The go-live date for the CDS project is set at the end of July, at yesterday's ACITA
meeting (The Automated Customs and International Trade Association) we were informed that export declarations are extremely unlikely to be ready for the initial go-live. A source at HMRC stated 'export is fighting a losing battle', referencing a push to ensure integration with port systems (CSP - community systems providers) would be completed in time. We were also informed that the new Tariff document
, to accompany the new service, would not be available until the autumn.
Looking at the whole project though, CDS is progressing well, HMRC have been issuing iterative documentation and test packs, enabling companies to develop part of the solution and test using HMRC's developer environment endpoints. There are six trade tests scheduled, the first and second are complete and the third is currently open. At i2i we are currently working on the third trade test and feel we are making good progress.
The timelime for the CDS project was always aggressive, perhaps with Brexit in mind and a worry that the CHIEF system is struggling with the current amount of declarations processed. With a new transition deal now in place, which will keep us in the Single Market until the 31st of December 2020, any delays in the CDS export declaration pipeline or publishing of the tariff manual, should not have a significant effect on UK importers and exporters, as the period of duel running between the CHIEF and CDS systems would no doubt be extended also.
It should be noted though that if the Transition deal is not ratified by all EU27 states, due in October, then 'more than significant' pressure will be back on the CDS project, especially the export route.
Within the next few days all companies who interact with HMRC, some 200,000 UK entities, should receive a letter from HMRC giving a top-level explanation of the CDS project and providing a means to stay updated. If you have any questions or concerns about the CDS project and how it might affect you, please contact us, leave a comment or post in the Brexit Toolkit Forums.
If you didn't receive your email from HMRC, you can read the full text below, which confirms the delay:
As you will be aware, HMRC is phasing in the new Customs Declaration Service (CDS) from August this year to replace the current CHIEF system. CHIEF is one of the world’s largest and most sophisticated electronic services for managing customs declarations. However, it is nearly 25 years old and cannot be easily changed to meet new requirements under the Union Customs Code (UCC).
We have been working in close consultation with you on the development of CDS and can now share more detail on the delivery and migration plan.
We are maintaining our high level delivery and migration strategy in the order of:
- Import Supplementary declarations
- Import Frontier declarations (including Inventory Linking)
- Exports (including Inventory Linking)
We will be working to a timeline of IT ‘releases’, with each release delivering certain CDS functionality.
We will start with Release 1 on the 12th August. Supplementary declaration functionality will be our priority, but we will also be delivering a small amount of frontier declaration functionality.
Traders selected for Release 1 will be able to submit declarations for the following customs procedures:
• Supplementary declaration into Free Circulation
• Supplementary declaration out of Customs Warehousing into Free Circulation
• Simplified declaration into Free Circulation
• Simplified declaration into Customs Warehousing
• Simplified declaration out of Customs Warehousing and into Excise Warehousing
• Simplified declaration out of Customs Warehousing and into Free Circulation with Onward Supply Relief
• Pre-lodged Simplified Declaration into Free Circulation
Release 1 will not deliver full capability for the procedures above, however traders will be selected carefully to ensure these constraints do not affect their usual business behaviour. Constraints in
Release 1 include:
• Any liabilities will be paid via a single deferment account on a declaration and no securities will be required
• All goods will be declared in GBP (British Pound)
• Only warehousing in the UK
• Only licensable commodities requiring Department for International Trade (DIT) and Rural Payments Agency (RPA) licences can be declared.
Release 2 will go live in November, which will cover the remaining import functionality including Quota and multiple deferment accounts on a declaration.
The third release will cover exports. Feedback from our meetings with you and the wider trade has been to consider a phased implementation for the delivery of exports, including inventory linking, to minimise the impact on customers’ supply services. We are reviewing this option and will continue to consult with you on how we deliver this.
For the migration of customers, we are working to a timeline of ‘tranches’. A tranche is the group of traders that will be migrating certain declarations over to CDS, based on available functionality.
Migration will start on the 14th August, when we will initially migrate a small number of low volume declarants as agreed with their software developer. We are calling this small group Tranche 0.
Following this live proving, we will begin the movement of high volume declarants, in line with our migration strategy. The priority traders for Tranche 1 migration will be those who are CFSP authorised and submit supplementary declarations for goods being released into free circulation or into customs / excise warehousing.
We will start migration of Tranches 2 and 3 from November, to align with Release 2. Tranche 2 will be another small group, followed by the remaining eligible traders who will form Tranche 3. The subsequent tranches will align with the release of exports functionality and we will determine the timing and definition of these in line with our developing release strategy.
Information covering trade test 4 scope, along with the scope of subsequent trade tests will be issued shortly. There is no change to the timelines for technical documentation to be issued.
We are now matching the functionality of the first release against current CHIEF users. This will help us to identify ‘early adoption’ candidates and confirm the Tranche 0 and Tranche 1 declarants, many of whom we have already been working with.
We will be providing more information on the releases and tranches as the implementation plan develops further. If you have any questions in the meantime, please email email@example.com.
We will be issuing this information to a wider group of traders and associations at the end of this week. If you have any comments on the content, please let us know before midday on Thursday (5 April).
The Customs Declaration Service (CDS) programme