Representation
Source: gov.uk (2025-04-30)

Information about representation.

General information

Simplified Customs Declaration Process (SCDP) may be operated by any legal entity that is established within the UK. Legal entities may be authorised to act purely on their own behalf (Self Representation (SR)) or on behalf of their customers (as an authorised Indirect Representative (IR) or an authorised Direct Representative (DR)).

Some legal entities may wish to become authorised in their own right but employ a third party to complete or submit the declarations for them. These third parties may also be employed to maintain certain supporting documents and records for the authorised trader. The third party (such as an agent, warehouse-keeper, or software bureau) in these instances would be acting as a DR.

In the UK, third parties may only be authorised for SCDP as authorised DRs if they and their clients are established in the UK and only for goods imported into Great Britain.

Self Representation

The importer is the SCDP authorised trader and submits the customs declarations in their own name and on their own behalf. They do not use the services of a DR to submit the declaration and they do not import goods for other legal entities through their SCDP authorisation. All of the SCDP operations are contained within the one legal entity.

The SR must state that they are acting in a self representative capacity by declaring themselves as declarant in DE 3/18 and as importer in 3/16, leaving Representative DE 3/20 and Representation code 3/21 blank. AI code 00500 must be declared in DE 2/2 (Additional Information) and their Trader Identification details (EORI) should be included within the Declaration Unique Consignment Reference (DUCR).

Some SCDP authorisation holders may also submit their own Simplified Frontier Declarations (SFDs) as self-representatives as well as their Supplementary Declarations (SDs).

Liability for the customs debt

The SCDP authorised trader is solely liable for any customs debt arising from the use of SCDP. The trader retains full responsibility for any irregularities or demands for duty.

Indirect Representation

In most cases an IR will be a third-party agent or warehouse-keeper authorised for SCDP in their own right to conduct customs formalities in their name on behalf of their non authorised clients. Their clients do not require a separate SCDP authorisation. The authorised IR is responsible for meeting all the general SCDP criteria and conditions for authorisation. There are certain additional criteria that IRs will also have to satisfy.

An authorised IR who also imports their own goods (Self Representation) will only require one SCDP authorisation.

The authorised IR is responsible for ensuring that all declarations are submitted on time, in full and are accurate. They are required to maintain a full audit trail in respect of the goods declared and any necessary supporting documentation. The authorised IR may return certain original documents (for example, invoices) to the importer but must retain a duplicate for their own records. The maintenance of paperwork must be agreed with the applicant applying to be an authorised IR at the authorisation stage.

This agreement must include:
- timescales for presenting any exhausted documentation to Customs - for example, licences and transit documents
- timescales for the presentation of supporting paperwork to Customs to allow post-clearance checks and audits to be carried out
- a list of the documents being maintained by each party (and the timescales in which documents held by the importer will be presented)
- the locations at which documentation will be made available for inspection by Customs
This information must be recorded and maintained within the authorised IR’s documented procedures.

The authorised IR must state that they are acting in an indirect capacity by entering representation status code 3 on all declarations.

Liability for the customs debt

The authorised IR is jointly and severally liable with the person represented for any customs debts arising from the importation of goods through their SCDP authorisation.

Sub agents

If there are 3 parties involved in the making of the declaration (for example, an importer employs a SCDP authorised IR who sub-contracts the submission of the declarations (SFD or SD) to a sub-agent (DR)).

See CDS Tariff Vol 3:
- DE 3/15 & 16 importer = importer
- DE 3/17 & 18 declarant = DR
- DE 3/19 & 20 representative = SCDP Authorised IR
- DE 3/21 rep status code = 3
- DE 3/39 holder of the auth = SCDP authorised IR
Direct Representation

In an SCDP context, there may be two scenarios where DR is used.

SCDP Authorised Direct Representation

From January 2021 third party intermediaries were able to apply to be authorised DR. This is, however, restricted to situations where both the intermediary and the client are UK established and only for imports into GB. The intermediary will hold the SCDP authorisation and declare representation type 2 submitting the declarations in the name of, and on behalf of, their client. As the authorised DR holds the SCDP authorisation, their EORI must be shown in the DUCR (Links to definitions earlier in the handbook). The client retains liability for any customs debts arising from the use of SCDP. The intermediary, as the SCDP authorisation holder, is responsible for meeting the conditions of the authorisation.

An SCDP authorised DR must state that they are acting in a direct capacity by entering representation status code 2 on all SFD/C21i EIDR NOPs, and SDs and also include their EORI in the DUCR. The authorised SCDP trader retains liability for any customs debts arising from the use of SCDP.

SCDP authorisation holder employs the services of a Direct Representative

This is where a SCDP authorisation holder employs the services of a third party to act as a DR on their behalf. The third party may then submit the SCDP authorised trader’s declaration to Customs. The declarations are submitted in the name of, and on behalf of, the SCDP authorisation holder. The third party may also be employed to maintain certain supporting documents or records for the authorised trader. These records and documents must be made available at the authorised trader’s premises on request to allow Customs to undertake any necessary post-clearance checks or audits.

The SCDP authorisation holder should hold a record of the agreement made between themselves and the third party and the roles and responsibilities of the third party within their documented procedures.

Where a DR is used, only DRs responsible for submitting the SDs should be recorded on the C&E48 application and C&E58 authorisation approval notification. Details of DRs who are responsible only for the submission of SFDs or C21i EIDR NOPs should not be recorded.

The use of a third party to submit their declarations and maintain their records does not transfer any civil liability for customs debts from the authorised SCDP trader.

Any failure to comply with the conditions of their authorisation regarding the maintenance of these records will result in action being taken against the SCDP authorised trader only, not the DR.

Sub agents

If the SCDP authorised trader wishes to use a DR to submit their SDs or maintain their SCDP records and supporting documentation they must gain prior authorisation from their authorising officer. The details of the DR must be quoted within their SCDP application (C&E48) and their authorisation (C&E58). Details of DRs used to submit SFDs or C21i NOPs do not have to be included.

If there are three parties involved in the making of the declaration, see CDS Tariff Volume 3. The following DEs are required:
- DE 3/15 & 16 importer = importer
- DE 3/17 & 18 declarant = DR (sub agent)
- DE 3/19 & 20 representative = SCDP Authorised DR
- DE 3/21 rep status code = 2
- DE 3/39 holder of the authorisation = SCDP authorised DR