ACITA Midland Meeting Minutes

17th April 2018

Venue: Triumph Motorcycles, Hinckley

John Griffiths, HMRC – ITDLO – an update on CDS and Brexit

EU Exit and Customs (click title to download the presentation)

Lancaster House Speech - the UK will pursue a new strategic partnership with the EU, including an ambitious and comprehensive Free Trade Agreement and new customs agreement. This will seek to ensure that cross-border trade with the EU is as friction-less and seamless as possible.”

A White Paper was released by the Government called ‘ The UK’s exit from and new partnership with the EU. Point 8 stating ‘We will forge a new strategic partnership with the EU, including a wide reaching, bold and ambitious free trade agreement, and will seek a mutually beneficial new customs agreement with the EU.’

15th August saw ‘A Future Partnership’ Paper being published

The government has a vision of a highly streamlined arrangement which will simplify requirements. New technology will be implemented – CDS was mentioned. There is however no other new regarding any other new technology.

Comments from traders regarding the ‘New Customs Partnership’  - One potential approach would involve the UK mirroring the EU’s requirements for imports from the rest of the world where their final destination is the EU – Most traders felt it was a nice idea but seemed very naive of Customs to think that removing the need for a UK-EU border was going to be friction-less. The practicality of it is very limited given timescales involved.

The Interim Period (Transitional period) will run from 01/04/2019 – 31/12/2020 although there is still little to go on as to what this actually means.

The implementation of BREXIT will mean that HMRC will legislate for a new customs regime to be in place by March 2019.

Traders pointed out that they feel like they don’t know what they are planning for.

The Governments Contingency scenario is quoted as follows:

  • ‘While the government hopes for and expects a mutually beneficial outcome to negotiations, it is prudent for both government and businesses to plan for a contingency scenario, where the UK leaves the EU without a negotiated outcome on customs arrangements.’
  • In this scenario, the Bill will make provision for the UK to establish a standalone customs regime from day one, including setting tariffs and quotas, and establishing a goods classification system in line with the government’s WTO obligations.’
  • ‘The government is committed to developing solutions to the issues that implementing a new customs regime would raise, particularly in the areas, such as ro-ro ports and the Northern Ireland-Ireland land border, that are likely to be the most complex. The government is seeking the views of businesses and other stakeholders on these solutions.’

CDS Update (click title to download the presentation)

Draft Volume 3 – Imports CDS tariff publication was in March. Consists of:

  • General introductory text
  • Data element completion rules (including guidance tables detailing the relevant category completion requirements)
  • Procedure code guidance
  • Appendices containing reference data.

Draft Volume 3 – Exports due autumn 2018 and will be parallel to imports

Rewrite of Volume 1 but small changes expected such as changing CHIEF to CDS

Key Changes to Declarations – see slide 4, 5 and 6 on CDS presentation

CDS help and supports available:

Nicola Haynes, KPMG –  UCC Transitional Period

Letters are being sent out to traders who have old approvals explaining what they need to do.

Customs Comprehensive Guarantees are now required when traders reapply

Traders stated they had submitted their re-approval and received a response in good time.

Traders expressed a concern that various levels of AEO audits have taken place recently with some taking only a few hours and others taking months.

Businesses were reminded that if AEO approved that they must inform HMRC of any significant changes to the business.

Companies reported the CCG’s were causing financial impacts to businesses with one trader even going so far as to state they wouldn’t bother with a Customs Warehouse any more as the costs were just too high.


Customs Information Papers released since last meeting

  • The Customs Comprehensive Guarantee Questionnaire (CIP23) Published 12/10/2017
  • Due Diligence when making customs declarations (CIP27) Published 01/12/2017
  • Reassessment of Customs open-ended authorisations (CIP32) Published 03/01/2018
  • End Use Procedure change (CIP33) Published 10/01/2018

Trader Questions

  • One trader asked a question concerning goods being sent to Norway for repair on behalf of a customer. When the goods were returned, the supplier only invoiced for the repair plus freight charges and they would not include a value for the goods for customs purposes. The question was - should the supplier have included a value for the goods?

The general response to this question was that the goods should have been declared to include the value of the goods.

Next Meeting Date

The meeting originally set for 27th June 2018 has been cancelled, the new date is 12th September 2018 at Triumph Motorcycles Ltd. Hinckley.

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