Policy & Compliance
Entry Summary Declarations – another last minute delay
Delayed implementation of Entry Summary Declarations is likely to add more pressure on UK-based freight forwarders and Customs agents, and encourage increasing non-compliance
B IFA has been writing about the Safety and Security regime for goods imported from the EU for at least six months, but when we thought we were almost there (31October 2024) we were told there would be another delay. Is it the final one? At the time of writing this article we cannot provide a convincing answer, but we already know a little more about the technical side of lodging entry summary declarations (ENS). Following the budget announcement on 30 October 2024, it became clear that one of the government IT developments, the Single Trade Window (STW), was going to be temporarily paused. Under other circumstances this would only attract a brief mention as most of the functionalities it was supposed to deliver had never been clearly identified, but this time it requires more attention. Important functionality The reason for this is the fact that it was supposed to deliver a functionality important in the context of safety and security declarations. The STW was going to provide a web level access to the Safety and Security GB (S&S GB) system that would allow filers without specialised software or an API connection to lodge safety and security declarations in the S&S GB. That is not now going to be the case, which effectively means that anyone who would like to lodge an ENS may need to speak to their software provider about alternatives. As a consequence, BIFA believes that this may add more pressure on UK-based freight forwarders and
Customs agents as those carriers (mostly road hauliers) who were considering lodging their own declarations using the online service would need to find an alternative. This may also lead to more widespread non-compliance as some may simply ignore the requirement. Although not specifically IT- related, it is also important to mention that it will not be possible to lodge multiple consignments under one ENS, despite previous assurances by HMRC that this would be the case. This time the reason is legal, as the data model used for safety and security purposes is based on the EU legislation which requires specific data elements to be provided on header level, thus potentially preventing multiple consignments being lodged under one ENS if header and item level data differ.
BIFA believes that this approach lacks pragmatism and has called on HMRC to review the practical application of certain pieces of the assimilated legislation. BIFA also believes that this may further exacerbate non-compliant behaviour patterns as many traders will not declare all data required by the data model. BIFA concerns Adding in the facts that it will not be mandatory to include ENS reference in GVMS and a generally low level of awareness amongst hauliers, BIFA is concerned about how this system will operate and whether it will deliver the desired effects. BIFA will work with Members, authorities and partners in the EU to address the concerns raised in this article and will update members as appropriate.
“ BIFA is concerned about how this system will operate and whether it will deliver the desired effects
8 | December 2024
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