This article was published before we became the Chartered Institute of Export & International Trade on 10 July 2024, and this is reflected in references to our old brand and name. For more information about us becoming Chartered, visit our dedicated webpage on the change here.


In our regular feature on the world of customs, we cover common errors with both Customs Declaration Service (CDS) submissions and sanitary and phytosanitary (SPS) processes following the second phase of the Border Target Operating Model’s (BTOM) implementation. There’s also an update on testing for the New Computerised Transit System (NCTS5).

CDS export licence errors

HMRC has issued guidance to traders following frequent issues with CDS errors on declarations involving an export licence.

The department notes that a mismatch between information in an export licence and the data submitted in an export declaration will create issues with “data flows between CDS and the Department of Business and Trade's (DBT) electronic licensing systems (SPIRE/LITE)”.

Most of the issues centre on data element (DE) 2/3, which HMRC cautions not to fill with “document status code EE (Electronic Exhausted) or ES (Electronic Surrendered)”, which will exhaust or surrender a licence. Instead, “EP (Electronic Partial)” should be used.

If EE or ES have been incorrectly used, traders should inform HMRC via this link.

DE 2/3

Another common problem with the data element is traders entering zero for licence quantity.

“Quantity for the licence must not be zero, unless you want to delete an existing reservation.

“If no reservation exists, an issue will occur and the declaration cannot be amended or deleted and you will need to submit a new declaration.”

Additionally, traders must ensure that data entered in the declaration matched information in the export licence. When completing an export declaration, if a measurement unit is included for the quantity, this must be the same as the licence.

If a document status code applies, the same code must be used for all goods in the declaration.

What to do?

If one of the above errors has been made, the declaration will exist in a limbo state, neither rejected nor able to progress.

HMRC advises traders to invalidate a declaration and resubmit – it’s not possible to amend an error containing any of these errors.

The same Declaration Unique Consignment Reference (DUCR) should be used. However, if the DUCR has been consolidated into a Master Unique Consignment Reference (MUCR), you may need to manually dissociate the DUCR from the MUCR once the declaration is invalidated.

If the DUCR/MUCR has already arrived at its destination, the carrier may need to ‘re-arrive’ it in order to trigger P2P status.

BTOM updates

The Department for Environment, Food and Rural Affairs (Defra) has issued guidance in the wake of the implementation of the second phase of BTOM.

Traders moving animal products from the EU by transiting through Great Britain - known as ‘landbridge’ movements - are reminded that when completing a common health entry document (CHED), the exit and entry border control posts (BCPs) are different and that the exit date is after the entry date.

Defra also said that traders must notify Port Health Authorities (PHAs) when goods transiting Great Britain from the EU have left Great Britain. For germinal products, animal by-products (ABP), and products of animal origin (POAO), this means emailing the PHA for your exit BCP.

For goods leaving the Port of Dover or via Eurotunnel, this means contacting Ashford PHA via Sevington BCP. For those entering Ireland via a British port with no BCP, traders should inform their entry BCP.

From eggs to EHCs

Traders are reminded that hatching eggs are in the high-risk category and therefore subject to inspections at the border.

They can be imported via any live animal or animal product BCP and should be notified on IPAFFS at least one working day before their arrival.

If eggs are entering through a live animal BCP, CHED-A should be used. If they’re entering through an animal product BCP then a CHED-P should be used.

There are also housekeeping notes Export Health Certificates (EHCs), which must accompany all medium- and high-risk goods.

EHCs must be submitted in English as well as in the original language. In TRACES, the PDF preview settings enable an English-language version to be created under ‘advanced print settings’.

Traders are also reminded that digital signatures are required for online submissions, while the signature and stamp of the certifying officer is needed on paper documents. Any attestations in the EHC must be completed or deleted or omitted correctly; they cannot be left blank. For paper documents, deletions must be initialled and stamped.

NCTS5 environment online

Following disruption to the service due to technical issues, HMRC announced that the NCTS trader test environment became functional again from 14 June.

The system allows traders to create declarations using a UI that simulates the new NCTS system, which they’re strongly advised to practice on ahead of NCTS5 going live on 1 July.

All Common Transit Convention (CTC) member countries must upgrade to NCTS5. Some functionality will only become available once all member countries have upgraded.

All traders submitting transit movements, whether through commercial software or the government gateway portal, will need to subscribe to NCTS.