HMRC released CDS version 4.4 on 23 March 2024. This latest version will have an impact on traders and declarants who import goods into Northern Ireland, as the CDS has been updated to take account of the United Kingdom Internal Market Scheme (UKIMS) authorisation.

CDS 4.4 Changes - Imports into Northern Ireland (NI)

Import Declaration Completion Instructions have been updated with information regarding the declaration of a United Kingdom Internal Market Scheme (UKIMS) authorisation.

Data Element 3/15 has been updated with information relating to the circumstances where a GB EORI can be declared in DE 3/16 and the importers name and address is required in DE 3/15.

Data Elements 3/16 and 3/39 have been updated with information relating to United Kingdom Internal Markets Scheme authorisations.

Data Element 8/1 has been updated to reflect latest changes for claiming Tariff Quotas on imports into Northern Ireland.

Data Element 2/2 has been updated to include new guidance for goods moving into Northern Ireland.

The updated completion rules can be found through the links here.

https://www.gov.uk/government/publications/cds-uk-trade-tariff-volume-3-import-declaration-completion-guide/group-3-parties

https://www.gov.uk/government/publications/cds-uk-trade-tariff-volume-3-import-declaration-completion-guide/group-8-other-data-elements-statistical-data-guarantees-and-tariff-related-data

https://www.gov.uk/guidance/additional-information-ai-statement-codes-for-data-element-22-of-the-customs-declaration-service-cds

The changes to the completion rules for Northern Ireland affect:

DE 3/15    Importer name and address

DE 3/16    Importer identification number

DE 3/39    Holder of the authorisation identification number

DE 8/1       Tariff Quota - holder of the authorisation identification number

DE 2/2       Additional Information (AI) Codes

The declaration completion rules for Northern Ireland for these Data Elements are reproduced below.

Please always refer to the Tariff Completion Rules for the most up to date version.

DE 3/15 IMPORTER NAME AND ADDRESS

 If a recognised EORI is held it must be declared in DE 3/16 (Importer Identification Number).

DE 3/15 is mandatory where: 

• A GB EORI is declared in DE 3/16 or 
• DE 3/16 is left blank 
• 
  

DE 3/15 must be left blank where an XI EORI is declared in DE 3/16.

DE 3/16 IMPORTER IDENTIFICATION NUMBER

If a recognised EORI is held it must be declared in DE 3/16 (Importer Identification Number).

DE 3/15 must be left blank where an XI EORI is declared in DE 3/16. 

DE 3/15 is mandatory where: 

• A GB EORI is declared in DE 3/16 or 
• DE 3/16 is left blank

A GB EORI is permitted in DE 3/16 where the importer is: 

• Diverting goods to free circulation and/or home use that were previously entered to a special procedure prior to the introduction of XI EORIs 
• Utilising certain transit and special procedures authorisations where a specific legal exemption under Taxation (Cross-Border Trade) Act (TCTA) 2018 or Regulation (EU) No. 952/2013 (Article 170) and/or Regulation (EU) No. 2015/2446 (Articles 5 and 6) applies 
• Entering goods using excise authorisations and approvals 
• Submitting a supplementary declaration for which the tax point is prior to the introduction of XI EORIs 
• Using indirect representation by a representative with an XI EORI who is established in Northern Ireland (NI) 
• The UKIMS authorisation holder and the authorisation has been issued against a GB EORI

In no other circumstances may a GB EORI be declared in DE 3/16 for imports to NI.

When a UKIMS authorisation is used, the following details must be declared:

• DE 2/3: document code ‘1UKI’ followed by the UKIMS authorisation decision number
• DE 3/16: GB or XI EORI associated with the UKIMS authorisation
• DE 3/39: Authorisation type ‘UKIM’ followed by the GB or XI EORI of the UKIMS authorisation holder as declared in DE 3/16

DE 3/39 HOLDER OF THE AUTHORISATION IDENTIFICATION NUMBER

   With the exception of:  

• Diverting goods to free circulation and/or home use that were previously entered to a special procedure prior to the introduction of XI EORIs
• Certain transit and special procedures authorisations where a specific legal exemption under Taxation (Cross-Border Trade) Act (TCTA) 2018 or Regulation (EU) No. 952/2013 (Article 170) and/or Regulation (EU) No. 2015/2446 (Articles 5 and 6) applies
• Excise authorisations and approvals
• Supplementary declarations for which the tax point is prior to the introduction of XI EORIs
• The UKIMS authorisation holder and the authorisation has been issued against a GB EORI

Any other authorisations and approvals declared must be NI specific and the EORI number of the Holder of the Authorisation must have an ‘XI’ country code prefix.

When a UKIMS authorisation is used, the following details must be declared:

• DE 2/3: document code ‘1UKI’ followed by the UKIMS authorisation decision number
• DE 3/16: GB or XI EORI associated with the UKIMS authorisation
• DE 3/39: Authorisation type ‘UKIM’ followed by the GB or XI EORI of the UKIMS authorisation holder as declared in DE 3/16

The GB or XI EORI declared against the UKIMS authorisation type in DE 3/39, and the UKIMS authorisation, must be valid at the tax point date of the declaration.

DE 8/1 TARIFF QUOTA - HOLDER OF THE AUTHORISATION IDENTIFICATION NUMBER

Movements from RoW into NI can claim a UK quota where there is both UK and EU quota capacity (for the relevant country of origin).

The quota can only be claimed with Additional Declaration Types A, D, Y, or Z in DE 1/2 and must include Additional Information (AI) codes NIIMP and NIQUO in DE 2/2. Any other Additional Declaration Type will result in the declaration being rejected.

DE 8/1 must be completed with the GB quota order number.

Movements from GB into NI can count towards EU-UK quotas where EU trade defence measures are in place (for example, movements of steel that would otherwise attract additional duties)

In these cases, DE 2/2 must contain NIDOM and NIQUO, and the free text field must be completed with the relevant EU quota order number and the word ‘QUOTA’.

DE 8/1 must not be completed with a quota order number for GB-NI movements or the declaration will be rejected.

DE 2/2 ADDITIONAL INFORMATION CODES

One of the following AI Codes must be entered in DE 2/2 in all instances on every goods item when goods are being declared on entry to NI.

The table below specifies which documentary controls will be applied to the goods according to which AI Code used to identify the goods status.

Note: Failure to declare either NIDOM or NIIMP on every goods item will result in the declaration being rejected.

DE 2/2 ADDITIONAL INFORMATION CODES

One of the following AI Codes may be entered, as required, in DE 2/2 on each goods item when goods are being declared on entry to NI.

The next table specifies whether the goods will be considered to be ‘At Risk’ or ‘Not At Risk’ of entering the EU according to which AI Code used to identify the goods status.

Failure to declare either NIREM or NIQUO against a goods item will subject the goods item to a CDS calculation to determine the correct duties to pay (if any). This will result in the goods being considered ‘At Risk’ where the applicable duty calculated according to the NI Tariff (‘applicable EU rate of duty’) is greater than the applicable duty calculated according to the GB Tariff (‘applicable UK rate of duty’).

Determining the ‘At Risk’ or ‘Not At Risk’ status

Goods are considered to be ‘At Risk’ where there may be duty to be charged according to the Northern Ireland Online Tariff. CDS will check both the GB and NI Tariffs to determine the correct duty rate.

AI Code NIREM can be used to indicate that goods are ‘Not At Risk’ when a UK Internal Market Scheme (UKIMS) authorisation is held and declared in DE 2/3.

When a UKIMS authorisation is used, the following details must be declared:

• DE 2/3: document code ‘1UKI’ followed by the UKIMS authorisation decision number
• DE 3/16: GB or XI EORI associated with the UKIMS authorisation
• DE 3/39: Authorisation type ‘UKIM’ followed by the GB or XI EORI of the UKIMS authorisation holder as declared in DE 3/16

If one of NIPRO, NIQUO, or NIREM is not declared in DE 2/2, CDS will determine ‘At Risk’/’Not At Risk’ status by checking both the GB and NI Tariffs to determine the correct duty rate.

In this calculation, goods will be considered ‘Not At Risk’ where:

• The applicable EU rate of duty is zero, in the case of movements from GB to NI, or
• The applicable UK rate of duty is equal to or more than the applicable EU duty, in the case of movements into NI from a country outside both the UK and the EU.

NIREM cannot be used to declare goods ‘Not At Risk’ if the goods will be subject to processing in NI, unless the goods meet the additional processing requirements covered in the notices section. NIPRO should be declared for goods subject to processing in NI that do not meet the additional criteria.

Duty rates applied to the goods

The table below specifies which duty calculation will be applied to the goods according to the AI Codes entered in DE 2/2 to identify the UK domestic and ‘At Risk’ status. This does not remove the need to declare either NIDOM or NIIMP to establish the control measures to be applied to the goods item.

Any combination of AI Codes NIDOM, NIIIMP, NIPRO, NIQUO, and NIREM not listed in the table above will result in the declaration being rejected.

AI Code NIAID will not affect the ‘At Risk’/’Not At Risk’ status or duty calculation. It is only used to determine a claim to a customs duty waiver (subsidy), where applicable. NIAID can be combined with NIREM if you are declaring goods ‘not at risk’ under UKIMS that are moving into Northern Ireland from a country outside of both the UK and the EU (rest of world), where you are not sure that the difference between the applicable EU rate of duty and UK rate of duty is not greater than 3 percentage points at the time of the goods movement.

Claiming customs duty waivers (subsidies)

To make a claim to subsidy, AI Code NIAID must be declared in DE 2/2, with either AI Code NIDOM or NIIMP. The claim to subsidy will be assessed based on the ‘At Risk’/’Not At Risk’ treatment as specified in the table below:

For details of how the ‘At Risk’/’Not At Risk’ status is determined, please refer to Determining the ‘At Risk’ or ‘Not At Risk’ status.

Notice Declaring goods you bring into NI ‘Not At Risk’ of moving to the EU

Authorisation By Customs Declaration (ABD) Changes

Two new Additional Information (AI) codes are being introduced which distinguish between goods being placed into a Special Procedure using ABD and those being removed from Special Procedure which they entered using ABD.

The new AI codes which can be declared in DE 2/2 after the release are

• ABDIN – this code is used to indicate that the request for ABD applies to the requested procedure code.
• AI code 00100 must be declared in addition to ABDIN
• ABDOU – this code is used to indicate that the goods are being removed from a procedure which they entered using ABD.
• AI code 00100 must be declared in addition to ABDOU

Once these changes are implemented, the ABD workaround will no longer be required in most instances.

In the case of Authorised-Use/End-Use, the current workaround must still be applied in addition to use of ABDIN/ABDOU.

Tariff functionality will reject a declaration using an Authorised-Use/End-Use commodity code if the document code N990 for a full authorisation is not declared.

Changes by Special Procedure

Inward Processing

• If ABD applies to the requested procedure code 51, then DE 2/2 must include AI codes ABDIN and 00100
• If ABD applies to the previous procedure 51, then DE 2/2 must include AI codes ABDOU and 00100
• DE 2/3 Document code C601 will not be required for the IP authorisation covered by the AI code ABDIN or ABDOU
• DE 3/39 Authorisation Type code IPO will not be required for the IP authorisation covered by the AI code ABDIN or ABDOU
• DE 2/3 Document code C505, DE 3/39 code CGU and the associated codes in DE 8/2 Guarantee Type and Guarantee Reference will not be required for ABD purposes unless providing a security deposit from a deferment account. They may still be required for other purposes.
• An approved security Method of Payment code must be provided in DE 4/8 and any associated codes provided, including in DE 8/2 and DE 8/3

Temporary Admission

• If ABD applies to the requested procedure code 53, then DE 2/2 must include AI codes ABDIN and 00100
• If ABD applies to the previous procedure code 53, then DE 2/2 must include AI codes ABDOU and 00100
• DE 2/3 Document code C516 will not be required for the TA authorisation covered by the AI code ABDIN or ABDOU
• DE 3/39 Authorisation Type code TEA will not be required for the TA authorisation covered by the AI code ABDIN or ABDOU
• DE 2/3 Document code C505, DE 3/39 code CGU and the associated codes in DE 8/2 Guarantee Type and Guarantee Reference will not be required for ABD purposes unless providing a security deposit from a deferment account. They may still be required for other purposes.
• If security is required, then an approved security Method of Payment code must be provided in DE 4/8 and any associated codes provided, including in DE 8/2 and DE 8/3

Authorised-Use (known as End-Use in Northern Ireland)

• If ABD applies to the requested procedure code 44, then DE 2/2 must include AI codes ABDIN and 00100
• If ABD applies to the previous procedure code 44, then DE 2/2 must include AI codes ABDOU and 00100
• DE 2/3 Document code N990 will still be required with document status code XW, in addition to ABDIN or ABDOU
• DE 3/39 Authorisation Type code EUS will still be required with AI code ABDIN or ABDOU and should be completed with the EORI of the party which is requesting ABD or requested ABD at the time the goods originally entered Authorised-Use.
• DE 2/3 Document code C505, DE 3/39 code CGU and the associated codes in DE 8/2 Guarantee Type and Guarantee Reference will still be required for ABD purposes even if a security deposit is not being provided from a deferment account. They may still be required for other purposes.
• If deferment is not being used to provide security for ABD, then an approved security Method of Payment code must be provided in DE 4/8 and any associated codes provided, including in DE 8/2 and DE 8/3

Outward Processing using code 21 as the requested or previous procedure code

• If ABD applies to the requested procedure code 21, then DE 2/2 must include AI codes ABDIN and 00100
• If ABD applies to the previous procedure code 21, then DE 2/2 must include AI codes ABDOU and 00100
• DE 2/3 Document code C019 will not be required for the OP authorisation covered by the AI code ABDIN or ABDOU
• DE 3/39 Authorisation Type code OPO will not be required for the OP authorisation covered by the AI code ABDIN or ABDOU



Outward Processing using code 22 as the requested or previous procedure code

• If ABD applies to the requested procedure code 22, then DE 2/2 must include AI codes ABDIN and 00100
• If ABD applies to the previous procedure code 22, then DE 2/2 must include AI codes ABDOU and 00100
• DE 2/3 Document code C019 will not be required for the OP authorisation covered by the AI code ABDIN or ABDOU
• DE 3/39 Authorisation Type code OPO will not be required for the OP authorisation covered by the AI code ABDIN or ABDOU
• For VAT only OP, it will not be necessary to declare either the full authorisation details or the ABD details.
• Any export declaration with requested procedure code 22 which does not include DE 2/3 Document Code C019 (full OP authorisation held), must have either DE 2/2 Additional Information code OPVAT (VAT only OP) or DE 2/2 Additional Information codes ABDIN & 00100 (OP using ABD).
• Any import declaration with previous procedure code 22 which does not include DE 2/3 Document Code C019 (full OP authorisation held), must have either DE 1/11 Additional Procedure Code B06 (re-import after VAT only OP) or DE 2/2 Additional Information codes ABDOU & 00100 (discharge of OP using ABD).