Logistics & customs

Appoint a customs agent: direct or indirect?

For a UK-established importer, direct representation is a sensible starting point, but ask your customs agent to confirm your customs-debt exposure under both direct and indirect representation. Confirm the capacity, authority and work allocation in writing before clearance. Discuss supplier documents with Cambridge China Bridge.

Written by Bono Xu, Founder, Cambridge China Bridge · 3 min read · Updated 2026-10-04

Shipping containers stacked several high against a blue sky

Choose the capacity before signing

For ordinary imports into Great Britain by a UK-established business, ask about direct representation first. Ask your customs agent to explain whose name it acts in under direct and indirect representation, who carries the customs debt and whether HMRC could pursue either party for the whole debt. Check your own exposure before agreeing the arrangement.

A business not established in the UK importing into Great Britain must use indirect representation. Before accepting an arrangement involving an overseas seller, establish which business is appointing the agent. Our importer of record guide covers the importer’s identity and VAT evidence; this guide focuses on the appointment and working instructions.

Check written authority and subcontracting

HMRC requires written instructions stating whether the agent acts directly or indirectly. Ask for an appointment naming your business and the actual customs representative, with the agreed capacity clearly shown. Keep the signed appointment, accepted terms and shipment instructions together. Avoid signing a form with the representation choice left blank.

If a direct agent delegates tasks to a sub-agent, the agreement with the principal must allow this. Ask who will actually submit the declaration, whether subcontracting is permitted and how instructions reach that business. Request written confirmation before a different broker takes over. Compare the roles in our sourcing agent, forwarder and customs broker guide.

Agree who supplies and checks each detail

Appointing an agent does not remove your responsibility to identify the applicable rules and duties. Create a written allocation of work: who supplies the product description, proposes the commodity code, checks the customs value, selects the procedure and resolves missing documents. Ask the broker to flag assumptions for your approval rather than silently filling gaps.

Agree how duty will be paid, how import VAT will be accounted for and who receives the declaration copy. Ask separately whether the service includes checking your supporting documents or only submitting supplied data. For the document pack, use our UK customs clearance documents guide. Keep supplier specifications and invoices consistent with the instructions sent to the broker.

Plan for errors and review the completed entry

Under direct representation, ask your customs agent or legal adviser to confirm whether an agent's deliberate or unreasonable error after receiving clear instructions could make it jointly liable. Do not assume every broker mistake transfers liability. Before signing, ask how the agent handles disputed instructions, correction work and claims under its terms. Read any indemnity and liability limitation, and seek advice if the wording is unclear.

Request the completed declaration and compare it with your approved instructions and supplier documents. If something differs, ask the agent to explain it and propose the correction route in writing. Name a contact for later HMRC queries and agree who retrieves the evidence. Cambridge China Bridge has its own staff in China; ask us to clarify supplier-side documents before they reach your customs agent.

Frequently asked questions

Should I choose direct or indirect customs representation?

For a UK-established importer, start by asking about direct representation. Ask your customs agent to confirm the customs-debt liability you retain and whether indirect representation would share that liability with the agent.

Does indirect representation remove my customs liability?

Do not assume indirect representation releases you from customs debt. Ask your customs agent to confirm whether you and the indirect representative would be jointly and severally liable and whether HMRC could seek the whole amount from either party.

Does my customs agent need written authority?

Yes. Written instructions must state direct or indirect representation. Ask for the named businesses, agreed scope and subcontracting arrangements to be clear before signing.

Can my customs agent use another broker?

A direct agent’s agreement with you must allow delegation to a sub-agent. Ask who submits the declaration and confirm that your instructions reach that business.

Sources

  1. HMRC: Get someone to deal with customs for you
  2. HMRC: Customs debt liability
  3. HMRC: Due diligence when making customs declarations

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