EU exit bulletin, 17 February 2023
In this week’s EU exit bulletin, we bring you the latest guidance updates and publications relevant to EU exit. HMRC has also provided an update on additional steps needed for representative status (i.e. if the importer/exporter has an agent for customs declarations) in the Customs Declarations Service (“CDS”).
Additional steps needed for representative status in the Customs Declarations Service (“CDS”)
As part of the CDS 3.9.0 update, a change has been implemented mandating that if representative status details are not provided (when required), then the declaration must contain an additional information code for self-representation. These are as follows:
- Where on an Import declaration (All Types and Categories) where Representative status code in DE 3/21 is not declared (left blank) then DE 2/2 must include additional information code 00400 or 00500;
- Where on an Export declaration (All Types and Categories) where Representative status code in DE 3/21 is not declared (left blank) then DE 2/2 must include additional information code 00400 or 00500;
- Where Agent is omitted from the declaration, DE 2/2 must include additional information code 00400 or 00500; and
- Where Agent is omitted from the declaration and a trader has not submitted AI codes 00400 or 00500 in DE 2/2, CDS will reject the declaration and send a DMSREJ to the submitter.
This change is designed to ensure that the above declarations are completed in line with tariff completion instructions. In order to prevent rejections upon the implementation of CDS 3.9.0, you are advised to ensure that all pre-lodged declarations comply with the above.
Please note that there remains a known error that when submitting a Final Supplementary Declaration (FSD) by self-representation, CFSP/SCDP traders are only required to complete DE 3/18 with their EORI. CDS will however currently mandate that either DE 3/21 must be completed with a representative status, or that an AI statement is entered on all declarations including the FSD.
This can be avoided by submitting an FSD under self-representation, and entering an AI statement in DE 2/2 to indicate self-representation is used ('00500-importer' for imports and '00400-exporter' for exports).
Miscellaneous updated guidance etc.
The latest guidance updates, and publications relevant to EU exit are as follows:-