Policy & Compliance
With just over a month to go, it is important that Members who want to lodge safety and security declarations familiarise themselves with data requirements and start putting operational arrangements in place Entry summary declarations – technical and data requirements
A s 31 October is drawing ever nearer, BIFA is trying to ensure that Members do not lose sight of the last few remaining elements of the Border Target Operating Model (BTOM) still to be implemented. One of these is the requirement to lodge safety and security declarations, otherwise known as entry summary declarations (ENS), for goods imported from the EU and EEA countries. In the August issue, BIFAlink looked at ENS from a wider legal perspective. This time we take a closer look at the technical and data aspects. The legislation behind the requirement has already been explained in previous issues of BIFAlink but just to summarise, the legal requirement to lodge an ENS lies with the carrier whose very simplified definition says that it is the person who controls the active means of transport. The UK legislation relative to the ENS requirement is still largely based on the retained EU legislation and that legislation makes a number of operational simplifications – for instance by allowing for a pre-lodged Customs declaration to be used for safety and security purposes if certain conditions are met. Yet, HMRC is currently not planning on using any of the UCC facilitations which, in effect, means that traders need to submit full standalone declarations into Safety & Security GB (S&S GB). This can be done via an API connection with the system – a number of software suppliers and CSP already offer this functionality – but in the near future it will also
be possible to use the Single Trade Window (STW) to lodge an ENS. This functionality is currently being developed and tested, and BIFA Members may still be able to take part in this phase of the STW development. As for the data requirements, the below list presents the mandatory data elements. This represents the current data set and, although unlikely, it is not impossible for this data set to change before the implementation date. There are also conditional and optional data sets whose usage will very much depend on the circumstances and specifics of a movement. Members are advised to familiarise themselves with the data requirements thoroughly. We understand that HMRC is still working on additional guidance to provide definitive information on the data requirements with an intention to release for 31 October. Mandatory data elements: • Local Reference Number (LRN) • Country(ies) of routing codes • Person lodging the summary declaration • Mode of transport at the border • Identity of means of transport crossing the border • First place of arrival • Date and time of arrival at first place of arrival • Place of loading • Consignor • Consignee
• Seal number • Transport document number • Transport charges method of payment • Declaration date and time. It is also worth adding that multiple consignments can go on a single ENS. Up to 999 items, consignee and consignor details can be declared, which is an important feature for groupage operators. Submission timeframes There is obviously the question of when to lodge an ENS; the time limits are as follows: • Maritime containerised cargo: at least 24 hours before loading at the port of departure • Maritime bulk or break-bulk cargo: at least four hours before arrival • Roll on roll off (RoRo) — accompanied freight: at least two hours before arrival of the ferry operator • RoRo — unaccompanied freight: at least two hours before arrival of the ferry operator • Shortsea journeys: at least two
“ We understand that HMRC is still working on additional guidance to provide de fi nitive information on the data requirements with an intention to release for 31 October
• Place of unloading • Goods description • Types of packages • Number of packages • Goods item number • Gross mass
10 | September 2024
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