BIFAlink August 2022

BIFAlink is BIFA's monthly magazine covering issues of importance for the logistics and supply chain industry.

August 2022 The magazine of the British International Freight Association BIFA link Issue: 384

Container overboard: How did that happen? – Page 8


9-12: Special four-page pull-out: Customs Declaration Service: your guide to essential information

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National & European customs tariff classification and Harmonised System Notes. UKFR BE

A solution for all customs mangement needs: Common & Simplified, Import & Export Special Procedures UKFR BE

Entry Summary declarations ENS to GB S&S (Safety & Security) and EU ICS (Import Control System) UK NI EU

Robert Keen’s Column


Making hay whilst the sun shines

BIFAlink is the official magazine of the British International Freight Association Redfern House, Browells Lane, Feltham TW13 7EP Tel: 020 8844 2266

The saying that headlines this piece came to mind as I was reading a recent report issued by consultant Transport Intelligence (Ti) about the current state and future prospects of the freight forwarding market. As farmers in the UK are predicting excellent harvests this summer, Ti reports that according to its research the global forwarding market had a record ‘harvest’ of its own in 2021, rebounding and exceeding its pre-pandemic levels. It added that whilst limited capacity and record high freight rates present a challenging market for shippers, this has presented opportunities for extraordinary ‘uplift’ in the profitability of freight forwarders, which is certainly the case from the conversations that I have had with many Members.

Web site: E-mail:

(A company limited by guarantee. Registered in England: 391973. VAT Registration: 216476363) Director General Robert Keen Executive Director Robert Windsor, Policy & Compliance – Surface & Legal

Ti reports that the global freight forwarding market grew by 11.2% in real terms during 2021, the fastest expansion in a decade, and forecasts that the market will grow 5.7% in 2022 and at a 3.7% compound annual growth rate over the five years to 2026. This also corresponds with many of the anecdotal comments about growth that I am hearing from BIFA Members and will be music to your ears. The market’s expansion was driven by global trade which reached new record highs during the year as recovery from the COVID-19 pandemic boosted demand. As well as the phasing out of pandemic-related restrictions on economic activity, government support schemes and economic stimulus packages introduced in many countries remained, keeping demand for goods at elevated levels. Factors such as the expansion of the e-commerce industry and the rise of free trade agreements have also been contributors to the growth of the global digital freight forwarding market in 2021. However, Ti’s report foresees that the drivers of the growth momentum are likely to gradually abate, with forecasts for the period 2023-2026 being more pessimistic due to inflation, the war in Ukraine, and consumer spending slowing down. The entrance of shipping lines into the acquisition market has created a new driver of industry consolidation, not least due to the carriers’ almost unlimited funds and access to ‘cheap’ money. But ocean freight and port congestion show few signs of improvement and will continue to push traditional ocean shippers into the air freight market. It was interesting to read that the digitalisation trend in the forwarding industry, which was already gathering pace before the pandemic, has been accelerated further by the crisis with the adoption of digital forwarders, online freight booking platforms and marketplaces increasing threefold since 2019. Many believe these ‘newbies’ could become game changers in the industry, and I was somewhat surprised to read that digital forwarders and booking platforms are used by 81% of the shippers and logistics service providers (LSPs) that were surveyed by Ti. What it does not indicate is whether the users are satisfied with their experience, nor how successful the digital forwarders and booking platforms have been in their aim to combine smart technology with actual operational experience. Clearly, however, driven by challenging market conditions, shippers are re-assessing their freight procurement strategies and contractual relationships with LSPs to adjust to the ever-changing environment. Something that another of my old bosses, who has recently hung up his boots, will have seen plenty of during a 62-year career in the freight industry. After a couple of recent obituaries, I am honoured to mark the retirement of industry stalwart, Gerry Burgin, who has been attending meetings of the BIFA Air Policy Group for over 20 years. I worked under Gerry at Transglobal in the early 1980s and he was a dynamic leader then with boundless energy, which is still evident today. Knowing Gerry, I expect he will still be on the forwarding social scene for many years to come and I am sure he will agree with me when I suggest that Members should take heed of the headline of this column and invest profits wisely now to meet the current and future issues that they will face. Executive Director Spencer Stevenson Executive Director Carl Hobbis Policy & Compliance Advisor – Customs Igor Popovics Policy & Compliance Advisor – Air David Stroud Editorial Co-ordinator Sharon Hammond Communications Manager Natalie Pitts Membership Supervisor Sarah Milton

Published by Park Lane Publishing 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

August 2022



News Desk

Ian Matheson, from Impress Communications, reviews some recent news that might impact on Members’ business

Increased biosecurity risks, and delays for biosecurity clearance at the border, are adding costs to already costly global supply chains. Concerns have been raised that some of these new and emerging risks may take limited biosecurity resources away from business-as- usual trade facilitation activities, and lead to bigger delays for some importers at international borders. So that standard and arrived export ports are using similar processes to verify Customs clearances and keep goods flowing at the border, HMRC has made some changes in GVMS for Common Transit Convention Movements for exports. These came into force on 1 August 2022 and mean that an operator can no longer input a transit Movement Reference Number (MRN) in a Goods Movement Reference (GMR) for an outbound transit movement from Britain, unless it is an authorised consignor or consignee (ACC). A retailer rush to restock depleted inventories has left many of the world’s largest stores with an unexpected glut of goods, even as inventory levels across the economy remain lean by historical standards. Supply chain experts say that the gap is in part due to general merchandise stores pulling in orders earlier to fill shelves, whilst consumers have now pivoted in the other direction, pulling back on purchases of goods that were once in high demand. Six in 10 SMEs in the USA have reported stolen shipments over the past year, with 75% of thefts resulting in losses of up to USD20,000, according to a survey of 320 supply chain managers conducted by Capterra. Of those suffering losses, 33% said that theft was enabled by employees and 30% said it was enabled by vendors, whilst 63% reported performing background checks on logistics/inventory management employees.

Ocean carriers adopt blanking strategies

ON THE OCEAN The Loadstar reported in July on the latest edition of project44’s Ocean Carrier Report, concluding that ocean carriers are resorting to more aggressive blanking strategies to

alleviate supply chain constraints and improve the performance of the air cargo market in May, with global demand 8.3% below May 2021 levels. This was an improvement on the year-on-year decline of 9.1% seen in April. Capacity was 2.7% above May 2021, which more than offset the 0.7% year-on-year drop in April. The European Commission (EC) is urging the air cargo industry to prepare for new rules that from March next year will require the submission of advanced shipment information before air cargo is loaded.

and outside of working hours – for the past 28 days.

Eurotunnel Le Shuttle Freight wants to expand its unaccompanied freight business to link inland UK rail freight hubs with European origins and destinations, according to The Loadstar. It says that its Border Pass can make the border crossing as quick as pre-Brexit transitions for unaccompanied freight. IN BUSINESS According to Transport Intelligence, the global forwarding market exceeded pre-pandemic levels in 2021, but limited capacity and record-high freight rates present a challenging market. Ti predicts that the market will grow 5.7% in 2022, slowing to 3.7% by 2026. The TT Club has used the IMO’s recently revised guidelines for the implementation of the inspection of cargo transport units (CTUs), which aims to help governments implement a uniform and safe inspection programme, to reiterate its call for increased inspections of all types of cargo, not just those declared dangerous.

manage a dip in demand and decreasing freight spot rates.

July saw FIATA, the International Federation of Freight Forwarders Associations, make a further call on industry stakeholders and market regulators to take action to ensure a balanced and fair trading system within maritime supply chains. The World Shipping Council (WSC) has reported that during the last two years, container losses at sea have increased significantly with the average losses for the two-year period 2020-2021 reaching 3,113, compared with 779 in the previous period. The WSC said that one of the most important reasons for this worrying spike is the unusually high number of weather-related incidents. IN THE AIR IATA has reported that the easing of the COVID-19 Omicron restrictions in China helped to

OVERLAND With the DVSA increasingly enforcing regulations during roadside stops and when

investigating operators, as well as scrutinising operators’ facilities to find out if they have systems in place to document drivers’ timetables in sufficient detail, TruTac has warned businesses about little- known but stringent tachograph compliance rules. These require commercial vehicle operators to record and show evidence of drivers’ timetables – both during


August 2022




News Desk

Fit for human consumption

Inaccurate weights issues highlighted

In the lead-up to the implementation of the International Maritime Organization’s Safety of Life at Sea (SOLAS) verified gross mass (VGM) regulations, BIFA was heavily involved in making Members aware of the changes. This regulation, which requires the gross mass (cargo gross weight plus container tare weight) of loaded shipping containers to be recorded and verified before they can be loaded onto a vessel for export, came into force on 1 July 2016. Effectively there are two methods to achieve an accurate VGM, but both require weighing. The VGM regulations have been successfully implemented across the globe, resulting in much safer supply chains. BIFA receives very few enquiries on this subject from Members now. Recently, however, concerns have been raised over the accuracy of weighing facilities, as well as the number of late VGM amendments. Asia-Europe ocean carriers are starting to take action against shippers who incorrectly declare westbound booking container weights and make last-minute VGM amendments. Misdeclared booking weights can cause the weight allocations of individual alliance partners to be exceeded, ships to shut out cargo, contracts to underperform and revenue to be lost. The Japanese carrier ONE became the first carrier to take action when advising that it would impose a $2,000 per container weight discrepancy charge (WDS) from 1 July for bookings accepted on or after that date. ONE said the penalty fee would apply where the cargo weight deviated by more than +/- 3 tons per teu from the bill of lading instructions and documentation. The implementation of VGM coincided with relatively low maritime traffic levels. COVID-19 and the resulting higher traffic levels have focused minds on the weight issue, making it more important to ensure that the correct weight for each container is declared.

In an example of its work, the Suffolk Coastal Port Health Authority (SCPHA) has shared information relating to the identification of a consignment of frozen sea bream imported through the port of Felixstowe in June which was contaminated with the tongue-eating parasite cymothoa exigua. With a team of 130, the SCPHA provides essential health checks on food and animal-related imports to ensure that they are safe for human consumption and present no risk to UK wildlife and agriculture. In this case it was able to prevent the parasite- infested consignment from entering the UK. In the course of its work it will check around 80,000 consignments a year arriving at the port of Felixstowe – Britain’s busiest container port – Harwich international port and the port of Ipswich. Port health inspectors are part of the environmental team of the local district council. Information on the import of goods subject to port health control via UK ports can be found at: • for the Port of Felixstowe, Harwich International Port and the Port of Ipswich • for the Port of Liverpool • standards/london-port-health-authority/contact-lond on-port-health-authority for London Gateway • health/ for Southampton •

safe/environment-health/port-health/grimsby-and- immingham-port-health-charges/ for Grimsby and Immingham • Protection/Port-Health/Port-Health.aspx for Dover. Cymothoa exigua are tongue-eating parasites that affect fish and were found in some imported sea bream during a health check by Suffolk Coastal Port Health Authority

Reference to CHIEF removed from BIFA training courses – not quite

All courses from 1 August will contain reference to CHIEF and C88 for exports only. With the full introduction of the Customs Declaration Service (CDS) on the horizon, our training team have been faced with the dilemma of when they stop talking about CHIEF, box numbers, C88 etc, in our Customs-related courses. Carl Hobbis, executive director with responsibility for training, explained: “With a track record of 11th hour delays on previous Brexit and EU Exit-related subjects, this has been a bit of a conundrum for us. “In the end, we have decided that for any Customs course starting from 1 August, all references to CHIEF-related items will be limited to exports only. This is because the

CHIEF import facility is due to be removed on 30 September 2022, with CDS becoming the only place to make import entries. It will still be possible to make export entries through CHIEF until the end of March 2023 when this function will also be removed. “From August, any delegate doing our BTEC course will find that all teaching, homework and the final assessment will be based on CDS.” BIFA is still receiving a relentless number of enquiries and appetite for Customs training, and as a result our freight and Customs training courses are now booked-up months in advance. Hobbis said: “We have added more dates to our calendar for the remainder of the year, so we

encourage people to book early to secure places. “Our training has built-up a reputation for being relevant for the day-to-day knowledge needed and the feedback we receive from our sessions is incredibly positive. “We have recently delivered face- to-face courses in Heathrow, Manchester and the Midlands, plus some in-house at BIFA Member premises. Whilst we all understand the convenience of remote learning, you cannot beat face-to-face, so I would encourage Members to support these.” For course information visit: procedures or to discuss training options, contact Carl Hobbis at


August 2022

News Desk


BIFA welcomes government supported Generation Logistics

Return to Liverpool Following a COVID-19 enforced hiatus, the BIFA Liverpool Region Annual Dinner returns to The Liner Hotel, Liverpool, on Friday 30 September 2022. Tickets are now on sale for this popular black-tie evening during which guests will hear from the Drum Corps of the local Ellesmere Port Sea Cadets, enjoy a three- course dinner and be entertained by comedian John Martin. BIFA is grateful to the sponsors Genco Logistics, Hapag-Lloyd, Maersk, MCP and Peel Ports for their support for this event. The BIFA Liverpool Region Annual Dinner provides an excellent opportunity to entertain guests or reward staff for their hard work. Book your table now at to avoid disappointment. Once again we will be supporting the work of local charity Zoe’s Place Children’s Hospice, Help 4 Heroes and making a donation to the Ellesmere Port Sea Cadets. If you are able to offer either a raffle prize or auction lot, please contact Sharon Hammond at

BIFA is supporting the collaborative approach of all trade associations to addressing the industry’s long-term recruitment and staff retention issues with the launch of a major new awareness and recruitment campaign, Generation Logistics. The campaign, which was recently launched across the sector at Multimodal 2022 (pictured), has gained significant support from blue-chip organisations, BIFA Members and businesses of all sizes from across the logistics industry. It is also supported by the Department for Transport. Carl Hobbis, executive director, BIFA, said: “It is really encouraging to see all the key trade associations and the wider industry join forces to help raise the profile of the sector. All our Members have similar challenges attracting talent and this coordinated campaign will help put it at the forefront of young people’s minds as a potential career choice.” The Secretary of State for Transport, Grant Shapps MP, is delighted that the government is supporting the campaign. “I am proud to confirm government support for the Generation Logistics campaign. The pandemic has once again demonstrated the strategic importance of supply chains and their associated workers. Their work to keep the UK moving was exemplary and I have nothing but

backgrounds, experience and skills. This campaign will showcase those opportunities in artificial intelligence, advanced robotics, autonomous vehicles and the decarbonisation of the supply chain. This industry campaign is integral to not only supporting growth of this vital sector but also ensuring we have the workforce needed for now and the future.” In addition to a comprehensive web portal, containing careers advice and guidance, features, video content, jobs and news, the campaign will focus on several key demographic areas, all of which could be inclined towards taking up a role in logistics.

admiration for those unsung heroes who keep the UK trading, keep food on our shelves and provide our factories, shops, hospitals and schools with the supplies they need. Logistics workers make a substantial difference to our lives, every day. “However, we have a new challenge facing us as we look to the future of freight. We need to attract a diverse and skilled workforce to play a key part in a new, exciting era transforming an industry at the forefront of

innovation and technology. There are thousands of logistics roles available to people from all The target audience launch took place at the end of July. To find out more about becoming a sponsor, contact Carl Hobbis The Limits of Liability for Carriers

By sea – Hague Visby rules (2 SDR): £2.20 per kg £731.69 per package

By air – Warsaw Convention (17 SDR): £18.66 per kg

In association with

BIFA STC: (2 SDR): £2.20 per kg

By road – CMR (8.33 SDR): £9.14 per kg

Insurance for the Marine & Logistics industries

(The SDR rate on 18 July 2022,

By air – Montreal Convention (22 SDR): £24.15 per kg

according to the IMF website, was 1.09753)

+44 (0) 1628 532613

August 2022



Policy & Compliance

goods are involved there is the ever-present danger of pollution and damage to the marine environment. The shipping lines argue that the number of containers lost overboard remains small, relative to the total number of containers shipped in a year. The latest figures from the World Shipping Council, which represents the major container lines, show the number of boxes lost overboard in 2020-21 account for less than a thousandth of 1% of the 241 million containers shipped each year. But the past two years had seen a “worrying break in the downward trend” of losses, with the average number of containers lost at sea per year in the 14 years since the survey began increasing to 1,629, up 18% since the previous survey results for the 12 years to 2019. “The winter of 2020-21 saw an unusually high number of weather-related incidents, and the average losses for the two-year period were 3,113 compared with 779 in the previous period,” the WSC said. Three-year moving average figures had been trending down since 2013, when the total loss of MOL Comfort (IMO: 9358761) with 4,293 containers on board led to a sharp spike in the number of boxes lost. But this trend was reversed in 2020 following the ONE Apus casualty, where more than 1,800 containers were lost in a single event, and the loss of another 750 from Maersk Essen in 2021. To reduce the number of losses, the WSC and its member carriers have joined with Dutch research institute Marin to run a study on how to reduce the risk of container losses. Parametric rolling Among the concerns being investigated is the phenomenon of ‘parametric rolling’, where ships lose stability in following seas. A Notice to Mariners has been developed to help crew recognise, plan their response and prevent parametric rolling. The WSC and member companies have also contributed to and supported revision of the International Maritime Organization (IMO) guidelines for the inspection programmes for cargo transport units. It also supports the creation of a mandatory reporting framework for all containers lost at sea. The WSC will be increasing the frequency of its own reporting, following the sharp increase in numbers during 2020-21. The report, which was previously published every three years, will now be issued annually. There is an increased emphasis on safety in the maritime environment, which is to be welcomed, but it is incumbent upon each party in the supply chain to play their part in driving up standards.

The number of containers lost overboard has, worryingly, begun trending upwards again after a period of decline. As a result the World Shipping Council has joined a study looking at how to reduce these losses How did that happen? Container overboard

In a recent BIFAlink article we highlighted the dangers of undeclared dangerous goods, especially lithium batteries, to ships, crews and landside operations. Whilst major incidents such as the loss of MSC Napoli (2007) attract the most attention, the loss of a number of containers overboard attracts little attention. Some of these incidents can be amusing and can actually have beneficial side effects. The most famous such incident, and the one discussed by David Attenborough in the Blue Planet, was the case of the ‘friendly floatees’ after a consignment of some 29,000 plastic yellow ducks, red beavers, blue turtles and green frogs (estimated weight 28,000 kilos) were washed into the Pacific in 1992. The little toys began appearing on beaches around the world, from the west coast of America to South America, Australia, and by 2007, Europe. This incident attracted considerable media attention and allowed scientists to analyse global ocean currents.

The sad truth of the matter was that scientists were already working on a model, tracking 61,000 Nike trainers lost overboard in 1990. Unfortunately, amusing as these incidents are, sight must not be lost of the simple fact that each container lost overboard represents a loss to the owner of the goods. Also shipping lines, where there is a danger to shipping, are required to recover such containers whenever possible. Bay of Biscay losses One such incident occurred on 14 February 2014, when 520 containers were lost overboard in bad weather in the Bay of Biscay. About 85% of the containers, being empty, sank almost immediately, but some of the balance entered the English Channel. Whilst empty containers sink reasonably quickly, it can take up to two months for a loaded 20 ft container to sink and, buoyed by refrigerant, a ‘reefer’ can take longer. While afloat, these containers represent a danger to shipping, and in all cases where dangerous


August 2022

Special Pull-Out & Keep Guide


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 below link collects introductory guides related to import, export, duty payment options and also a description of the CDS Movement reference number (MRN). 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 blications/customs- declaration-service-commu nication-pack/declarant- checklist-moving-to-the-cus toms-declaration-service

For TRADER 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: 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

August 2022



Special Pull-Out & Keep Guide

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 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. 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: 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: requested-and-previous-procedure-codes-of-the-customs-dec laration-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: additional-procedure-codes-of-the-customs-declaration-servic e-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: to-additional-procedure-code-correlation-matrix-for-cds

IMPORT Group Guide blications/cds-uk-trade- tariff-volume-3-import-decla ration-completion-guide

EXPORT Group Guide 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 ate-the-uk-trade-tariff-cds- volume-3-for-imports

EXPORT Guide ate-the-uk-trade-tariff-cds- volume-3-for-exports

This should be read in conjunction with the Import/Export Group Guide which provides information listed by group and subject matter

Click here to view this document online


August 2022

Special Pull-Out & Keep Guide


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: 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: service-error-codes Further assistance can be requested by contacting HMRC support team: For Trade dress rehearsal entries: 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 and 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 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. HMRC guidance refers to the ‘CDS Financial Dashboard’ as the web interface that can be used to add additional funds,

‘View your Customs Financial Accounts’, pictured below, needs to be

accessed to complete the transaction

August 2022



Special Pull-Out & Keep Guide

however it is the web page named ‘View your Customs Financial Accounts’ which needs to be accessed to complete the transaction and can be accessed via the following link: 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. Also, the Customs Financial Accounts page can be used to: • Grant or cancel authorisations to use the account for payments; • View Import VAT certificate (C79);

In addition, detailed guidance regarding Completing CDS Declarations is available on the ASM website here: 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 IPR/OPR 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 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 a CDS entry is 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: relation_table_v4.pdf Additional comments ASM offers useful information entitled ‘Getting started with CDS declarations’ cds/getting-started-cds-declarations/

Click here to view this document online


August 2022




The biggest change in nearly 30 years is happening in our industry over the next  months.

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 knowi if youo woul ld like a convs ersat tion. .ukk


BIFA Awards


staff the fantastic opportunity to obtain a recognised qualification within the industry,” he added. “We pride ourselves on providing an environment that allows our people to thrive. By establishing defined goals and action plans for career progression, we endeavour to help our teams expand their knowledge and continue to improve the quality of their work life, which we know is essential to the success of any business.” Among Unsworth’s initiatives for boosting morale is the company’s GEM Award, which every quarter celebrates a member of staff who has ‘Gone the Extra Mile’. Noting that employees vote for their own colleagues, Hogg added: “The awards are a chance to recognise and highlight those who have gone above and beyond the call of duty, and they create a feel-good factor among our staff.” Feedback and suggestions Unsworth employees are also encouraged to provide feedback and suggestions to senior management as part of the company’s policy of open communication. “Staff can speak to us face to face or give feedback via an anonymous form, and we also hold periodic Q&A sessions to address their concerns. Where people can see that the company is listening, taking on board their views and implementing some changes, they feel that their voices are being heard.” It is through weekly feedback meetings that Unsworth took on board the suggestion to introduce a wellbeing day during the COVID-19 pandemic: an extra day of annual leave available to all staff immediately, that allows teams to take a day off work to look after their mental wellbeing. This was felt to be necessary given the challenges of COVID-19 and Brexit. Unsworth now also provides a company healthcare plan for all employees. Hogg observed: “Health and wellbeing are especially important when there is continuous supply chain disruption; people need to find a work/life balance in order to function at their peak level of performance.” Albacore believes that people are a company’s most valuable asset. That is why we are proud to sponsor the Staff Development Award once again with 2021 being the 11th year. Albacore supplies and supports efficient and reliable IT systems which ensure productive, empowered and satisfied staff.

Recent Unsworth GEM awards winners: Mario Maresse and Magdalena Krasinska

Building success by putting people first

Unsworth, winner of the 2021 BIFA Staff Development Award, prides itself on investing in its employees through training, recognition and career progression

“As an industry we need to be doing more to attract and develop staff,” said Richard Hogg, managing director at Unsworth. He feels the skills gap in logistics has been compounded by Brexit. “There is a lot of demand in the market for skilled Customs resources. The only solution is to encourage more people to join the industry and give newcomers structured learning paths and career progression.” Unsworth’s ‘onboarding’ strategies for new staff are structured plans with progressive milestones; face-to-face and online training; and reviews with the employee’s line manager and HR to identify any gaps in their knowledge and provide more support where needed. This has been especially important through Brexit, as the company has upscaled rapidly with the addition of a brand-new Customs Solution team to deal with the influx of Brexit- related Customs enquiries. “As part of our approach to staff development, we re-launched an updated in- house training course on Customs Clearance Requirements and Compliance in the UK, using our internal platform iSpring,” Hogg said.

Richard Hogg,

managing director at Unsworth

iSpring is a flexible training tool; Unsworth can configure modules and tests according to need, and the digital courses are supported with events such as visits to ports like Calais or Dublin. “Our Customs course enables staff to continue their training further using the UK Customs Academy to gain externally accredited qualifications, which is good for their career progression,” Hogg said. “The UK Customs Academy delivers training and qualifications that help our staff become either an accredited Associate Customs Practitioner or a Certified Customs Practitioner. As Unsworth is very keen to invest in our team’s professional development, we are glad to provide


August 2022



Legal Eagle

Know your BIFA Standard Trading Conditions – Clause 4

In this month’s edition of BIFAlink we turn to the section of the BIFA Standard Trading Conditions (STC) headed ‘The Company’. In this part of the STC there are 13 clauses numbered 4 to 16 and they describe the role of the freight forwarder in the provision of services to the customer. Certain rights are stated and what actions the forwarder can take in certain circumstances.

care towards his Customer’s interests and in the choice of contractors but may escape liability for the actual performance, such as damage or loss arising during the carriage of the goods or from their packing or handling. As a principal, a BIFA Member has responsibility for the performance of the contract but does not have to concern himself with the Customer’s interests beyond that task. In practice, a BIFA Member can sometimes act both as an agent and as a principal – a ‘mixed contract’ – for example by acting as an agent for the packing and as a principal for the carriage of goods, or vice versa. When a BIFA Member’s own staff perform a task then it usually acts as a principal. When a BIFA Member operates his own groupage or consolidation service, it is as a principal. When a BIFA Member issues his own bill of lading or own air waybill, it is as a principal. When a BIFA Member acts as a ‘house agent’ for the Customer, acting as a traditional forwarding agent booking space with the shipping company and paying freight, etc, on behalf of the Customer, then the BIFA Member acts as an agent. However, the distinctions are not always that clear. Generally speaking, if there is doubt, the BIFA Member probably acted as a principal. A BIFA Member can have a different agency role – that as agent for the principal carrier. For example, this may arise when the BIFA Member acts as the English agent of an overseas carrier, issuing transport documents that clearly show the overseas company as the carrier or receiving goods on behalf of the overseas carrier. The BIFA Member’s obligations are then predominantly to his overseas principal. Notification of a claim to the BIFA Member as such an Agent is tantamount to notification to the overseas carrier, and the transaction may be subject to the trading conditions of the overseas carrier, even when its English agent is a BIFA Member. This clause gives the BIFA Member full discretion as to how any service is performed, whether acting as an agent or as a principal. However, the interests of the Customer or Owner must be observed and if a particular means, route or procedure is specified by the Customer or Owner, care must be taken that there is not blatant breach of contract. See also Clause 6 (A) for when the BIFA Member acts as an agent.

CLAUSE 4 This clause gives the BIFA Member a liberty to act as an agent or as a principal. The BIFA Member will have differing responsibilities and liabilities according to which role applies. Clauses 11 and 12 are referred to as an exception because it is deemed that a BIFA Member always acts as an agent when arranging insurance or when arranging conditional delivery or release of goods or documents by the use of third parties. It can be difficult to decide whether a BIFA Member acts as an agent or as a principal. The following points should be taken into account (not all need apply): 1. A BIFA Member is not an agent simply because he believes he is an agent, or says he is an agent, or has the word ‘Agent’ or ‘Agency’ in the company name. 2. A BIFA Member can be a principal (carrier) even if he does not own any vehicles or other transport equipment. He can sub-contract. 3. The impression of his role given by the BIFA Member to the Customer and whether the Customer had the expectation that the BIFA Member would assume the role of principal, sub-contracting as necessary, or whether the BIFA Member would act as a forwarding agent making arrangements on the Customer’s behalf with other carriers. If a BIFA Member deceives a Customer by advertising, or promises that it operates certain services when in fact it does not, it will probably be deemed to have acted as a principal and denied any assertion that it acted as an agent. 4. Whether the identity of the actual carrier was revealed at the time of shipment. 5. Whether or not the BIFA Member quoted and/or charged a lump sum or gave a breakdown of freight and ancillary charges. This point is of less importance than in the

past because charges are commonly aggregated to be zero-rated for VAT purposes. 6. Whether or not freight and other charges were charged by the BIFA Member according to the carrier’s charges with a modest agency charge added for profit. At English common law, an agent has no right to a secret profit but a principal is free to make whatever profit he can get without the need for disclosure. 7. Would the BIFA Member be comfortable in revealing to his Customer the amount of the invoice paid to the carrier or other third party? 8. Whether the BIFA Member deals with the

Customer in a general way for several destinations by one or more modes of

transport, or whether the BIFA Member was chosen for a particular job or a particular destination. 9. Whether or not the BIFA Member can comply with Clause 6(B) 10. If a BIFA Member has acted on instructions from his Customer to contract with a carrier nominated by his Customer, the BIFA Member will be deemed to have acted as an agent and not as a principal (unless there are very unusual overriding circumstances). It is a fallacy to assert that the BIFA Member has less liability as an agent than as a principal. The truth is that a BIFA Member’s liability as an agent is different from that of a principal. As an agent, a BIFA Member owes a higher duty of


August 2022

BIFA Awards


The go-to guy on Brexit Jamie Halliday joined Tudor International Freight through its links with Leeds Trinity


quicker that way,” he said. Jamie took a proactive approach in response to the UK’s exit from Europe and has become Tudor’s ‘go-to guy’ for all things Brexit. He believes youth has been on his side through the various changes, saying: “When you are younger it is easier to adapt, because you are not as set in your ways as someone who has been clearing goods the same way for 15 or 20 years.” Evidently quick to learn, Jamie has also been passing on his skills. For instance, he mastered the Destin8 Customs software and then trained his colleagues. He pointed out: “As we are only a relatively small team, it is really important that all members have an understanding of how everything works across the board.” Virgin Atlantic Cargo is proud to sponsor BIFA’s ‘Young Freight Forwarder Award’ to recognise and encourage the next generation of industry leaders. As well as rewarding the progress of the best young people, this award helps to highlight the vital role freight forwarders play in the growth and development of our industry.

University. He has never regretted applying for a graduate position in logistics and was proud to reach the finals of BIFA’s Young Freight

Forwarder of the Year Award in 2021

Jamie Halliday observed: “I knew nothing about the freight industry – probably like most young people straight out of university. I undertook some brief external training in respect of Customs processes and procedures during my first few weeks at Tudor; however, the most beneficial training came from my colleagues, who trained me on live jobs from day one.” During the COVID-19 pandemic, though, Jamie had limited assistance and he is certain that this helped accelerate his development. “I was thrown in at the deep end, but you learn

Calm and confident


Seetec Outsource Training & Skills is a

One of the finalists in the BIFA Apprentice of the Year Award category for 2021 was Thomas Low, who has made rapid progress along his chosen path at OIA Global

quickly – and it is the same with cargo. The challenges of everything coming together at the right time, under very time-critical circumstances, are similar.” Thomas started his career in logistics as a purchasing assistant. Furloughed and then made redundant during the pandemic, he found his way to an apprenticeship through his links with the BIFA Young Forwarder Network. “I really enjoyed the process of going through the BIFA Apprentice of the Year Awards,” he said. “I would definitely advise other apprentices to go for it. Confidence is important in making the most of opportunities.” leading provider of innovative training, education and recruitment. Established in 2009, Seetec Outsource has delivered thousands of successful programmes to a range of small and large organisations nationwide and helped many people into employment. Seetec Outsource provides apprenticeships and traineeships on a range of subjects at various levels.

The combination of Thomas Low’s ‘all hands on deck’ approach, willingness to take on challenges and the support of his colleagues led to him taking his final apprenticeship exam three months earlier than scheduled, because he had progressed so quickly. He believes learning on the job was an important factor in that achievement. His biggest learning curve to date was taking on one of OIA Global’s top 25 accounts when a colleague handed in their notice. “I have always been ready to take on tasks and help people when needed, and I also realised it would be amazing for my progression,” he said. Thomas previously worked as a chef and pointed out: “Catering is a tough industry to be in; the kitchen is a very pressurised zone. That is something you have to learn to deal with very

August 2022


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