively +

Customs isn’t a ‘set and forget’ process.

Best practice means:

Responding quickly to queries from your intermediary
Clarifying inconsistencies
Flagging any changes in your supply chain

Active engagement helps resolve issues quickly and reduces the risk of errors.

4 Understand your responsibilities +

Using an intermediary doesn’t remove your responsibilities.

Depending on how you’re represented, you may still be responsible, or jointly liable, for customs debt and compliance. You can read more about the differences between direct and indirect representation in our Customs Representation Guide .

Understanding this ensures businesses remain accountable for the data submitted on their behalf.

Businesses should also pay close attention to powers of attorney and indemnity clauses. These may be necessary in some circumstances, particularly where overseas representation is involved, but they can also create exposure that is not obvious at the point of signing. The agreement with the intermediary should make clear who is doing what, what type of representation applies, who pays for corrections, and what support is available if HMRC audits the declaration.

5 Build internal awareness +

Even if you rely on an intermediary, a basic understanding of the following will improve the quality of instructions and strengthen overall compliance:

Classification
Origin
Valuation
Customs procedures

A shared responsibility

PAS 41201 isn’t just about raising the bar for intermediaries, it’s about raising standards across the entire supply chain.

When both sides work together:

Declarations are more accurate
Goods move more smoothly
Compliance risks are reduced

And ultimately, businesses are better protected.

The best relationships are built on clear instructions, transparent charges, documented communication and regular checks. If an intermediary does not follow written instructions, businesses should challenge the error, request correction and review whether that relationship is still providing the level of control they need.

Why ChamberCustoms is already ahead of the curve

For ChamberCustoms, this is not a new direction prompted by PAS 41201. It is the approach we chose from the start.

We recognised early that customs declarations should be treated with the same seriousness as any other regulated tax or compliance process. That is why ChamberCustoms developed an externally accredited qualification for customs clearance before there was any formal requirement to do so, and why we made qualification a condition of operating as a ChamberCustoms agent.

This means businesses can expect:

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Tested knowledge Agents tested against a recognised standard of practical customs knowledge.

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Consistent qualification requirements Consistent qualification requirements across the ChamberCustoms network.

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Practical customs understanding Practical understanding of CDS declarations, classification, origin and valuation risks.

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Challenge, not assumption A clear expectation that missing or inconsistent information should be challenged, not simply processed.

That matters because the UK customs intermediary landscape has historically relied heavily on experience, individual judgement and internal processes. Those are important, but they are not enough on their own. External accreditation gives businesses confidence that competence has been tested and evidenced, not simply assumed.

In that sense, PAS 41201 formalises many of the principles that ChamberCustoms has already built into its operating model. We have invested in training, accreditation, audit and quality control because compliant customs processes protect traders, intermediaries and the wider supply chain.

At ChamberCustoms, we’re committed to supporting best practice through our clearance, consultancy and training services. We internally audit all ChamberCustoms agents to ensure compliance remains at the forefront of everything we do.

Build your own customs capability

For intermediaries and businesses that want to develop their own capability, that same expertise is available through our training and consultancy services. Participants can also take our Accredited Customs Clearance Agent Exam to formally evidence their knowledge.

Whether you’re an intermediary looking to align with PAS 41201, or a trader wanting to strengthen your internal processes, we can help you:

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