Introduction
Parcels move faster than policy, yet every package that leaves Great Britain is subject to customs law. Until now, foreign designated postal operators—think La Poste, USPS, Deutsche Post, Australia Post and their peers—have been able to lodge thousands of low-value exports each day from their extra-territorial offices of exchange (ETOEs) in London, Heathrow or Birmingham by relying on long-standing Universal Postal Union conventions. The growth of cross-border e-commerce and heightened security concerns, however, have convinced HM Revenue & Customs that the existing regime no longer provides enough oversight or parity with the standards that apply to Royal Mail and Parcelforce.
On 25 June 2025 the Government therefore brought the Customs (Miscellaneous Amendments) Regulations 2025 into force. The centrepiece for the postal world is a brand-new customs authorisation scheme for foreign postal operators. Once the twelve-month transition expires, no overseas postal provider will be allowed to use the simplified CN22 or CN23 declaration route for exports unless it is formally authorised by HMRC. The change reshapes the compliance obligations of more than fifty operators and promises leaner bureaucracy for millions of British online sellers who rely on them.
Why Has HMRC Introduced a Separate Authorisation?
Four policy objectives sit behind the reform.
A level playing field. Royal Mail has, for years, undertaken stringent security checks and transmitted electronic export data to HMRC before letters or parcels depart the UK. Overseas operators running ETOEs on British soil did not face identical requirements, creating competitive asymmetry. The new authorisation removes that mismatch.
Data-driven risk management. Simplified export declarations remain attractive for parcels under £900, but HMRC wants richer pre-departure information to screen consignments for illicit goods or sanction breaches without forcing every seller to complete a full electronic export declaration.
Alignment with e-commerce growth. Online marketplaces routinely fulfil UK orders through third-country logistics networks. Authorised postal operators will now be able to continue offering quick, low-cost services while providing HMRC with the data needed to underpin trust.
International credibility. The United Kingdom still participates in the Universal Postal Union; tightening its regime shows partners that it can police outbound flows effectively, a prerequisite for future trade facilitation deals.
Who Exactly Counts as a Foreign Designated Postal Operator?
Under postal treaties, each country names one or more designated operators to handle international mail. When such an operator opens an office in another country exclusively for outward traffic, that facility becomes an Extra-Territorial Office of Exchange. DHL eCommerce, for instance, uses this model to consolidate UK parcels before flying them to Germany; La Poste and PostNL do something similar via dedicated distribution centres near Heathrow. Any designated operator running an ETOE in England, Scotland or Wales now falls within the scope of the new scheme.
Northern Ireland, by contrast, remains subject to the EU Union Customs Code for postal exports because of the Windsor Framework, so foreign operators there will continue to follow EU authorisation rules rather than the British scheme.
What Does Authorisation Permit—and Require?
Privileges granted
- Continued access to the CN22 / CN23 paper declaration for goods valued below £900 (currently the low-value threshold).
- The right to lodge a simplified electronic pre-advice instead of a full export declaration in the Customs Declaration Service.
- Faster release times at outbound border locations and reduced intervention by Border Force, provided risk indicators remain low.
Core obligations
- A clean compliance history—HMRC will assess previous customs infractions and may reject habitual offenders.
- Demonstrated customs competence and robust record-keeping systems that can supply shipment-level data for audit within two hours of a request.
- Financial soundness—operators must show sufficient liquidity and bonding capacity to satisfy potential duty liabilities.
- Physical access for HMRC and Border Force officers to inspect premises, IT infrastructure and sample consignments at any time.
- Proactive due-diligence checks on exporters and contents, including watch-list screening, embargo controls and random opening of parcels.
- Data-sharing capability—API connectivity or secure file transfer that transmits electronic advance data (EAD) before departure.
Failure to meet any of these standards can result in suspension or withdrawal of the authorisation, effectively excluding the operator from the simplified export route.
Timetable and Transitional Arrangements
The statutory instrument came into force on 25 June 2025 but recognises that businesses need time to adapt. HMRC has therefore offered a minimum twelve-month implementation window, meaning operators must submit their applications by 25 June 2026. During that period they may continue to use existing processes, though HMRC encourages early adoption because application vetting can take several months.
The application portal is expected to open in late summer 2025 on the Government Gateway. Applicants will complete a detailed questionnaire, upload evidence of compliance procedures, and undergo a site visit before approval. Early pilot submissions will help HMRC refine guidance before volumes ramp up.
Operational Changes Inside an ETOE
To secure and keep the new authorisation, foreign postal operators will need to make tangible operational upgrades.
First, data capture at source becomes critical. Parcel labels generated on marketplace platforms must include accurate HS codes, values and descriptions. Operators lacking end-to-end electronic data interchange will require new manifesting software or partnerships with technology providers.
Second, staff training will shift from a purely logistics focus to a hybrid customs-security model. Frontline sorters must recognise prohibited items and understand escalation pathways.
Third, physical security enhancements—such as CCTV coverage, controlled-access zones and tamper-evident cages—may be necessary to satisfy HMRC’s inspection-readiness criteria.
Finally, operators will need a compliance dashboard capable of generating exception reports, monitoring false-declaration rates and demonstrating continuous improvement.
Implications for UK E-Commerce Sellers
Although the authorisation applies to postal operators rather than exporters, marketplace merchants will feel the knock-on effects. Sellers using foreign postal services should expect:
- More structured data fields at label-creation time, with mandatory tariff-code and value inputs.
- Earlier cut-off times during the transition phase while operators fine-tune data flows.
- Enhanced content checks—parcels could be returned if descriptions are vague (e.g., “gift”) or if restricted goods appear in low-value consignments.
The upside is that, once operators are authorised, paperwork burden falls. Sellers will continue to affix a simple CN22 or CN23 form rather than navigate the full CDS export workflow for inexpensive items. Parcels should clear outbound controls more swiftly, improving delivery promise accuracy on international platforms.
How Does This Interact with Royal Mail and Other UK Operators?
Royal Mail and Parcelforce already meet the standards baked into the new authorisation, so their day-to-day processes remain largely unchanged. What the scheme does is align foreign operators with the benchmarks UK-based providers follow, ensuring equal treatment in the market. It also reduces the incentive for exporters to route parcels through an overseas operator simply to avoid customs scrutiny.
Northern Ireland and the EU Dimension
Because Northern Ireland stays within the EU’s customs perimeter for goods, a separate set of rules continues to govern postal exports from Belfast or Derry. Foreign designated operators serving NI destinations will adhere to the Union Customs Code and any authorisations issued by the EU or Irish authorities. Businesses sending parcels across the Irish Sea must therefore maintain dual procedures if they operate from facilities in both Great Britain and Northern Ireland.
Compliance Enforcement and Penalties
HMRC has signalled that it will take a risk-based but firm approach to enforcement. Spot checks will increase during the transition year to deter operators from delaying compliance. Common failures—misdeclared values, missing exporter data, undeclared restricted items—will trigger warning letters. Persistent offenders face fines, seizure of goods and, ultimately, revocation of the authorisation, effectively pushing them into the full export-declaration regime at far higher cost.
6 Frequently Asked Questions
When does a foreign postal operator have to apply for authorisation?
Applications must be lodged within twelve months of 25 June 2025, meaning no later than 25 June 2026. HMRC encourages early submission to allow time for site audits and system testing.
How long will HMRC take to process an application?
Processing times will vary with complexity, but HMRC expects to decide straightforward cases within three months, provided the operator furnishes complete documentation and access for inspection.
What happens if an operator misses the deadline?
From 26 June 2026 an unauthorised foreign operator will be barred from using CN22/CN23 simplifications. All of its outbound parcels will need full customs declarations, adding cost and delay until authorisation is secured.
Is there a fee for applying?
HMRC has not announced an application fee, but operators will bear their own costs for system upgrades, staff training and any security improvements required.
Strategic Outlook: Toward Data-Centric Border Management
The authorisation scheme sits neatly within the Government’s broader Border Target Operating Model and its commitment to a digital-first customs environment. Parcel data will feed directly into the Customs Declaration Service and risk-profiling engines, enabling HMRC to focus physical interventions on higher-risk consignments while keeping compliant traffic moving. Looking ahead, officials have hinted at a second-phase review of the Export Memorandum of Understanding that governs bulk parcel exports, potentially extending electronic pre-lodgement to higher value bands or incorporating artificial-intelligence screening tools.
For postal operators, the message is clear: invest once in robust compliance infrastructure, and the UK market will remain open, efficient and predictable. For e-commerce sellers, the reward will be cheaper, faster access to overseas customers with fewer bureaucratic hurdles.
Practical Next Steps for Postal Operators
- Map existing processes against the authorisation requirements and identify gaps in data capture, security and audit trails.
- Engage early with HMRC—request pre-application meetings to clarify expectations and shorten approval times.
- Upgrade IT systems to generate and transmit electronic advance data in the prescribed schema, ideally by the first quarter of 2026.
- Train frontline staff on restricted-goods identification, accurate CN22 completion and escalation channels for suspicious consignments.
- Communicate with exporter customers so they understand new data fields and avoid shipment rejections during the transition.
Completing these actions well before the deadline will not only secure authorisation but also improve operational resilience across the entire parcel chain.
Conclusion
The 2025 customs amendments mark the most significant shift for foreign postal operators in a generation. By demanding authorisation and richer data, HMRC is tightening security without sacrificing the low-friction qualities that make international postal services attractive to small businesses and marketplace sellers. The twelve-month grace period offers ample time to adapt, but operators that delay run the risk of losing their competitive edge. In a world where cross-border e-commerce volumes grow double-digit each year, compliance is no longer a back-office function—it is a front-line differentiator.
British exporters, meanwhile, should welcome the move. A harmonised standard across all postal channels means greater reliability, predictable costs and the confidence that their parcels will reach customers abroad swiftly and legally. The UK is signalling that it wants to remain a hub for global e-commerce, but only on the basis of transparent, data-rich trade flows. That is a future in which both business efficiency and border integrity can thrive.
