BIFAlink is BIFA's monthly magazine covering issues of importance for the logistics and supply chain industry.
September 2022 The magazine of the British International Freight Association BIFA link Issue: 385 www.bifa.org
The importance of the Customs intermediary
– Pages 8-10
11-14 : UPDATED Special four- page pull-out: Customs Declaration Service: your guide to essential information INSIDE
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Robert Keen’s Column
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EU Exit issues rumble on
BIFAlink is the official magazine of the British International Freight Association Redfern House, Browells Lane, Feltham TW13 7EP Tel: 020 8844 2266
As this issue of BIFAlink is delivered to your desk, or inbox, Britain will be welcoming a new Prime Minister, facing a bulging in-tray of issues to address, many of them trade related. There is a perception from many in the UK that “Brexit is done”; however, among many unresolved issues related to EU exit, at the top of the new PM’s in-tray should be how to ensure unhindered trade between Britain and Northern Ireland without breaching the Northern Ireland Protocol. In this issue of BIFAlink , several articles touch on some of the other unresolved EU exit related issues, many of which are related to Customs procedures.
Web site: www.bifa.org E-mail: bifa@bifa.org
(A company limited by guarantee. Registered in England: 391973. VAT Registration: 216476363) Director General Robert Keen r.keen@bifa.org Executive Director Robert Windsor, Policy & Compliance – Surface & Legal
On page 8, we bring you a report of an HM Revenue & Customs (HMRC) review, which concludes that the SME sector largely wants to use a Customs agent at the frontier, with respondents stating that capacity in the sector has been improving since EU exit, adding that there is sufficient capacity for GB-EU trade. We make no apologies for once again including a four-page guide to the Customs Declaration Service (CDS), with the deadline for making the transition from CHIEF to CDS for import entries on the immediate horizon at the end of this month. The CDS train left the station long before the EU referendum, but the vote in favour of exit moved the tracks somewhat and probably made the development of CDS and transition from CHIEF more complicated. Our BIFA award winner profile in this issue is also topical and reveals how Brunel European’s proactive approach to the challenge of the UK leaving the EU took it to victory in the 2021 BIFA Supply Chain Management category. With the submission deadline for the BIFA Awards 2022 competition now around a month away, make sure that you have begun to get your story ‘on paper’ to avoid a last-minute panic as October begins. See the article on page 22 for some guidance on the entry process. The UK business community remains negative with the publication of a report (Economic Confidence Index) by The Institute of Directors. The report notes that business leader optimism about the prospects for the UK economy remained very low, at -54, in July with the difficulties in the UK’s trading relationship with the EU cited by 18% of respondents, coming second only to the rate of inflation in the UK (29%) as a cause for concern. Trade is facing greater headwinds than it has faced for at least the last four decades. EU exit has reintroduced friction into GB-EU trade and business needs to adjust to this situation. Government thinking appears to be that there is a need to offset the negative impact of increased friction by improving frontier procedures. It has announced six Ecosystem of Trust pilots that will assess the use of technology, data and trusted trader relationships in an attempt to create a more secure border, while limiting the need for the government to conduct compliance activities, with traders allowed to perform more self-assessment at their premises. The pilots will run until the end of the year to establish how they can be scaled to a new border model, which will increase the efficiency, speed and, crucially, the safety of the UK’s trade borders. It will be interesting to see how projects, such as developing the single trade window, make progress over the next few years, as well as seeing whether the Northern Ireland Protocol issue can be resolved without a trade war with the UK’s largest trading partner. I end this issue’s column with thanks to our friends at EFTA (the European Freight Trades Association) which has contributed an article on page 6 about fraudsters and fake e-mail addresses. Many of you will be well aware of the many scams perpetrated by fraudsters and that continued vigilance is essential. EFTA specialises in identifying and warning its members on the cons that are out there.
r.windsor@bifa.org Executive Director Spencer Stevenson s.stevenson@bifa.org Executive Director Carl Hobbis c.hobbis@bifa.org Policy & Compliance Advisor – Customs Igor Popovics i.popovics@bifa.org Policy & Compliance Advisor – Air David Stroud d.stroud@bifa.org Editorial Co-ordinator Sharon Hammond s.hammond@bifa.org Communications Manager Natalie Pitts n.pitts@bifa.org Membership Supervisor Sarah Milton s.milton@bifa.org
Published by Park Lane Publishing peter@parklanepublishingltd.com Contributors
Robert Keen, Robert Windsor, David Stroud, Spencer Stevenson, Carl Hobbis, Sharon Hammond, Natalie Pitts, Igor Popovics Note to media: If you wish to use items in this magazine that are older than one month, please contact the editor to ensure that the item in question still reflects the current circumstances. Please be advised that BIFA DOES NOT OFFER LEGAL ADVICE. BIFA is not a law firm and the authors of this publication are not legally qualified and do not have any legal training. The guidance and assistance set out herein are based on BIFA’s own experience with the issues concerned and should not be in any circumstances regarded or relied upon as legal advice. It is strongly recommended that anyone considering further action based on the information contained in this publication should seek the advice of a qualified professional.
Robert Keen Director General
September 2022
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Container lines set for record profits again Ian Matheson, from Impress Communications, reviews some recent news that might impact on Members’ business
developments in road freight prices, reveals the Ti/Upply/IRU Road Freight Rate Benchmark for Q2 2022, which reports that the European contract road freight rate index reached an all-time high of 121 points, up 6.1 points quarter- on-quarter and 13.1 points year-on-year. The European spot road freight rate index also reached a record high of 134 points, up 11.8 points from Q1 2022 and 20.1 points from Q2 2021. The Department for Transport is seeking views on potential changes to driving licence flexibility regarding vans that are powered by alternative fuels. A consultation running until 4 October is focusing on the additional training that drivers must complete to gain driving licence flexibility; the types of vehicles that should be eligible; the towing allowance of these vehicles; and the powertrains that should be eligible. ON THE QUAYSIDE Strong post-COVID-19 performance by global shipping lines has led to a reassessment of the viability of greenfield terminals by global terminal operators (GTOs), which now have an increased appetite for such higher-risk projects to deliver long-term growth says consultancy Drewry. However, it added that the majority (70%) of GTO investment plans remained focused on existing assets.
ON THE OCEAN The world’s biggest container lines are on course to post profits in 2022 of around US$256 billion, topping last year’s record by 73%, according to a new forecast from Blue Alpha Capital. The profits have been buoyed by logistics and labour strains that are squeezing capacity amid sustained US demand for imports. The European Commission has launched a call for evidence, inviting feedback on the performance of the EU legal framework which exempts liner shipping consortia from EU antitrust rules. Targeted questionnaires have been sent to
carriers, shippers, freight forwarders and port and terminal operators on the impact of consortia between liner shipping companies. Peel Ports Group says there has been a substantial increase in trade on its unaccompanied freight service between Calais and its port of Sheerness, with the route
experiencing a 30% increase in volumes between April and June this year, compared with the last six months of 2021, in the wake of the suspension of P&O Ferries services in Dover, with individual sailings often carrying more than 200 vehicles. IN THE AIR Air cargo demand was down in July as economic and political uncertainties continued to affect the air cargo market, CLIVE Data Services reported. Month volumes were down 9% year-on-year and down 9% compared with 2019, whilst capacity was 4% above 2021 but still 11% below 2019, causing the dynamic load factor to drop 8 percentage points to 58%. The Chartered Institute of Logistics and Transport – CILT(UK) – has released a briefing paper on air freight in the UK that reviews the current nature of the air freight sector. It aims to highlight areas where government and industry policymakers can assist with the progress required to support UK cargo aviation. Registration is now open for the IATA World Cargo Symposium, which will be held from 27-29 September at the Excel Centre in East London. OVERLAND Inflation, weakening demand, social instability and the war in Ukraine are leading to tumultuous
IN BUSINESS August saw the launch by
government and the logistics sector of Generation Logistics, a campaign that aims to tackle the industry’s long-term recruitment issues and future-proof the industry’s talent pipeline. Generation Logistics is sponsored by the Department for Transport along with companies from all sides of the industry, including BIFA. It will raise awareness of an industry often overlooked by those seeking employment and challenge their pre-conceptions about what working in logistics can offer.
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Beware of company identity theft
Transaid makes big steps in reducing road deaths BIFA continues to support the work of industry charity Transaid and is delighted to share information from the organisation’s Q2 2022 report. An estimated 1.35 million people die each year as a result of road traffic crashes. Even though low- and middle-income countries account only for approximately 60% of the world’s vehicles, they experience 93% of the global fatalities on roads. Transaid’s portfolio of road safety programmes continues to grow, with Mozambique and Ghana benefitting from new driver and rider training programmes, building on the success of existing programmes in Tanzania, Uganda and Zambia where a steady return to pre-pandemic training levels has been seen. Transaid also continues its Emergency Transport Scheme (ETS) to provide bicycle ambulances to rural areas, halving the travelling time from village to healthcare facility for seriously ill
We are reproducing a communication sent recently by the European Freight Trades Association (EFTA) to its members. EFTA is the leading credit forum for UK and Irish-based logistics companies and many BIFA Members are EFTA members. Company identity theft occurs when fraudsters in effect hijack a company by creating a similar email address (such as having one character different) to that of an innocent company and then use that email address to place orders for goods and services which are never paid for. If you do not spot what is going on (and to detect it you have to compare the bogus email address against the real one) there is a distinct likelihood that you could end up extending credit to fraudsters when you think you are
dealing with a genuine company. The amounts might not be insignificant as the fraudsters (and this is organised crime) are not doing this for pennies. As part of the rigorous credit checking procedure, EFTA recommends the email address being used is compared with the one that will, hopefully, be on the website of the company supposedly applying for credit. There can be a twist as a recent case seen by EFTA concerned a company without a website (not every company has or needs a website), so there was no opportunity to compare a genuine
website email address. Fraudsters constantly become more sophisticated and have spotted that by using innocent companies that do not have websites there is less chance of them being rumbled. Without a website it is one less check that you, the innocent supplier, can make. Fraud is an ever-growing risk and EFTA urges extra vigilance, especially if you receive an application for credit from a company that seems very healthy but does not have a website. For more information about EFTA, visit www.eftaweb.com
Russian sanctions: What you need to know
patients. In the year ending November 2021, 277 ETS
Members are reminded that the UK government has imposed a range of measures, including trade and financial sanctions, under the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Sanctions Regulations). Further information can be found at www.gov.uk/guidance/trading- under-sanctions-with-russia?utm_me dium=email&utm_campaign=govuk- notifications-topic&utm_source=2bf2 bdb6-39f1-48d0-9928- 11d599136dee&utm_content=daily The purposes of the Russia Sanctions Regulations are to encourage Russia to cease actions: • Destabilising Ukraine, or • Undermining or threatening the territorial integrity, sovereignty or independence of Ukraine. Find detailed guidance on all sanctions at www.gov.uk/government/collection
s/uk-sanctions-on-russia UK businesses are responsible for the decision on whether to trade with Russia. Business should expect a highly unpredictable trading environment as a result of: • Designations of individuals and entities under the Russia Sanctions Regulations by the UK, • Retaliatory measures by Russia. The Russia Sanctions Regulations affect several aspects of trade with Russia, including: • The movement of goods to and from Russia, • The settling of financial transactions with suppliers and customers, • Trading with certain businesses and individuals. BIFA has noted a significant increase in enquiries regarding sanctions and embargoes, particularly for shipments transiting
the EU, where carriers are seeking clarification as to what checks are being carried out by shippers and freight forwarders. One such incident highlighted the issue: a shipment destined to a Russian national based in the Democratic Republic of the Congo transhipped via Brussels, where it was stopped. Investigation established that the Russian individual was actually subject to sanctions and the consignment was seized by Belgium Customs. Dealing with sanctions and embargoes is complex, particularly where individuals adopt aliases and information provided by government is often not in the easiest to read formats. There is commercially available software which can be used to check for sanctions and embargoes. We also suggest Members should seek legal advice if they plan to continue trading with Russia.
volunteer riders were trained and 5,064 individuals were provided with transport — 50% of these being severe malaria cases. For more information see Transaid.org TT Club highlights warehousing risks Insurer and loss prevention advisor the TT Club has issued a new series of TT Brief documents on the risks involved in running a warehouse. See www.ttclub.com/loss- prevention/warehouse-risks to view and download the individual guides entitled: Operating a secure warehouse; Choosing a storage warehouse; Operating a safe warehouse; Mitigating flood risk; and Preventing warehouse fires.
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News Desk
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Make a ‘new-term’ resolution ‘Book it right and pack it tight’ update
It may not be a new year yet, but young people need you. With the recent launch of the government-backed Generation Logistics initiative, all companies need to do their bit to raise the profile of the logistics industry amongst young people. It is also much easier than you think. The autumn term is a good time to start building a new and exciting relationship with your local school or college; most of the big companies do it well, with many having resourcing and future talent teams in place. What the industry and schools need is more SMEs forging a solid relationship with their local community as well. Where do you start, you may ask? Well, it is quite easy. Every school must list its careers lead and contact details on its website. So, there you go. Just reach out to them and find out what careers activities are planned and get involved.
We are all aware that the logistics market is vast with many pathways to follow, yet young people are unaware of its potential and will never consider it as a career option unless companies go and tell them about it. With concerns over skills shortages within the industry, we all need to join forces to help to raise its profile. Here are a few ideas to get you started: 1. Appoint a staff member with excellent communication skills to oversee the project. Ideally this should be a young person; it will also be a fantastic opportunity to enhance their own project management skills. 2. Contact the school or college nearest to your branch – this is important from a mobility perspective until young people can drive. Obviously if you have a good public transport network this does not matter so much. Or
find out where children of your employees attend. 3. Enquire about their existing careers programme; there will be a calendar of planned events that you could support, including mock interviews, speed networking, careers days and assembly talks. 4. Offer workplace visit and work experience opportunities. This is a big challenge for schools and colleges, but you get the chance to see potential employees of the future, first-hand. 5. Alternative ideas – Why not try a local community sports club? Perhaps one of your employees is involved in a youth team or social group. Let us know what you are up to and have planned and we can always provide guidance. Please contact Nezda Leigh on n.leigh@bifa.org
TT Club and UK P&I ha ve issued guidance on packing dangerous goods for carriage by sea – IMDG code amendment 40-20. The loss prevention department of the UK P&I and TT Club have updated their industry leading Book it right and pack it tight publication, to bring it in-line with the most current thinking and regulations. The book is free to download from ttclub.com in the news and resources section (www.ttclub.com/news-and- resources/publications/birpit/). This book is essential for anyone packing dangerous goods for transport by sea.
The Limits of Liability for Carriers
In association with
By air – Warsaw Convention (17 SDR): £18.57 per kg
By sea – Hague Visby rules (2 SDR): £2.18 per kg £728.06 per package
BIFA STC: (2 SDR): £2.18 per kg
By road – CMR (8.33 SDR): £91.0 per kg
Insurance for the Marine & Logistics industries
(The SDR rate on 15 August 2022,
By air – Montreal Convention (22 SDR): £24.03 per kg
according to the IMF website, was 1.09209)
+44 (0) 1628 532613
macbeths.co.uk
September 2022
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An independent Customs regime: your views on intermediaries
As part of its research into possible changes to frontier procedures, government has canvassed trade’s views to establish the level of satisfaction with the current situation. Inevitably this included what importers thought of the Customs intermediary sector. Certain bodies have been lobbying for significant changes, arguing that many traders want to submit their own declarations directly to HM Revenue & Customs (HMRC). BIFA reasoned that fewer importers than stated would want to adopt this business model. The outcome of HMRC’s review indicates that, at least amongst the SME sector, the majority seem to wish to continue using a Customs agent at the frontier. However, amongst larger traders there does appear to be an appetite to use current simplified procedures to a greater extent, and perhaps go further. However, BIFA strongly believes that government has failed to fully understand the importance of inventory systems at the frontier to control cargo flows and ensure that only ‘cleared and released’ freight is released. The two processes of ‘Customs’ and ‘inventory’ are inextricably linked and need to be considered in tandem. Whilst the research generally supports the role and function of the Customs intermediary, in certain cases there is scope for improvement and also the potential for as yet undefined regulation, even if on a voluntary basis, to differentiate the intermediaries’ service levels. Responses to the Call for Evidence (CfE) emphasised that intermediaries play a vital role An HMRC review indicates that the SME sector largely wants to continue using a Customs agent at the frontier. However, amongst larger traders there does appear to be an appetite to use current simplified procedures to a greater extent
in the Customs process for many traders. Respondents reported using a Customs intermediary for a wide range of services, including making their Customs declarations for both imports and exports, arranging the transportation of goods, operating warehouses, and giving advice on Customs. The intermediaries research sought views on three main themes: • Ease and cost of access, • Quality, • The future of the sector. Broadly, stakeholders felt that there is sufficient capacity in the sector. Stakeholders reported that the cost of using an intermediary was proportionate to the services they provide. Most stakeholders said that they had generally received a satisfactory service from their intermediary, but there were some accounts of poor-quality services being provided.
Intermediaries suggested that some of the quality and cost issues may be attributable to recent changes and uncertainty over rules; perceived poor HMRC systems, guidance and support; and a lack of knowledge in the sector. Looking to the future of the sector, some stakeholders felt that automation would provide the greatest scope for innovation, but that there were currently some barriers to innovation. Ease and cost of access The majority of respondents reported that they currently face no significant issues accessing intermediary services. It was widely recognised that capacity in the sector has been improving since ‘EU Exit’, and although a few stakeholders thought that the sector would struggle to take on more work, most agreed there is sufficient capacity for GB-EU trade. Most intermediaries said they offered their services to all types of business, although some
Continued on page 10
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The biggest change in nearly 30 years is happening in our ind month.
CDS is replacing CHIEF for import customs declarations at the end of September 2022. In times of great change and upheaval, you look to who stands beside you and with you. ASM is guiding and partnering more than 500 freight forwarders through migration to CDS.
Who s partner?
ASM. Here today. Here tomorrow.
Let us know if you would like a conversation. admin@asm.org.uk
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From page 8
noted that they sometimes choose whether or not to take on a client depending on their commercial attractiveness. Generally, stakeholders described using intermediaries for a wide range of services. A small number of respondents expressed their wish to be able to do some Customs processes, such as import declarations, in-house. Most respondents stated that there was a large variation in price between different intermediaries, and many acknowledged that the cost is generally higher for infrequent traders using intermediaries. Roughly two-thirds of respondents said that the cost of using an intermediary is proportionate to the services offered. Intermediaries reported a wide range of key factors that drive their pricing including market competition, the volume of declarations per client, the cost of software, staff training and wages, the complexity of and time needed to complete declarations, and related to that, the quality of data provided by the customer. Quality The majority of traders, in response to HMRC questions, reported receiving a satisfactory service overall, even if most had also seen or experienced a poor service to some extent or at some point. The accounts of poor quality were not restricted to a particular type of intermediary, although some stakeholders said that the service received from Customs agents was good or better than other types of intermediaries. Of the stakeholders that reported that their intermediary had submitted incorrect or incomplete declarations on their behalf, in most instances this did not have a detrimental impact on the movement taking place, although there were financial and subsequent compliance issues to consider. Future of the Customs intermediary sector Stakeholders reported that automation, for instance of processes such as data collection, would provide the most significant scope for innovation in the sector, but they also identified a range of barriers to innovation. The most frequently mentioned was the perception of some stakeholders that government systems are complicated, and it is difficult to access relevant Customs information. Some respondents also felt that Customs infrastructure and technology is often outdated, and a number felt that the uncertainty and instability around Customs processes had resulted in a lack of knowledge in the sector. There was also concern over whether intermediaries would be able to train staff in time
for the transition to CDS. There were a range of suggestions from stakeholders on how to aid innovation in the intermediary sector. These included the improvement or simplification of government Customs systems and infrastructure, and addressing non-compliant intermediaries. A small minority of respondents mentioned that they would benefit from an option to submit import declarations themselves. Some replies to the CfE suggested introducing regulation in the sector in the form of licensing or standards, including on a voluntary basis, to improve the education and quality of the sector. Examples were drawn from various countries that regulate their intermediary market in these ways, including the USA, the Netherlands, Singapore, Greece, Spain, Australia and Canada. On the other hand, some respondents believed that the sector would develop on its own without any form of government intervention. Also, the CfE covers other areas of Customs activity including Simplified Frontier Declarations (SFD) and trials regarding experimenting with the aggregation of VAT declarations. Simplified frontier processes have already been touched upon, but there seems to be renewed interest in Entry In Declarant’s Records (EIDR), particularly
if data can be directly imported into traders’ systems from information in the supply chain. Traders found aggregated VAT declaration rules to be too complex. Lastly, Transit was considered, and the problems identified were largely in line with those reported to BIFA by Members over many years. It should be remembered that this regime is governed by international convention. Some of the problems that users encounter with Transit are outside HMRC’s ability to rectify without the co-operation of other signatories to the convention. At a time when our sector has been under constant pressure, the outcome of the CfE is to be welcomed. BIFA always argues the case for the important role that Members fulfil in facilitating international trade and it is clear that the majority do it well. Inevitably there is even more change on the horizon and potentially increased regulation, even if it is voluntary, although as one person commented, “I thought that AEO-C was meant to be the badge to identify the good agent”. The core message being HMRC needs to look at existing standards and ensure that these work before considering the implementation of any new schemes.
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Special Pull-Out & Keep Guide
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Customs Declaration Service (CDS): AN OVERVIEW HM Revenue & Customs (HMRC) has published numerous guides designed to assist users making the switch to the new Customs Declaration Service (CDS), most of which are available on GOV.UK The aim of this guidance is to provide an overview of the new CDS system and to highlight the main differences between the incoming system and CHIEF. Undoubtedly, aside from the difference in the interface, the additional data required makes CDS declaration completion more challenging compared with a CHIEF entry submission.
In this document BIFA has collated the most useful information sources that are recommended for use while completing a CDS declaration. Basic information The link below collates introductory guides related to registration, import/export declarations and description of the CDS Movement reference number. www.gov.uk/government/publications/customs-declaration- service-communication-pack?utm_medium=email&utm_campa ign=govuk-notifications-topic&utm_source=30758a10-c373- 4439-8936-25f3afa0210c&utm_content=daily Useful checklists indicating what steps must be completed in order to sign up for the Customs Declaration Service can be found here:
Moving to Customs Declaration Service Checklist
For DECLARANT www.gov.uk/government/pu blications/customs- declaration-service-commu nication-pack/declarant- checklist-moving-to-the-cus toms-declaration-service
For TRADER www.gov.uk/government/pu blications/customs- declaration-service-commu nication-pack/trader- checklist-moving-to-the-cus toms-declaration-service
Information about the Customs Declaration Service related to accessing the CDS, making payments and submitting live/training declarations can be found at: www.gov.uk/government/collections/customs-declaration- service CDS Movement Reference Number (MRN) Document The C88 and the E2 documents available in CHIEF are replaced by a combined MRN document in CDS. Please use
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the following link to see the format of the document which is agreed by the majority of the software providers. Furthermore, the document guide contains detailed technical description and example templates of the MRN documents. The document is available to view via the following link https://bifa.org/media/4924452/cds-recommended-import- declaration-layout.pdf Detailed entry completion guide The most important information source for completing Customs declarations in CDS is the UK Trade Tariff: volume 3 for CDS. www.gov.uk/government/collections/uk-trade-tariff- volume-3-for-cds--2 The information required in the CDS declaration is divided into eight distinctive data groups consisting of a number of data elements (DE). The following links list all the data groups and give detailed explanations of each data element of the specific data group:
Additional declaration completion guidance and technical assistance can be found in the ‘Tariff Volume 3 Great Britain Supplement CDS and CHIEF’, issued by HMRC. It includes the 2022 requirements where these differ or where changes to standard practices are applicable. The supplement is constantly updated and needs to be used in conjunction with the Trade Tariff Volume 3 for CDS. The document is available for download here: www.gov.uk/government/publications/customs-declaration- completion-requirements-for-great-britain Customs procedure code One of the most significant changes in the CDS compared with CHIEF is the requirement to build the Customs Procedure Code based on circumstances. The procedure codes in CDS are split in two parts: a single four-digit Procedure Code (DE 1/10) which has to be combined with a three-digit Additional Procedure Code (DE 1/11). Information regarding the four-digit Procedure code (DE 1/10) can be found here: www.gov.uk/government/publications/appendix-1-de-110- requested-and-previous-procedure-codes-of-the-customs-d eclaration-service-cds/appendix-1-de-110-requested-and- previous-procedure-codes-introduction-and-index-list Information regarding the three-digit Additional Procedure code (DE 1/11) can be found using the following link: www.gov.uk/government/publications/appendix-2-de-111- additional-procedure-codes-of-the-customs-declaration-serv ice-cds/appendix-2-de-111-additional-procedure-codes- introduction-and-index-list In order to see which three-digit Additional Procedure Code (DE 1/11) can be used with the appropriate four-digit Procedure code (DE 1/10) please use the Correlation Matrix which is available for download via the following link: www.gov.uk/government/publications/4-digit-to-3-digit- procedure-to-additional-procedure-code-correlation-matrix-f or-cds
IMPORT Group Guide www.gov.uk/government/pu blications/cds-uk-trade- tariff-volume-3-import-decla ration-completion-guide
EXPORT Group Guide www.gov.uk/government/pu blications/uk-trade-tariff- cds-volume-3-export-declar ation-completion-guide
The above links provide information regarding how to complete a CDS Customs declaration. They provide detailed information and explanation by the relevant groups within the entry, eg Group1 – Message information (including Procedure Code). This includes information regarding the relevant data elements contained within each group. Detailed step-by-step guides to completing CDS Customs declarations can be found via the following links:
IMPORT Guide www.gov.uk/guidance/navig ate-the-uk-trade-tariff-cds- volume-3-for-imports
EXPORT Guide www.gov.uk/guidance/navig ate-the-uk-trade-tariff-cds- volume-3-for-exports
These should be read in conjunction with the Import/Export Group Guide which provides information listed by group and subject matter
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Supporting documents For situations where the National Clearance Hub (NCH) requests additional documentary checks, CDS offers the opportunity to upload the supporting documentation directly and eliminates the need for sending copy documents by email to NCH. The documents can be uploaded using the following link: www.gov.uk/guidance/send-documents-to-support- declarations-for-the-customs-declaration-service CDS error codes When a CDS entry is submitted with incorrect data element information, the system will generate an error code. The error code aims to notify the user what information was submitted incorrectly and what actions are required to overcome the problem and successfully submit the entry. The full list of error codes can be accessed via: www.gov.uk/government/publications/customs-declaration- service-error-codes Further assistance can be requested by contacting HMRC support team: For Trade dress rehearsal entries: TDRcommunications@hmrc.gov.uk For live CDS entries: Financial impacts The Customs Declaration Service offers multiple options to the user to remit Import VAT and/or Duty payments. The three main payment methods are: • Cash Account • Immediate payment • Duty deferment account isbc.eoricontact@hmrc.gov.uk and cds.operations@hmrc.gov.uk There are alternative payment methods for certain regimes where General Guarantee Accounts (GGA) can be used to allow traders to release goods without payment of a deposit. Members should carefully check the criteria and circumstances when this can be used. In HMRC’s own guidance, the following examples are provided: • When moving goods no more than three times a year using Common or Union Transit,
• When using authorisation by declaration to put goods into Customs special procedures (inward processing, temporary admission or end use) no more than three times a year. Further information regarding General Guarantee Accounts (GGA) can be found at www.gov.uk/guidance/apply-for-a- general-guarantee-account-and-pay-disputed-amounts Before choosing the method of payment for a declaration it is essential to remember that in CDS the Method of Payment cannot be changed after the entry has been accepted by HMRC. If an entry is rejected due to insufficient funds the only options available are to make additional payments into the relevant account (Cash or Deferment) usually by bank transfer or cancel the original entry and re-enter using an account with sufficient funds in it.
Financial Dashboard
View Your Customs Financial Accounts looks like this
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Special Pull-Out & Keep Guide
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HMRC guidance refers to the ‘CDS Financial Dashboard’ as the web interface that can be used to add additional funds, however it is the web page named ‘View your Customs Financial Accounts’ (see page 13) that is required to complete the transaction and can be accessed via the following link: www.tax.service.gov.uk/customs/payment- records?_ga=2.204739600.18194638.1656319653-163236296 2.1638523190 Each user registering for CDS with a deferment account must set up a new direct debit instruction for the deferment account in CDS. Furthermore, the user needs to establish a new guarantee or apply for a waiver. The Customs Financial Accounts page can also be used to: • Grant or cancel authorisations to use the account for payments; • View Import VAT certificate (C79);
cds/getting-started-cds-declarations/ In addition, detailed guidance regarding Completing CDS Declarations is available on the ASM website here: https://help.asm.org.uk/sequoia/user-guides/guides/decln- cds/import-cds-declarations/ Most important points The KEY facts for the reader to be aware of are: • That a new direct debit instruction is required for deferment accounts following the successful CDS registration; • A Customs Comprehensive Guarantee (in most cases) is not required for the deferment account; however, a guarantee waiver must be granted; • Authorisation is required via the CDS dashboard to use someone else’s cash/deferment account or guarantee; • New format IP/OP authorisation references must be obtained for CDS declarations; • Method of payment cannot be changed after the CDS declaration is submitted; • Ensure you have sufficient funds on your accounts prior to goods arrival at the UK border. Cash/deferment account top- up can take up to 48 hours; • Postponed VAT accounting (PVA) is no longer declared at item level in CDS. Conclusion As might be understood from the information contained within this guide, CDS is a complex system based on interlinked data elements. The amount of information and the connection between the information components increases the chances of the entry being rejected, requiring additional work and time to amend the data and successfully re-submit the entry. Therefore, we strongly recommend commencing the transition from CHIEF to CDS as soon as possible by getting familiar with the requirements of each data element and submitting test entries via the Trader Dress Rehearsal service www.gov.uk/guidance/using-the-trader-dress-rehearsal-service which aims to mimic the live entry submission process. Disclaimer: All information was accurate at the time of writing. However, HMRC is making regular modifications to CDS, therefore certain information and processes may change. We suggest you regularly check GOV.UK for information.
• View postponed import VAT statements; • View notification of adjustment statements.
Greater complexity Why is a CDS entry more complex? • CDS is a move away from using paper-based rules on CHIEF to data processing rules; • CDS requires completion of 76 data elements for import and 65 data elements for export; • Most data elements in CDS are restricted to code format, other than name and address fields; • Three boxes on CHIEF may equate up to 17 different data elements on CDS; • CDS Procedure Codes (CPC) are multiple, interchangeable combinations depending on circumstances. In order to understand the relationship between CHIEF box numbers and CDS Data Elements, please use the CDS Data correlation Table, available here: https://bifa.org/media/4878814/106503_cds_data_element_cor relation_table_v4.pdf Additional comments ASM offers useful information entitled ‘Getting started with CDS declarations’ https://help.asm.org.uk/sequoia/user-guides/guides/decln-
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September 2022
BIFAlink
BIFA Awards
www.bifa.org
How Brexit presented a golden opportunity
SUPPLY CHAIN MANAGEMENT AWARD
Brunel European would have suffered disproportionately from the impact of Brexit. However, White said: “We saw a unique opportunity to develop our already established China imports Customs team on our deepsea division and train up a new EU brokerage team, thereby offering full EU transport and brokerage solutions to our EU clients – and also filling the Customs clearance void as 200,000 EU importers looked for a Customs broker.” “This was a golden opportunity. We believed that as Customs was effectively adopting the ROW model, everything entering the UK from the EU needed import brokerage services, and we knew our European transport division would hugely benefit in being able to offer end-to-end solutions for all our clients, so we linked the two together. We also invested £500,000 in our own ETSF in Ipswich to further enhance our service offering.” Adapting It has not been easy to manage the often last- minute changes that Brexit has entailed, but Brunel’s strategy has undoubtedly paid off. White said: “We just had to adapt and use our core experienced Customs team of 20 years, which was invaluable in terms of training additional staff. “European transport business is up 40% and we have attracted a lot of third-party brokerage from blue-chip companies, household names and major retailers, who choose to work with one company that can give them peace of mind and take care of all the new paperwork and delivery to door,” he added. “We believe we have filled a void in the market as some of the major European transport companies had to protect their own network of clients; there was a large gap for an independent company not tied to an existing network to develop and offer full door-to-door solutions and give value for money at the same time.” Brexit has been challenging but White said he has “quite enjoyed it – we are in the business of finding solutions for people, after all”. He added: “We have all had to develop a more specialist, skilled service, which is good for the industry long term.” BoxTop Technologies has been successfully delivering freight management software solutions to international freight forwarders and logistics providers for over 20 years. BoxTop puts you in control of a smarter, more efficient business and enables your team to free up time to focus on developing other areas of your business.
Brunel European took a proactive approach to the challenges of Brexit, developing new solutions for its European road freight customers and as a result scooping the 2021 BIFA Supply Chain Management Award
Brunel European’s BIFA Supply Chain Management Award win was based on its work for a Spain-based retail logistics company, which approached Brunel European in December 2020 to provide UK supply chain solutions as it was encountering huge delays with parcel carriers owing to Brexit. On behalf of its client’s customers, Brunel began delivering UK-bound goods to its own external temporary storage facility (ETSF) in Ipswich for storage prior to processing by UK Customs or re-export. Mike White, group operations director at Brunel European, explained: “We raise a T1 document from Spain to our bonded Ipswich site and we then Customs-clear and discharge all the documents, and the drivers continue to the parcel hub carrier.” The drivers are normally held in Ipswich for three hours maximum (a huge improvement on the sometimes month-long delays Brunel’s client had previously experienced); the system has been working “seamlessly” since January 2021, White said. In-house brokerage Brunel also developed its own in-house ‘J Freight’ Customs brokerage package to enable multiple-origin cargoes from up to 30 different countries to be declared correctly and with all duty and VAT paid, expediting the clearance process and ensuring compliance. Three different modes of clearance are used per truck – inward processing relief, bulk data and home use – plus different forms of duty relief claimed, depending on various free trade agreements from origin. Given that it has specialised in European road freight for 15 years, one might assume that
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September 2022
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HMRC is retiring CHIEF. Is your business ready for CDS? The Customs Handling of Import and Export Freight (CHIEF) — the UK’s existing electronic system for handling customs declaration processes — will soon be retired and replaced by the new Customs Declaration Service (CDS). Anyone who imports or exports from the UK should be aware of the upcoming changes and have a plan for the transition. Adjusting processes is never easy, but with the right planning and support, you can adapt to CDS, continue to serve your clients, and protect your bottom line.
BIFAlink
Policy & Compliance
www.bifa.org
overhauled to recognise the needs of cargo movements both currently and in the future. The relevant planning authority will be empowered to plan for these needs. People and skills: To ensure that logistics becomes the industry of choice for talented and skilled people at all stages of their career. This The Future of Freight – an overview In a new document outlining its aims for UK trade, the Department for Transport sets out its priorities and the criteria by which progress can be judged
Some weeks ago, the Department for Transport (DfT) released its 133-page document entitled The Future of Freight detailing its aspirations to improve freight flows both nationally and where there is an interchange between these and international supply chains. The document is a direct result of work between the department and trade during and after the pandemic to keep supply chains open. Historically, the DfT has focused its work on domestic transport issues, planning and regulation, so in many ways this document is an interesting innovation. The importance of international freight and logistics is highlighted, being given significant prominence in the document. One comment is particularly relevant: “The multimodal freight and logistics sector is critical to every supply chain into, across and out of the UK and is fundamental to our economic well being.” What is particularly telling is the contrast in ownership models: domestic infrastructure such as roads is predominantly state owned, whilst most entities involved in international trade, including the majority of the main UK (air)ports, are in private ownership. This latter group includes most freight forwarders and all of BIFA’s Members. In the spotlight Due to EU-exit, the disruption stemming from COVID-19 and the war in the Ukraine, the international freight sector has been in the public eye. Whether or not we are comfortable with being the centre of attention, these events have highlighted the sector’s importance to government and the wider public. In the UK, international trade is economically more important than in other countries. The UK is a trading nation with imports and exports comprising 62.9% of GDP, higher than the global average of 56.3% in 2019. It is estimated that the sector contributes 10% of the UK non- financial business economic activity with a estimated gross turnover of £127 billion. The report highlights the importance of each mode and illustrates why it is important to be able to switch between them. For instance, the critical role air played, particularly in the early stages of the COVID-19
pandemic, in moving PPE. In many ways the plan is only a starting point for government-industry
increases resilience and facilitates the distribution of goods to, within and from the UK.
Data and technology: The ambition is to increase the
collaboration on improving freight flows. The following criteria have been agreed between government and trade as key indicators for judging performance: Cost efficient: The sector needs to deliver globally competitive costs and support the broader UK economy with access to low-cost goods transport.
awareness of the sector amongst innovators and to make the logistics sector more aware of the potential to innovate.
Economic ambitions These are the main themes from a
purely business perspective. However, the document does reference government’s wider economic and related political ambitions which cover: • The levelling up agenda: by encouraging economic growth across the country, • Strengthening the Union by involving the Devolved Administrations in implementing the plan throughout the UK, • Increasing UK global influence through trade, and the efficiency with which it is handled. Trade is facing greater headwinds than it has faced for at least the last four decades; for whatever reason, the economic liberalism that under-pinned growth and the spread of the global economy is increasingly being challenged. As some have commented, ‘friction’ has been re-introduced into trade and business needs to adjust to this new situation. Effectively ‘friction’ is becoming the new normal, with resultant slowing down of supply chains and increase in costs. It is against this background that the Future of Freight and other government initiatives, such as developing a ‘Single Trade Window’, need to be considered. Clearly government thinking is that there is a need to offset the negative impact of increased ‘friction’ by improving both frontier procedures and domestic capability to make it physically easier to move cargoes in order to ensure the UK’s long-term prosperity. It will be interesting in a few years’ time to assess how many of these projects, some of which are conceptual, have been implemented and what benefits they have delivered.
Reliable: Delivering consistently good performance for its customers, providing reliable access to the goods that businesses and consumers need. Resilient: Ensuring that the freight network has the capacity to anticipate, absorb, resist or avoid disruption and recover when disruption does occur. Maintaining the smooth flow of goods throughout. Environmentally sustainable: Achieving a net zero freight and logistics sector by 2050, whilst supporting broader environmental objectives of air quality and noise reduction. Valued by society: Ensuring that freight is valued by the public and decision-makers across sectors, reflecting the sector’s critical importance to the wider economy and the lives of everyone in the UK. In order to ensure that these goals are met, the five main priority areas have been identified as: A national freight network: Government and industry will work together to ensure that the freight network supports end-to-end freight journeys that are efficient, reliable and resilient. The role of freight will be considered in strategic infrastructure investment and planning. Transition to net zero: The ambition is to enhance investment certainty to harness cross- modal efficiencies as the whole sector journeys to net zero by 2050. Planning: The planning system will be
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September 2022
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