www.truckandtrack.com Spring 2023 Truck and Track 19 DESCARTES™ Fear of the new system, as well as scepticism about HMRC and trade readiness, has been understandable – as too the expectation of further delays based on precedent (let’s face it, it isn’t unreasonable to make comparisons here with the Boy Who Cried Wolf) – yet, the consequences of inaction are now speeding dangerously close to becoming a reality. Despite the latest delay from March ’23 to November ’23 for 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. HMRC has tried to introduce some simplifications. For example, a blanket document code to declare that no prohibitions or restrictions apply “999L” has been temporarily introduced under CDS to speed up onboarding. And, like other software houses, Descartes continues 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 drive improvement. Training and education are essential as is access to test systems to ensure organisations understand the new processes and steps required. Last summer, Descartes saw an exponential increase in companies engaging to be ready for CDS imports, showing a hunger for education and training that can’t be left to the last minute. Reality bites 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 just a few months to go, group sessions from software providers on how to use the software, or external training organisations who can provide more generic CDS guidance, are now the most likely to help. And while both software providers’ and HMRC’s 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. Time critical 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. Unless you choose to use a broker to submit your declarations you will need to: ■ 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. Benefits of doing your own CDS declarations: ■ 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. If you choose to use a broker rather than submit your own declarations, there are still five steps that should be taken: ■ 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; ■ Choose which payment method to use and ensure you have set up the correct Direct Debits or authorisations; ■ Set up a process to ensure your broker has clear instructions and information about your consignment. For example - the incoterms, awareness for all values, the location information, and nature of transaction information. 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. Conclusion 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-declarations-changes Or email info@descartes.com Descartes is the global leader in providing on-demand software-as-a-service solutions focused on improving the productivity, performance, and security of logistics-intensive businesses. Descartes will be attending Multimodal 2023 at the NEC Birmingham between 13th and 15th June. Come along and talk to one of our experts on stand No. 4058. www.descartes.com
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