Updates on the UKCS customs process from OEUK.

One of the key benefits of our involvement with OEUK is the opportunity to contribute directly to discussions with HMRC on the challenges facing the offshore energy sector. Through this collaboration, industry can share operational realities and work collectively towards customs processes that support both compliance and efficiency.

In this guest update, Graeme Rafferty of OEUK outlines the latest developments in the UKCS customs framework, the progress made through industry engagement, and the practical improvements currently being considered by HMRC.

Over to Graeme …

Compliance and the complexities of offshore logistics. 

OEUK and its members - including Bethan Customs Consultancy - have been working closely with HMRC for several years to develop a practical customs framework for goods moving to and from the UK Continental Shelf (UKCS). The aim has been to strike the right balance - a proportionate approach that supports compliance, while recognising the complexities of offshore logistics. 

There has been progress.

HMRC has now published guidance, and engagement with industry has become more constructive. There is a stronger recognition of the challenges industry faces, and a more collaborative approach to working through them. That said, there is still work to do.

A clear framework. 

At its core, the framework is clear: goods moving between the UK and the UKCS must be declared, with the G‑form supporting a simplified process for low-risk goods movements. The challenge comes in applying this in practice and ensuring the simplified process genuinely reflects the realities of offshore operations. 

A single vessel or helicopter movement can involve multiple operators and contractors, each responsible for supplying cargo, with movements that are frequent, time‑sensitive and subject to change. Requiring multiple and separate G-form submissions from different parties can introduce duplication, uncertainty and delays into processes that need to run efficiently.

Practical improvements to the UKCS customs process. 

Through sustained engagement, OEUK and its members have put forward a number of practical improvements to the UKCS customs process that would benefit both industry and HMRC. A more consolidated approach - such as moving towards a one G‑form per movement model - would better reflect offshore logistics and provide a clearer focal point for compliance. There is also a strong case for enabling the upload of manifest documentation, reducing duplication and making use of existing processes. 

Encouragingly, HMRC has recently confirmed to OEUK that approval has been given to progress work on improvements to the G-form process. This includes developing functionality to support the submission of manifest information and exploring ways to streamline reporting across movements. HMRC is also considering how technology could be used to make better use of submitted data and has indicated that this will be tested with industry to understand how it performs in practice.

While these developments are positive, the detail and implementation approach will be important. Industry will be keen to understand how these improvements will work in practice, what changes will be prioritised, and how they will be introduced in a way that reflects operational realities.

Overall, the direction is more encouraging. Further engagement is expected in the coming months to share updates and gather industry feedback. With continued collaboration, there is a clear opportunity to land a practical, proportionate solution that supports efficient and compliant operations across both oil and gas and offshore wind.

Thank you Graeme! And as Nicola Alexander, Director of Bethan Customs Consultancy, says:

"Meaningful change happens when industry and government work together to understand the practical realities of operations. The work being led through OEUK has helped bring those realities to the forefront of the conversation, and the resulting progress is positive for the wider offshore energy sector. We are proud to play our part in those discussions and to support businesses as customs requirements continue to evolve." #CustomsIsCool