Prepare now for CDS

clchristopherlong
Jul 1, 2022
3 min read

*Guidance from this post is accurate as of 30.06.2022. Guidance is gathered from HMRC sources.

The change from CHIEF to CDS is one of the biggest changes our industry will see. As of 30th September CHIEF will cease to exist for the submission of import declarations. Exports will be moved solely to CDS as of March 2023.

What can you do as an agent or importer to prepare?

1. Ensure you have your business Government Gateway details to hand (password and login ID)

2. Using your EORI and Government Gateway login details you will need to first register for CDS. This can be done here. This can take up to 5 working days.

3. If you have your own duty deferment account - you will need to set up a new direct debit instruction. Once you have successfully subscribed to CDS, locate the Customs Declaration Service Finance Dashboard on your Government Gateway Account, and follow the instructions.

4. If you, as an importer, have a Customs Broker submit declarations using your deferment account then you will need to authorise them to continue to do so. You can do this through the Customs Declaration Service Finance Dashboard.

* If, as an importer, you use Postponed VAT Accounting or have your Customs Broker pay VAT and Duty on your behalf then nothing will change.

What can you do as an agent to prepare?

1. Ensure your customs software is set up to enable access to CDS

2. Make sure you contact the CSP providers and that your access settings have been updated to allow for CDS

3. CDS and the way data is input is totally different to CHIEF. Be prepared and apply for a short course to aid your preparation.

4. Through your software provider, get access to the TDR (Trader Dress Rehearsal service) and start submitting test declarations to familiarise yourself.

5. Start submitting CDS declarations for your clients before the September 30th deadline.

Key differences between CHIEF and CDS

Below are some of the key differences we have noticed so far:

CDS uses Data Element sets instead of box numbers.
Further data must be input when declaring method of payment. In particular Guarantee numbers for deferment numbers and the EORI details of the deferment account holder (separate to the EORI noted as consignee)
Use of additional procedure codes.
More use of additional codes after the usual commodity codes.
Once a CDS declaration has been submitted with one method of payment it can no longer be amended to another.
Goods location codes are now much longer (unnecessarily so)
Documentation coding has changed too. For example - rather than 380 to note an invoice it is now N935.

Additional data required for declaration submissions on CDS

Declarations on CDS require more information than CHIEF. The procedure you import under of course determines what that data is. Some data, such as guarantee numbers, means you need to enter information into multiple data sets. This makes the process of submissions longer and perhaps pushes more of a focus to the use of templates within your software. The list that follows are just some of the additional requirements for a Home-Use declaration that we have noticed. The list should not be treated as exhaustive:

Nature of the Transaction
Incoterms shipped under
Comprehensive Guarantee number (CCG) if deferment is used
Valuation Indicator - I.E relationship between the parties and whether there is a price influence because of it.
LIC99 coding to override licenses are no longer useable. Specific coding for certain commodities is now required to give specific reasons as to why licenses may not apply.

Key points:

Everyone should register for CDS
If you have a deferment account you need to update your Direct Debit instructions.
If someone else uses your deferment account you should now authorise them to do so.
Ensure your software and CSP links are up to date.
Do your research