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.

customs checks

The Institute of Export & International Trade (IOE&IT) sits on HMRC’s Joint Customs Consultative Committee (JCCC) and, acting as the key interlocutor between government and industry on international trade, passes on updates from the committee to its members.

Below are a few important recent announcements regarding technical difficulties on the Customs Declaration Service (CDS) and upcoming strike action.

CDS – ‘technical fix’ being applied

JCCC wrote to stakeholders with two updates at the end of last week regarding issues that are affecting the submission of import declarations on CDS.

A “technical fix” to the issue passed “its initial testing phase” on Friday and JCCC said it was confident that implementing this fix will “not cause further disruption”.

The fix will be applied to “high usage commodity codes” first.

JCCC sends its apologies to CDS users for disruptions caused by the declarations' issues.

CDS business continuity plan

HMRC put into place a business continuity plan last week under which goods are being released manually through the National Clearance Hub, without a Movement Reference Number (MRN) where appropriate.

Firms lodging full frontier declarations with MRNs are being told that non-controlled goods are being allowed to move past the frontier, but under customs control until the importer is notified of clearance.

This plan is designed to “ease the volume of requests coming into the National Clearance Hub”, allowing officials to “focus on requests which cannot otherwise be released”.

Under the plan:

  • Hauliers moving goods through GVMS locations can provide a ‘declaration by conduct’ GMR type, which will be validated by carriers as normal
  • Carriers and agents are authorised to use contingency manifest codes at maritime temporary storage ports, where possible
  • Agents and operators at air freight temporary storage locations are being permitted to release non-controlled goods on the location’s inventory system, if possible

Traders are being advised to contact the CDS helpdesk in the first instance if unable to use the above options, providing their unique consignment number (UCN) and MRN if available.

A C130 form will not be required where goods are stuck at an inventory linked Temporary Storage location. 

Controlled goods

JCCC has said that controlled goods will be instructed to remain at the port or at an inland border facility, but that priority goods may be manually released by HMRC.

“Border Force may continue to place holds on consignments of interest or controlled goods as per the usual process,” it wrote.

Don’t repeat submit declarations

JCCC has advised firms not to resubmit declarations if it appears as though their already-submitted declarations have not been processed.

“We are working through all affected declarations and any duplicate entries could cause further delays and may result in payment being taken twice,” the committee’s secretariat writes.

Deferred duties and import VAT

For firms submitting supplementary declarations on imports, that are affected by these technical issues, JCCC has advised that deferred customs duty and import VAT will be collected from their Duty Deferment Accounts on 17 April.

Firms are reminded to ensure they have sufficient funds in their bank account to ensure these charges are paid.

JCCC has also written to industry about the planned industrial action of 100,000 civil service members of the Public and Commercial Services (PCS) union on Wednesday (15 March), which will include some HMRC and Border Force staff.

It said that the strikes could “impact the movement of goods through UK ports, airports and inland border facilities” on Wednesday and the morning of Thursday. It also said goods moving through UK border controls in Calais, Dunkirk and Coquelles in Northern France could be affected.

It has advised businesses to move goods outside this period if possible, or to expect disruption and delays at ports and inland border facilities if postponing the goods movement is not possible.

Merchandise in baggage

JCCC also warned that firms moving merchandise in baggage or more than £10,000 in cash need to make a declaration. It recommended to do this using an online declaration form if moving goods valued under £1,500 or 1,000kg in weight.

If your members are planning to carry merchandise in baggage or more than £10,000 in cash and need to make a declaration