The Deadline for CDS Exports in the UK

As the UK prepares for significant changes in export customs procedures, exporters face impending deadlines for migrating their export declarations from CHIEF to CDS. This article navigates through the upcoming milestones, outlining essential details for businesses to smoothly transition and be ready for CDS Export Declarations. 

Since exiting the EU, UK traders have weathered the introduction, delay and ultimate abandoning of some of the rules and regulations for importing goods into the UK. They’ve adopted the new, full controls on exports in the other direction and adapted to new processes laid out by the Northern Ireland Protocol, with further changes planned under the Windsor Framework. To add to the disruption, the way UK Customs declarations should be filed is part way through changing and traders are navigating their way through the transition from the legacy CHIEF customs declaration system to CDS. 

After multiple date changes and decision reversals, CHIEF has already been withdrawn in part with all imports now on CDS, with the final deadline due early 2024. 

HMRC are expecting that businesses will be able to transition export declarations to CDS according to the following schedule. 

• Starting from early February, export declarations for goods submitted through inventory-linked airports are due to be processed through CDS. However, if there is a possibility of goods being rerouted to an inventory-linked maritime location, exceptions may apply. 

• Beginning in early March, export declarations for goods submitted through inventory-linked maritime locations are scheduled to be processed through CDS. At this stage, all export declarants should be prepared to submit their export declarations through CDS. 

HRMC recognise that not all customers may be able to migrate by the specified deadlines. Therefore, HMRC will have a grace period of up to three months from the availability of CDS for exports to complete the transition. HMRC will reach out again with detailed timelines and instructions to confirm when businesses can initiate the migration process. 

Lack of preparedness: lessons from import declarations 

HMRC sent letters to 220,000 GB VAT registered traders and although not all of them were importers and/or exporters, and many would have used the services of a broker or forwarder. This communication was indicative of the lack of awareness, and lack of preparedness, for the impending move. 

While some traders were early adopters (and Descartes was the first company to get its customers onto the new system way back in 2018), a huge number failed to make the switch in time. With many leaving it to the very last minute and then not fully appreciating the difference between CHIEF and CDS, trying and failing to replicate the same workflows and processes. 

Unfortunately, we can expect the same this year. With exports to the EU accounting for 42% of all UK exports in 2021, according to data from the House of Commons Library – and exporters more likely than importers to be self-filers - there are likely to be many more organisations who have yet to make the switch. 

Fear of the new system as well as skepticism about HMRC and trade readiness has been understandable, the consequences of inaction are now speeding dangerously close to becoming a reality. Despite the latest updates on the export declaration deadline, the fact that the transition relating to import declarations has now happened, should be a stark reminder to businesses that CDS will happen in full. And lessons indicate that putting off the migration process is only going to complicate matters further. 

From the latest data requirements and processes, to the sheer scale of the challenge associated with new systems and software; the move from CHIEF to CDS is far from straightforward. CDS is a dramatic shift away from the previous ways of working in CHIEF, right from the way the customs declaration looks, to the new data needed and the way it interacts with port systems including GVMS. 

HMRC tried to introduce some simplifications. For example, a blanket document code to declare that no prohibitions or restrictions apply ‘’999L’’ which was temporarily introduced under CDS to speed up onboarding but has now been removed for all CDS Imports and will be removed for all CDS exports in early 2025. The customs software community that Descartes is part of, continue to make changes to ease the process. However, nothing can replace the time necessary to learn a new system and there is nothing like real user experience to help acclimatise to the changes, which is why self-learning and education is going to be vital. 

Training and education are essential as is access to test systems to ensure organisations understand the new processes and steps required. 

There is a great deal of source information available. HMRC has provided documents, such as declaration completion guidance; while systems providers such as Descartes have created online training courses, videos and other online guides as well as further technical solutions to guide users without making decisions for them. But those who have left it until now hoping for individual attention are going to find it difficult and it may be impossible to receive the attention they would prefer.

With time getting short make use of all the hints and tips, guides and clinics from software providers on how to use the software. Or engage with external training organisations who can provide more detailed CDS guidance, as whilst both software providers’ and HMRC support teams have been bolstered in anticipation of the surge of questions and enquiries, it’s inevitable that there will be delays in responding, which is why self-learning and education is going to be vital. 

It’s never been more important for declarants to understand the requirements to submit the customs declarations they need to, and be aware of changes in the codes used or information required as well as being aware of the various guidance to ensure smooth processing at the frontier.

• Apply for an Economic Operator Registration and Identification number, if you do not already have one. 
• Register for a Government Gateway account, if you do not already have one. 
• Register for the Customs Declaration Service via www.gov.uk/hmrc/cds-get-access.
• Unless you are using a Community Service Provider, authorise your chosen software solution to submit declarations on your behalf. 

• Control of the data being declared. 
• Direct visibility of the status of the declaration and confirmation when goods exit the UK supporting zero rating of VAT or reclaiming of taxes. 

• Register for a Government Gateway account, if you do not already have one. 
• Apply for an Economic Operator Registration and Identification number, if you do not already have one. 
• Register for the Customs Declaration Service via www.gov.uk/hmrc/cds-get-access.
• Ensure you have set up the correct authorisations. 
• Set up a process to ensure your broker has clear instructions and information about your consignment. 

Traders using brokers should also be prepared for the fact that the type of evidence and data they receive today will change – the old CHIEF prints just don’t exist anymore, the C88 is dead and the data is structured differently. Equally those used to the DTI-S8 for proof of exports will find that it no longer exists and instead be replaced with an Exit Confirmation message only. 

For those only submitting export declarations, the lessons learned over the last few months make it clear that the latest delay to CHIEF decommissioning is just that – and that, more importantly -  it remains vital to take action today and be CDS ready; even if you do not plan to go live immediately you can both get on the front foot and take advantage of any dual-running possibilities. 

It is merely a short matter of time now before CDS is the new normal. Until then, let’s not fool ourselves that it’ll be a smooth ride, it’s a bumpy road to progress. For more information visit https://www.descartes.com/uk-customs Or email info@descartes.com to arrange a call back from one of our team members.