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Imminent Changes To Customs Declarations Regulations You Must Be Aware Of And Act Upon Without Delay 

The C.H.I.E.F. (Customs Harmonized Import Export Freight) system which is currently being used to declare imports/exports is being replaced by
the new Customs Declaration Service (C.D.S.). This change will greatly affect how in future we complete customs declarations. The main differences are:

1 – We, Aerona (Air & Sea) Customs Clearing Agents Ltd will, from the end of September, be obliged to input additional information about the consignment being imported or exported. On imports we will need to input 86 data elements and on exports 74 data elements.

2 – From 30th September 2022 there will be a requirement to confirm relationships between the seller/exporter to the consignee/importer.  This change is to identify if there is any relationship between both, such as a family member selling goods to another family member; or the overseas arm of a business selling goods to a UK part of its business etc. This is because Customs believe that ‘relationships’ such as these affect the price at which goods are sold.

3 – Commercial invoices and packing lists MUST IN FUTURE show the incoterms – FOB/CIF/EXW etc - that the goods are being sold under. They must also be in the correct format with FULL NAME AND ADDRESS of the seller/exporter and must also include the full EMAIL ADDRESSES AND TELEPHONE NUMBERS.

4 – Our current clients and all future importers will need to register with a Government Gateway account and will need to authorise us - Aerona (Air & Sea) Customs Clearing Agents Ltd - of any use of their deferment accounts, customs guarantees etc.

5 – Whereas we now take into account past activities when you import the same goods, in future we will no longer be allowed to do so.  From 30th September under the new system we will be legally required to include a letter of direct representation and CLEAR customs clearing instructions on ALL IMPORTS, no matter if these are the same as in the past. We have created a form for this, and this will need to be completed on EACH and EVERY occasion.  

6 – We will also need to be more diligent regarding HS codes we are given.  At the moment the importer/consignee is legally liable for HS codes, but under the new system we will also have a duty to ensure the correct code is being used. This is especially important when goods can be VAT rated at 20% or Zero rated, or if goods incur DUTY, EXCISE DUTY, ANTI DUMPING DUTY etc.

Inevitably, these new regulations will mean importers in future will have to become more involved in their import declarations by having to fill in our forms with clear and precise written instructions. Because we will be committed to attach these instructions to all Customs entries, without written instructions we will be unable to complete entries.

All forms etc we receive will have to be in PDF format, which means there can be no photographs or JPEG versions of documents.

Our staff members have undergone training in the new C.D.S. system but nevertheless we still anticipate challenges during the transition period as everyone becomes more familiar with the changes. This is especially relevant regarding the additional information we will have to input.

WHAT YOU NEED TO DO AS QUICKLY AS POSSIBLE

To assist in the changeover, we recommend you undertake the following measures:

1 – You familiarise yourself with the new regulations by visiting this site https://www.gov.uk/government/collections/customs-declaration-service and study its contents.

2 – You start now by insisting your sellers/exporters make sure all commercial invoices and packing lists indicate the terms of the sale, and that they also include the full name and address of both the seller and the consignee. 

3 – You prepare yourself for the completion of our forms by familiarising yourself with them and storing them on your computers.  Then all you need do is simply amend them each time you import or export goods.

4 – It is important to ensure you always have the correct HS codes or have in place an Advanced Tariff Ruling that is available on this website
https://www.gov.uk/guidance/apply-for-an-advance-tariff-ruling.

5 – Make sure you are aware of the correct C.P.C. (Customs Procedure Code) especially with regards to goods coming in or going out where processes are taking place and goods are then returned back to the country of origin. This will enable INWARD PROCESSING RELIEF and OUTWARD PROCESSING RELIEF to be actioned correctly. Most imports will fall under the code 4000000 as this is home use, but if goods are going to be subject to ‘different process’ and are to be temporary imports or exports then there will be different codes, as there are now.
It is envisaged Customs will become more diligent on HS codes, CPC codes etc. 

This is just a snapshot of some of the changes that will come into effect from 30th September. We therefore suggest that you investigate how the change to C.D.S will affect you and the actions you need to take in order to become compliant.  If you require further information please do not hesitate to contact us and we will do everything we can to assist you.