Customs Declaration Systems (CDS) – Customs Declaration Technical Questions and Answers

Is it true that Deferment data 2/3 (C505, C506, 1207) is required at item level and header level? I would like this confirmed as a lot of data is repeated for the same entry if so.

The deferment account numbers and the EORI number of the account holder are declared at header level in DE 2/6 and DE 3/39. Document codes in DE 2/3 are only permitted at the item level. This means any authorisation needs to be provided at the item level.

“CDS Cash Account Deposit” – is that essentially FAS or what FAS accounting will become?

Yes, that is correct.

What’s the name of the current system used to declare goods by providing a “super reduced a dataset”? Is this possible in CHIEF and CDS?

Additional Procedure Code C07 is a CSDR relief that can be combined with additional procedure code 1RV for customs duty and VAT relief on goods below £135.

If we need to use a customer’s deferment. Do they have to give authority using a C1207N, or can we use a specific authorisation, CHIEF Option B, as was?

Standing authority can be provided using the CDS financial account authorisation. Alternatively, specific authority can still be given by declaring document code 1207 on the customs declaration.

Suppose the Authorisation Holder of DPO is required to identify the party which has authority to use the 1st deferment number. How would a declaration be made if two deferment numbers are declared (i.e. 1 paying the Duty and the other VAT)?

DPO is only required for deferment of customs duty. It is not required for deferment of VAT / Excise, so when two deferment accounts are held, or only VAT/Excise are being deferred, DPO is not required on the customs declaration.

Is there no method for having both a Home Use and an IP declaration on the same entry? i.e. multi-lines on a mixed invoice?

Entry of goods to IP requires using the H4 data set; release of goods to free circulation uses the H1 data set. There is no ability to combine goods across different data sets.

What is used instead of LIC99?

The correct document code for the waiver of the documentary controls for goods as shown in the online tariff against the specific commodity code.

As an NI agent, can we use either XI or GB EORI depending if goods are at risk or not? Will NIIMP have to be shown on every declaration regardless of it is at risk or not?

CDS does not currently accept the XI EORI. This is indicated by entering NIREM at the goods item level in DE 2/2 to state the goods are not at risk.

On full export dec B1 DE 1/2 a1 (alpha char) in the header mandatory entry, with our CSE approval, we currently use EX-D full declaration not arrived, but in CDS, we have the choice of A, B, or C which one will replace EX-D?

CSE requires an arrived declaration to be submitted as the goods have to be at the CSE premises at the point in time they are entered into the export procedure., EX-A is therefore used when CSE is used on a full (standard) declaration.

Do we need a separate deferment account for CHIEF and CDS, until all our agents move to CDS?

Please visit https://www.gov.uk/guidance/check-which-type-of-account-to-apply-for-to-defer-duty-payments-when-you-import-goods for Guidance on deferment accounts. Separate accounts will be required going forward for GB versus NI.

On CHIEF if goods are at risk we have to override the duty live to show the at-risk duty. Will this still be the case with CDS, or will showing either NIIMP or NIREM calculate the correct duty.

NIREM is used to determine the at-risk duty calculations applied. A manual calculation is not needed other than for excise duty offsets.

Is there an Index giving me an overview of the different procedure codes and what they mean?

There is an index of all 4 digit Procedure codes (PCs) in Appendix 1 of the relevant CDS volume 3 Tariff and all 3 Digit Additional Procedure Codes(APCs ). In Appendix 2 of the relevant CDS volume 3 Tariff. A matrix also shows which 4 digit PCs can be used with 3 Digit APCs and which 3 Digit APCs can be used with a particular 4 Digit. Caroline will cover this in more detail this afternoon.

What if you are deferring Excise Duty but using Postponed VAT so different tax payment methods?

Excise duty would show a method of payment code E for deferment, but postponed VAT is declared using DE 3/40, which overrides the VAT tax line, so no method of payment code is required.

IPR is under data set H4, pref is A = always? CHIEF Currently blank – what pref do we send as 5100 relieves duty – confused. What have I missed?

There are two ways of valuing the goods under IP, either on entry or removal from the procedure, so valuation information is required to help establish those values. Preference is a core determinant for the customs value there it is required. If preference is going to be claimed on removal, then the appropriate preference code is declared. Failing that, enter code 100 (no preference).

Is there a list of codes that CDS will accept for incoterms? d/e 4/9?

Incoterms are declared in DE 4/1. DE 49 are the additions and deductions that apply to the declared customs value. A list of the incoterms is in the code list (appendix 7) for DE 4/1:

https://www.gov.uk/government/publications/delivery-terms-for-data-element-41-of-the-customs-declaration-service

Do RoW imports include imports from the EU?

For GB yes

I notice that, unlike CHIEF, some call for Exporter, Consignor, Consignee, Importer and buyer in the data elements – all potentially different. Is there somewhere within the CDS tariff that defines these terms to ensure the correct parties are being declared? Sometimes as an agent/declarant, we may not be a party to that information – what would we do in that instance?

These are defined in the Declaration completion guides for the type of movement being made; see Group 3 Declaration Completion Guides. Importer, Buyer and Seller are only used on an import declaration. Consignor is only used on a C21 for exports. Consignee is used for exports (written description and C21s).

How can an importer stop a broker from making assumptions on the entry?

The importer should provide written instructions to their agent on how the goods should be declared.

What is the difference between DE 4/6 and 4/7?

4/6 is the amount of tax payable for that particular tax type, e.g., customs duty. 4/7 is the total amount of tax payable for that goods item.

Is there a list of the group preference codes available somewhere?

Appendix 13: table 5
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/885295/Table_5_-_preference_group_codes.csv/preview

We thought tax code information was not required if no manual calculation was being declared, as CDS would automatically work out what was required.

CDS will calculate the tax unless a manual tac calculation is used; for certain procedure codes and tax types, CDS cannot calculate the tax as the information required is not on the declaration, for example, OP, Where a manual tax calculation is not being used, the only tax line information required is the tax type and the method of payment to be used to pay that type of tax.

How useful/comprehensive are CDS error message rejections to help troubleshoot? For example, if a restricted comm code is attempted with a particular CPC – will that reason be identifiable from the error separately in error to other reasons?

There is a list of error codes available on GOV.UK. we are currently working on expanding the guidance on how to resolve/ address them, and this will be published as further guidance in due course. Current guidance can be found here https://www.gov.uk/government/publications/customs-declaration-service-error-codes

For Grouping, is there something specific we need to declare to customs that we are completing the entry under this procedure? My concern is that upon audit, HMRC would think that the entry is being completed incorrectly by the clerk, and this would result in clerks getting into trouble.

AI code 00600 is declared in DE 2/2 to say you are using grouping.

Is there an Org Chart type document to give high-level assistance of Vol 3 sections?

Each movement type (import, export, inventory import, inventory export) has a full content list at the end of the navigation guide. You should access the navigation guide for the type of movement you intend to make, and this will walk you through the guidance you need to access, including links to the relevant sections.

National is surely GB; Union is EU, so for an import SE-GB should we not only be using the National codes? And for SE-NI Union codes?

Union Additional Procedure Codes still apply In GB and NI, and the Union Additional Procedure codes take precedence over National Additional Procedure codes.

Currently, there is a list of all CPC codes for CHIEF – will there be a similar explanation list for all the CPC combinations for CDS, i.e. all the first 4 numbers with the available 99 3 digit codes? I ask because sometimes you don’t know which one you need until you can read through the possibilities, eg. Temporary admission is a good example of what I mean as there are so many possibilities.

There is a list and detailed description of all 4 digit procedure Codes in Appendix 1 of the relevant CDS Volume 3 Tariff, and a list and detailed description of all the 3 Digit Additional Procedure codes in Appendix 2 of the relevant CDS Volume 3 Tariff. The narrative description in the relevant Appendix also covers allowable PC / APC combinations as an alternative to using the matrix.

Would you please suggest the links for duty calculators? 

For those wishing to do an offline duty calculation, a ‘duty calculator function’ is available in the online tariff. For NI the link is: https://www.trade-tariff.service.gov.uk/duty-calculator/xi/2203000100/import-date

For GB the link is: https://www.trade-tariff.service.gov.uk/duty-calculator/uk/2203000100/import-date

Does the EORI number for deferment (DPO) in D/E 3/39 have to match one in D/E’s 3/16 & 3/18? Or can any be used?

It will have to match either the standing authorities set up in the CDS financial account or a specific authority declared on the declaration. Where authority is given it is for the agent to use the imports account. The owner of the account must be either the import (3/16) with authority given to the agent or owned by the agent (3/18 or 3/20).

If a customer has a special authorisation and HMRC has approved without the need for a CCG – how do we override this requirement to declare a guarantee, please?

Where a trader is exempt from a guarantee (as opposed to holding a 0% guarantee/guarantee waiver), then in DE 2/3 and 8/3, in lieu of the approval number/ guarantee reference number, enter ‘Guaranteenotrequired’. See guidance notes in Declaration completion guide, DE 8/3 for details.

If there are multiple additional codes that are the same for different item levels, is it possible to put them at header level on 2/3, or do they have to go on every item level individually?

This answer is based on the assumption that you mean document codes for an authorisation. Where there are multiple lines on a declaration that all require the same authorisation to be declared, e.g., 40 items all using Customs warehousing, CDS will accept the Warehouse authorisation to be declared in DE 2/3 on only the first goods item. It does not need to be repeated on each goods item.

When you clear a CDS declaration, you sometimes receive the following warning message: CDS13000 (Credibility check: incredible value found). Do we need to do something with this declaration? Is this warning message CDS13000 instead of the FEC-failures in CHIEF?

This is an FEC check and can be actioned by amending the declaration or ‘accepting’ it as currently in CHIEF.

Is there a single list of all AI statements and documents & other reference codes (also detailing union/national and their type), as looking at 4 or 5 separate lists is somewhat cumbersome. If not, could there be one in the future?

The AI Codes are listed in Appendix 4 of the Volume 3 CDS Tariff, and the Document Code are listed in Appendix 5. They are separated into Union and National Codes, which is why there are two lists in App 4 and two in App 5.

We already know that EU & national PCs & APCs can apply to declarations at GB mainland ports (not just N. Ireland), but do Union AI statements, documents, and other reference codes apply to declarations at and GB mainland ports as well? and if so do they take precedence over national ones / shown 1st?

Yes the Union Codes take precedence over National Codes in GB and should be declared first.

Can you provide an instance where DE 2/2 for AI Statement and Code would be used at Header Level.

Only in relation to RRS01. Only 1 AI code on CDS may ever be declared at header level, and that is only used for GVMS movements.

The tariff states that for commodity code 4407129090 the document code 9115 is required, for CHIEF this could be overridden which meant this document was not needed. On CDS it appears that I have to provide the document to be able to process the Import. a. if I use status XX to notify that the document does not apply, what should I be inputting as the reference text – Is ‘Not Required‘ okay to use? Appendix 5A states to ‘Enter GBAHC followed by the license number’, but I can’t add the number because I do not have a certificate. b. If I do need to get a 9115 Quarentine Release certificate for this commodity code now that we are moving onto CDS, where can I get one from?

If the goods are ex-heading and not required, insert a reason in place of the reference number. GBAHCexempt-exempt-XX or XW

Are the changes currently incorporated in the GB and NI Supplements likely to be incorporated into the main CDS Tariff when amendments take place?

Yes, it is HMRC’s current intention to do so in due course . However, HMRC has not done so to date as there are still a lot of changes taking place and will be more , for example with the removal of staged controls for EU imports into GB.

Does the 000 additional procedure code always has to be inputted if no other additional procedure code is applicable or can it also be left empty?

You have to declare at least one 3 digits Additional Procedure Code with the chosen 4 Digit Procedure Code. The matrix or relevant information in App1 (regarding which 3 digit APCS can be used with the 4 Digit PC ) should be consulted. 000 APC should only be used when no other APCs apply.

Although the haulier will have the option to use the GB EORI when creating the GMR if the goods are controlled (such as IPAFFS) I believe that an SFD entry will be required on the GMR. Is this correct?

An SFD is required for controlled goods yes.

What reference will need to be entered into the GVMS system when the importer is moving goods under EIDR using the CFSP approval of their clearance agent? Additionally, if the goods are deemed as controlled, does this change what will need to be entered onto the GVMS?

If goods are deemed controlled, they cannot be released under EIDR. Either an SFD would be required or an FFD. The MRN for those would be used. Where no MRN is held, an alternative reference can be entered to GVMS.

Does EU have a preference group , so for CDS EU group name rather than specific country 2 digit code could be used?

Group code 1013; however, when declaring this in DE 5/16 as a preference group you would need to declare the specific country in 5/15 as well. It means completing 2 data elements instead of just 1.

Is an SFD entry number required on a GMR for controlled goods such as IPAFFS?

If the goods are being released using simplified procedures (a simplified declaration followed by a supplementary declaration), then the MRN (entry number) for the simplified declaration would be required on GVMS. Controlled goods cannot be declared using EIDR, so either an SFD or an FFD would be needed.

Is EU a valid country code on CDS? In CHIEF tariff, is states “There is no country code for the European Community”.

This code is being reviewed on CDS and may be withdrawn.

If you are approved to use the Aggregation Method for import, do you have to declare Before the shipment has arrived to the UK or can it be done After the goods have arrived to the UK? Thank you.

It is for the supplementary declaration, so post-release to the procedure.

What are A B C & D again for location codes?

These indicate the type of location being declared. A – frontier, B – approved premises (away from the border), C – CoA Airfield, D – other such as pipelines, refineries etc.

What would the B&E stand for?

In the Vol 3 CDS imports Tariff B stands for a Simplified Declaration on an Occasional basis -Goods Arrived. E represents Simplified Declaration on an Occasional basis -Goods not arrived. The abbreviations are explained at DE 1/2 in the relevant Data Element Completion Guide. Caroline is currently providing more background information.

How do you know when to use VATZ

You use VATZ in DE 6/17 when the UK Global Tariff or NI (EU) Tariff tells you that the goods are zero-rated.

Is VATZ needed even if the commodity code can only be zero-rated?

Yes

What are the implications of using additional code 000 and missing something more appropriate?

If you use 000 instead of the appropriate code, then a post-clearance amendment or amendments would be needed -for example, if a declarant wanted Customs Duty, Import VAT relief and the goods were controlled, that would be three areas that would need to be amended after clearance.

What happens if you don’t put the document codes in or you miss some?

If you don’t put the required document codes in the declaration or correctly claim the waiver if one applies, then the declaration will be rejected.

How would the agent know whether the importers deferent is backed up by some guarantee or waiver?

It is up to the importer to tell the agent if they have a guarantee of waiver. They will have to provide the agent with the relevant information before the latter can complete the declaration on their behalf.