Planning for CDS Compliance... A Trader Perspective

BY:

Gail Leeson
Jun 14, 2022

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We are beginning to see evidence of businesses preparing for the changes CDS will bring.  Traders are starting to plan for CDS compliance, rather than waiting for impact at CDS introduction for imports in October.

Below are questions we like to see. 


The trader already has a good track record of compliance and is fully aware of their obligations to HMRC regulations. The questions asked should be those asked by all traders preparing to instruct agents who are making their import declarations from 1st October this year.


The Questions:

We understand CHIEF will no-longer be available for import declaration submission from 30th September and is to be replaced with CDS.

We currently provide all freight forwarders/agents with import clearance instructions for each shipment and the carriers complete the declarations into CHIEF on our behalf.

In preparation for the transition, can you confirm exactly what this will mean for us as an Importer of Record? We already have a Government Gateway ID.

 

  • What do we need to do in preparation?
  • Will current processes stay in place, or will they need to be changed?
  • Will we need to complete any import declarations ourselves?
  • Is there any IT integration that needs to happen?
  • Will the freight forwarders or agents require any authorisation from us to still be able act on our behalf?


The Answers:

The basic premise is that the regulations remain the same, but the method of making the declarations will change, as will the level of detail needed to be provided to the agent on your behalf.

If you already have a government gateway account, you will need to register for CDS through the gateway. Your finance department may likely have registered for CDS, as CDS has been operational for the submission of VAT periodic returns for some time.


Your customs brokers will no longer be able to use CHIEF from 1 October this year for imports. The brokers should, by now be testing their CDS software on the HMRC Trader Dress Rehearsal Service in preparation for going live. Many brokers are already live on CDS.

 

The brokers will be making the declarations for you. The difference to your business is that you will need to enable your broker to have access to your account.


If you pay duty at import, then you will need to authorise your brokers to use your deferment account number (DAN), if you use one.


If you pay duty at import and you do not have a DAN (cash import entries), then you will need to authorise your broker to allocate the duty and VAT payments against your CDS cash account. 


You will also need to take out an additional direct debit with HMRC to cover your DAN usage on CDS. The reason for this is that CDS uses a different bank account to CHIEF and the two are not interchangeable.


The link to the main CDS page is here:

Customs Declaration Service: service availability and issues - GOV.UK (www.gov.uk)


To register for CDS click this link:

Get access to the Customs Declaration Service - GOV.UK (www.gov.uk)


Once you have registered and linked your EORI to your CDS account, you can then start to authorise your agents using this link:

Get copies of your duty deferment statements - GOV.UK (www.gov.uk)


Clicking on the above link will take you to your financial page where you will see details of both your deferment and cash accounts. There is a link on the page which will allow you to start authorising agents.


In terms of clearance instructions to your brokers, you may need to add certain information. For example, if you are authorised for Inward Processing, you will need to provide details of your CDS IP authorisation and any guarantee. But, be guided by your brokers. They will know exactly what additional information they may require.


In summary:


You will need to register for CDS, but you will not be registering to make customs declarations.

You are registering so that you are visible to the CDS system as an importer (and exporter) so that you can download PVA statements, deferment statements and financial information.


You will need to authorise your brokers. This is done by adding their EORI numbers to your authorisations within your CDS Authorisation page.


The current import process doesn’t change, apart from how you pay duty to HMRC (there is a new direct debit for using a deferment account with CDS).


You will not need to complete customs declarations if you don’t want to. This can be done as it is now, by your brokers.


There shouldn't be any IT integration if you are not completing entries yourselves.


But you will need to authorise forwarders etc to use your cash and DAN accounts.


Strong & Herd CDS Resources and Training

CDS Community™ Membership

Practical and clear advice and assistance for importers , exporters , agents and those that are completing their own declarations.


CDS Clinics & Spotlight Sessions
Our clinics have been developed to give you an opportunity to ask questions and bring working examples of issues you facing surrounding the changes.


CDS Training
CDS is a major change to the way in which customs declarations are made, and this course provides detailed information on the changes.


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