Who or what is the customs representative?

From Janine Lampprecht | 20. January 2022 | Reading time: 5 Minutes

For some suffering, for others passion

You have probably heard the term “customs representative”, “customs officer” or “customs coordinator” before. Basically, the appointed person is responsible for ensuring that customs-related processes are carried out in a legally compliant manner. After the appointment, however, the tasks and responsibilities often remain rather vaguely defined and the company management is glad to have finally found someone.

Imagine you become the customs representative of a company. And now? What procedures are you now responsible for and are you personally liable? If you want to get an overview, you quickly realise: the master data are not correctly maintained, the work instructions are not up to date, and there is a lack of solid customs knowledge in the neighbouring departments. Maybe you also realise that you are new to one or the other technical topic. In short, there is a mountain of work to be done and you have to think about where to start and what is most important.

In our article, you can find out what is actually meant by a customs officer and what options are available in the company.


What skills do I need to have as a customs officer?

In principle, the customs officer should have sufficient and up-to-date knowledge in his field of activity.

If the company wishes to benefit from simplifications, the authorities require proof of a practical or professional qualification. Anyone who has worked in the field of customs knows that it often takes years of work to acquire knowledge and experience. Basic knowledge in the areas of export and import processing, export control and preferences is required in any case.

For practical implementation in the company, the mixture of theoretical expertise and basic organisational knowledge about process design and self-organisation is certainly the best combination. If you are already working as a customs officer, it is important to always check where you still need further training. If you are new to the role, don’t try to do everything at once, but make a training and project plan for the whole year.

We offer a customs officer programme that will provide you with expertise as well as practical application through the support of our advisors. If you now have a plan for building or deepening your expertise, let’s take a closer look at the definition of the role in the company.

Legal definitions of the role of customs officer

Companies must name direct contact persons for customs in the applications for authorisation or for AEO status. Who to appoint if no one wants to volunteer? Customs matters are often located in shipping, logistics or order processing and therefore employees are often appointed from these departments. These are called customs representatives or customs officers. The designations are freely chosen by the companies and are not reflected in the relevant laws; only the above-mentioned practical or professional qualification is required according to the customs authorities.

In the absence of this concrete definition, it makes sense to define the role and function of the customs representative yourself. Exactly what the scope of activities and the obligation are depends on the internal organisation. Depending on the size of the company, the task may be a mixture of operational and supervisory activities.

Have you ever written down your duties as a customs officer over a period of time, i.e. what you do every day? This is particularly interesting for those functions that are more strategically monitoring. It usually turns out that the customs officer acts more as a “fire extinguisher”, always straightening out things that are going wrong or quickly determining the customs tariff number so that the goods can leave. Then you should think about which projects and fields of action can help to get out of this hamster wheel and move the organisation forward.

So there is no definition of a customs officer, but there are employees named vis-à-vis the authorities for monitoring authorisations and simplifications. This would be a monitoring function for the customs-relevant or authorisation-relevant processes in the company. We have the following tips for you as a customs officer, or those who would like to become one, in order to bring clarity into your field of responsibility:

  • Check which permits you are responsible for
  • Which processes in the company are connected to this, e.g. export processing, possibly even parts  of export control, origin of goods and preferences.
  • You should also consider which processes you carry out yourself and which you monitor as part of an internal control system, e.g. export processing or requesting supplier declarations.

These points should be recorded in a role description and, of course, updated regularly. If you now have clarity about your role as a customs officer, then you can start working.


What is the liability of a customs representative?

Since the customs officer is not defined by law, the question of liability for the customs officer also remains open. Basically, customs belong to tax law and thus to the tax code.

A basic principle, regardless of the personal liability question, should be: How can I, as a customs officer, protect the company from administrative offences and fines? First of all, the managing body is called upon in the case of corresponding breaches of duty. However, questions can also be asked about acting persons. The question of personal liability is always a much-discussed topic, also in seminars. Unfortunately, it is often associated with fear and can often be answered with: “It depends”.

What is important, in terms of liability and avoiding damage, for the company as such? As a customs officer, one should avoid organisational culpability in order to protect against unnecessary fines. The cornerstones for avoiding organisational negligence are documented processes, trained employees and regular controls.

As an interface between the departments and the management, you should conduct internal audits as a customs officer. Our previously published blog post on customs audits can also help you with this.

Selection and appointment of the customs representative in the company

At the beginning, we already mentioned that employees are often appointed and then have to deal with the issue. We have two essential tips for you as an employee, but also for the management. If there is a possibility to become a customs officer in the company, take the opportunity, because as an expert in this field you create a professional profile for yourself and are in demand if you know your subject. Customs can be a fun and creative role in a company. If you are a manager yourself and need a customs officer in the company, then you should invest a little more time in the search. Maybe there is a trainee who is willing to take on a special qualification, or there are other colleagues who are motivated to take on the task of customs officer. It does not always have to be a full-time job either.

What is important is that the customs officer has a desire for the subject, clarity in his/her role and tasks, and support for professional and personal development.