CDS update: New service for claiming back VAT and import duty

7 June update:

HMRC have announced that a new service enabling traders to claim back VAT and import duty on import declarations made through CDS is now live.

The service can be accessed via these two links:

Users must be subscribed to CDS to access the service, and businesses that are VAT-registered can only claim import duty via the service; they must use their VAT return to claim back VAT.

However, businesses that are claiming a repayment following a Trade Remedy Authority review, or individual parties not registered as a business, should continue to use C285 CDS form.

4 June update:

Today is the deadline for migration to CDS. As noted previously, after today firms will no longer legally be able to submit new customs declarations through CHIEF. The government states:

“If you submit declarations on CHIEF after 4 June without permissions, we’ll start the process of removing your CHIEF badge permissions.”

Information on the new system will be provided by Institute of Export and International Trade (IOE&IT) and HMRC experts at this week's IOE&IT member-exclusive Lunchtime Learning webinar session on CDS, held on Thursday at noon. You can sign up for that here.

28 May update:

There is now just one week to go until the 4 June deadline to make the switch from CHIEF to CDS for export declarations, and HMRC has issued new guidance on best practice for both declarants and loaders, carriers, airlines and designated export places (DEPs).

Noting in its advice to declarants that “we are aware that some traders have been experiencing slower than normal processing times in CDS Exports”, the department said that this predominantly occurs in cases requiring more than 99 declarations.

In order to limit the impact of these situations, it offers the following advice:

“You can reduce the number of declarations you submit per shipment, by submitting a single declaration for 99 consignments if they fall under the same declaration category.”

This, HMRC explains, can be done by using “each of the 99 line items available to account for each consignment”. This will create one Declaration Unique Consignment Reference (DUCR) “which can be associated under a Master Unique Consignment Reference (MUCR) if required”.

The government also advises declarants to have DUCRs arrived individually before consolidation into a MUCR, ensure MUCRs are finalised and closed before arriving at the UK border and to use DEPs. It adds:

“If you are arriving your shipment at an inventory-linked maritime location, you should not provide the MUCR reference to the carrier until it has been finalised and closed; this may be different to what you did on CHIEF.”
“If you are arriving your shipment at an inventory-linked airport, and your software supports the Airline Delivery Schedule, we recommend that you produce this report before delivering your shipment to the airline or temporary storage facility.”
“For arrivals at inventory-linked maritime ports, avoid creating a MUCR with a single Declaration Unique Consignment Reference (DUCR) and use the DUCR as a reference instead.”

The rest of HMRC's advice to declarants can be found here.

For loaders, HMRC has issued advice stating that “you must not continuously re-arrive Unique Consignment References (UCRs) if you encounter missing responses”. It says:

“Although re-arrival is the standard process to resolve missing responses, re-arrival should not be repeated and you should wait at least 30 minutes before re-arrival is attempted.”

If loaders do not receive a response after a second attempt, they or the trader “may need to request manual clearance”.

The full text of HMRC's advice to loaders, carriers, airlines and designated export places (DEPs) can be found here.

The Institute of Export and International Trade (IOE&IT) offers elearning courses on CDS, which offer traders education and insight on the service here. The IOE&IT technical helpline also provides support to members on CDS.

23 May update:

HMRC has notified traders that both the Customs Declaration Service (CDS) and GVMS will be down for scheduled maintenance this evening from 7pm to 8.30pm UK time. Declarations submitted during this period will be processed once the services again become available. Creating, updating or embarking a goods movement reference (GMR) could be affected, the department explains.

The government has also advised that, from the 4 June deadline for CDS migration, HMRC “will not be able to accept the single administrative document (SAD) form that is currently submitted on CHIEF”.

Following the deadline, exporters will instead need to submit an electronic export declaration on CDS. With that in mind, the government’s notice provides links to guidance on CDS declarations as well as on declaring exports under the retained General Export Authorisations (GEA).

Under the GEA, declaring an export requires traders to enter document code X002 and to cite the retained GEA reference number in Data Element 2/3 of the CDS export declaration, HMRC explains. Further detail and links can be found in the notice here.

21 May update:

The National Export System Web (NESWEB) is currently experiencing technical difficulties, according to HMRC, which notes that it is “aware of an issue with accessing the service”.

The department is investigating and “will issue a further update”, it states. It adds that “NES XML is available for those signed up to that channel”.

Among the other means of making a declaration that are available is the ‘make and manage an export declaration online’ government portal.

CDS deadline reminder

HMRC has also today issued new communications to businesses still using the Customs Handling of Import and Export Freight (CHIEF) system, reiterating the need for them to migrate to CDS and offering a free webinar to support them in doing so.

It is now less than two weeks until the 4 June deadline for making the move, and the government is telling exporters that they “must act now” to move all export declarations to CDS “to make sure you can still export goods” after that date.

After 4 June, firms will no longer legally be able to submit new customs declarations through CHIEF. The government states:

“If you submit declarations on CHIEF after 4 June without permissions, we’ll start the process of removing your CHIEF badge permissions.”

Exporters are advised to follow the steps set out in the government’s declarant checklist for CDS exports if they have yet to make the migration, as well as to use the “safe test environment” of the Trader Dress Rehearsal service (TDR) to practice submitting CDS export declarations.

Limited extensions

Those who can’t make the move by 4 June “can apply for a limited month-long exception”, but this can only be obtained “if you can’t move because of an HMRC IT issue that won’t be resolved by 4 June”. This can be done by emailing chiefextension@hmrc.gov.uk.

HMRC advises exporters seeking this extension to “submit your application as soon as possible, to help make sure we can assess it before the 4 June 2024 deadline”. Extensions that are granted will run until 4 July.

Webinar

To help firms yet to make the move to CDS, HMRC is offering a free public webinar on Thursday 23 May at 9:45am which includes “information that wasn’t in previous webinars”.

Focusing on the process of migrating, as well as the differences between CHIEF and CDS, it will also look at onboarding with CDS, best practices for submitting and managing export declarations, and common error code messages.

Those wishing to attend can sign up here.

The IOE&IT perspective

Institute of Export & International Trade (IOE&IT) director general Marco Forgione spoke to Andrew Marr on LBC yesterday to emphasise the importance of the migration to CDS from CHIEF.

He also spoke on the £4.7bn cost of the implementation of the Border Target Operating Model (BTOM) so far, as reported by the National Audit Office (NAO) yesterday:

“If we haven’t got this one right after five delays, there’s a real concern that businesses – particularly those in the EU – will say it’s too complex, it’s too difficult and it’s costing us too much.”