TTM5.1 KEL Update

An updated KEL document  (TT5-1_KEL_181115_EB_v_2) is available, which includes the following additions since the previous version: (note Issues 35 and 37 have been resolved)

36 XML Structure

During TTM5.1, cancellation messages must include the element Declaration/Submitter in the body of the cancellation message. This should be populated with the EORI of the party making the submission. In addition, all Submitter elements (e.g. Name, Address) that were provided on the declaration must also be included in the cancellation message. This applies to both CSP and non-CSP cancellation messages.
Both of these are expected to be resolved in the next functional release into Trade Test.
The following should further be noted with regards to the Submitter:
Submitter is an optional element within the WCO Declaration Schema and therefore is not required within the declaration submission. We would advise against including this element on declaration submissions.
All CSP-initiated additional messages (goods arrival, cancellation, amendment), must include the Submitter in the API header of the message. This should be populated with the EORI of the Declarant or Agent who initiated the submission. This is an end-state requirement and will not change once this known error is resolved.

38 REJ instead of ACC

When Representation Status (DE 3/21) is included on the declaration but Agent EORI (DE 3/20) is not, the declaration is incorrectly rejected. This contradicts the requirement, where DE 3/20 should only be a mandatory element where there is more than one agent involved in the declaration. The legal requirement allows for the following 3 scenarios:

1. Importer Self-Representing (i.e. no agent or sub-agent used)
DE 2/2: AI Statement ‘00500’ – As the declarant and the consignee are the same person.
DE 3/16: Importer EORI - Identification number of the party who makes, or on whose behalf an import declaration is made.
DE 3/18: Importer EORI - Declarant

2. Declaration lodged by an Agent on behalf of Importer
DE 3/16: Importer EORI - Identification number of the party who makes, or on whose behalf an import declaration is made.
DE 3/18: Agent EORI - Declarant
DE 3/21: Representation status of the Agent in DE 3/18 (Direct-code 2 or Indirect-code 3)

3. Declaration lodged by a Sub-Agent, of the Agent, employed by Importer
DE 3/16: Importer EORI - Identification number of the party who makes, or on whose behalf an import declaration is made.
DE 3/18: Sub-Agent EORI - Declarant
DE 3/20: Agent EORI – Representative as different from Declarant
DE 3/21: Representation status of the Agent in DE 3/18 (Direct-code 2 or Indirect-code 3)

39 XML Structure

CDS incorrectly requires that for every guarantee reference declared in DE 8/3, it must be paired with a guarantee type code in DE 8/2. This contradicts the UK Trade Tariff guidance, which expects that a guarantee type code will only be declared once on a declaration and have a cardinality of 9, allowing for each of the possible Union codes to be used once on the declaration, while up to 99 instances of DE 8/3 can be declared. As a workaround, the cardinality of DE 8/2 will be treated as 99 to match that of DE 8/3.

40 REJ instead of ACC

Declaration is incorrectly rejected when certain Additional Information statement codes are entered in DE 2/2 with a valid StatementDescription as per the instructions in Appendix 4: DE 2/2: Additional Information Statement Codes of the UK Trade Tariff.  This impacts the following Additional Information statement codes: 00100, 00200, 00300, 00400, 00600, CAP10, CAP11, ECONR, ECONE, GEN45, GEN49, IRQ0B, MIB01, POD06, ROY01, ROY02, PRO07, PRO08, RPTID. This is due to incorrect reference data in the CDS core system. As a workaround, the StatementDescription should be removed from all instances of these codes.

As a workaround until the fix is in place, if the StatementDescription is removed from all instances of 00200 this Declaration it will remove the error.

i.e. declare as:
<AdditionalInformation>
<StatementCode>00200</StatementCode>
</AdditionalInformation>
Instead of:
<AdditionalInformation>
<StatementCode>00200</StatementCode>
<StatementDescription>Various-AGG</StatementDescription>
</AdditionalInformation>

41 REJ instead of ACC

Declaration is incorrectly rejected where document code N934 is omitted from the declaration where Valuation Method 2, 3, 4, 5, or 6 is entered in the declaration. Similarly, where N934 is declared the declaration will be incorrectly rejected unless Valuation Method of 2, 3, 4, 5, or 6 is entered. Document code N934 should only be mandatory if instructed to complete a form DV1 by Customs. As a workaround until a fix is released, document N934 should be included on the declaration in these scenarios.

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