Policy & Compliance
BIFAlink
www.bifa.org
CHIEF is essentially a data processing system supported by paper documents and authorisations. CDS, which links to the
noted, and recent downtime issues indicate, CHIEF needs to be replaced with a more stable and secure Customs platform. Additionally, CDS will allow the UK to utilise a platform that can be updated to facilitate changes stemming from the Border 2025 project, which aims to create a Single Trade Window for trade to communicate with government. There have been some declarants who have been using CDS for some time, primarily for supplementary declarations, whilst Members based in Northern Ireland have been using the system for frontier declarations since 2021. First steps in preparation Moving from CHIEF to CDS is a significant step and requires careful planning. The system is more complex, particularly because certain functions must be undertaken first on the Government Gateway and then linked to CDS. Some software houses have linked certain functions directly from their software to the Government Gateway to simplify the process – the commercial software is in effect the front end and you will need to check with your software provider for their plans. It is strongly recommended that you also contact any Community Service Provider (CSP) you hold a badge with to discuss the transition from CHIEF to CDS. Our first suggestion is for Members to internally devise an implementation plan, with your main priority being to determine who has access to the business’s Government Gateway and decide protocols for operational staff to access this system. You will need to authorise individual users to operate CDS and also, for instance, authorise the use of the deferment account by another agent. HMRC has published guidance on some steps to be taken: Get access to the Customs Declaration Service – GOV.UK (www.gov.uk). There are also some example declarations: www.gov.uk/guidance/get-help-using-example-declarations- for-imports-to-great-britain-from-the-rest-of-the-world As already suggested, Members should have a conversation with both their software provider and Community Service Provider (CSP) about how they can support the migration from CHIEF to CDS. Software providers have put great effort into developing software, which makes using CDS and generating Customs documents, such as the C88 and E2 which customers will want, as easy as possible. Another point to check is that your company’s details, including e-mail addresses, are up to date on the business tax account, as these will be needed to keep users updated. There are some significant changes to payment methods between CHIEF and CDS; for instance the Flexible Accounting Scheme (FAS) in CHIEF is replaced by the ability in CDS to top up a deferment, top up a cash account or pay directly using a credit/debit card or bank transfer. If you use a duty deferment account, either for declaring your own imports or on behalf of another business, it is essential that the duty deferment account holder completes a new direct debit instruction to use CDS. This will ensure payments are made to the correct bank account number. Only those registered to use CDS and acting as the official deferment account owner will be able to view deferment account statements and certificates. Whilst CHIEF is still operational, it is important not to cancel your original direct
Government Gateway, has become a Customs management system.
HMRC has advised that CHIEF will be withdrawn in two stages: • After 30 September 2022, it will not be possible to make import declarations on CHIEF. • From 31 March 2023, CHIEF will be closed to export declarations as well. The new system marks a considerable change from its predecessor and, in all probability, from what had been envisaged in 2013. CHIEF is essentially a data processing system supported by paper documents and authorisations. CDS, which links to the Government Gateway, has become an electronic Customs management system. Certain information has to be input into the Government Gateway; for instance the importer has to authorise the Customs agent to use the former’s deferment approval number. CHIEF appears to be coming to the end of its working life and it has to be remembered that originally CDS was conceived when the UK was a Member of the EU and change was needed to ensure compliance with the Union Customs Code (UCC). Some have questioned whether, in view of the UK leaving the EU, this change is still needed? The answer is that the UCC was based upon World Customs Organisation (WCO) guidelines and the UK still has to ensure that its systems comply with that organisation’s criteria. As we have already
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