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The UK government published an evaluation report for the six pilot initiatives on an ‘Ecosystem of Trust’ (“EoT”) on 29 August 2023, which was first set out in the government’s 2025 UK Border strategy. Aimed at using technology to create the so called EoT around the border, the UK proposed an automated assurance and reliability model that could allow a simplification of the current customs and border processes. Such an ecosystem would be built on three pillars: technological capabilities, real time data and trusted relationships. The goal is to reduce the burden on traders and increase border efficiency by moving physical processes away from border entry points. The government partnered with six industry consortia, made up of technology firms, traders and logistics companies to test this model via its pilot, announced in 2021.

The benefits of the EoT for businesses could be significant. The government estimates that the automation of customs declarations using business documentation, when possible, would reduce customs data collection costs by 40% for industry. The estimated annual reduction could be up to 225 million GBP depending on the scale of uptake.

The EoT evaluation report includes recommendations not just for the government but also industry. Notably, industry will need to adopt digital trade document standards. The lift is much higher for the government. Border measures have already been the subject of multiple delays post-Brexit. The government now has the task of tackling:

  • the interoperability problems for unstructured data (e.g., submissions of PDFs) flagged by the pilot;
  • improved legal and governance arrangements between parties around data access, anonymisation, data interpretation, and data ownership and liabilities; and
  • developing the processes for government to accept supply chain data through the UK Single Trade Window.

Linked to the EoT is the Trusted Trader scheme, with the pilot launched by Defra on 11 September 2023, to apply specifically to Sanitary and Phytosanitary (SPS) goods. Goods covered by the pilot are medium risk products of animal origin (POAO), and animal by-products (ABP), with applications due by October 6. Overall, the EoT aims to make improvements to existing Trusted Trader schemes (e.g., Authorised Economic Operator) to provide a more frictionless import/export process. This would also free up resources from government enforcement agencies to target more high risk operators.

The UK’s border efficiency ambitions are in good company. The US is also looking ahead at its next generation single window for trade data platform, currently in the early acquisition stages. Like the UK, the new US platform aims to increase supply chain visibility and allow faster, coordinated action before goods arrive at the border. The bottom line is improving border security and customs compliance while speeding entry for legitimate trade.


Jennifer Revis is a partner in Baker McKenzie's London office and co-leads our EMEA Customs Team.
Jennifer focuses her practice on the public regulation of international trade, particularly in a wide range of customs compliance issues. She regularly advises clients on import matters, including customs valuation, rules of origin, and classification. She has worked with clients designing and implementing their compliance programs, policies, procedures and risk assessments, and assisting them in customs audits. She has significant experience in managing global customs projects and disputes, particularly in the area of customs valuation (transfer pricing; assists; royalties). Jennifer also advises on FTAs and trade remedies matters.
Jennifer has been consistently recognised as a "Leading Individual" for Customs & Excise and “Next Generation Partner” for Trade, WTO Anti-Dumping And Customs. Clients describe her as "an outstanding customs lawyer and litigator with fantastic experience. She is also easy to work with and leads her team with aplomb", "without a doubt, one of the best customs lawyers in the business (…) with an exceptionally deep knowledge of customs valuation concepts, as well as considerable experience applying those concepts in a variety of jurisdictions."
Jennifer has been on secondment to the UK customs authorities (Her Majesty's Revenue and Customs) in their tax and excise litigation department and to the Firm's European Law Centre in Brussels.


Rini joined Baker McKenzie after six years with the Canadian government, having worked on Brexit policy, as well in trade and tax litigation. She obtained her legal training with the Canadian government with the Trade Law Bureau and the Department of Justice. Her background in trade matters spans legal advisory, litigation and policy, having worked on free trade agreements, WTO litigation on market access and trade remedies issues. Prior to joining the Canadian government, she was a government affairs associate at one of Canada's most recognizable brands.

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