With the deadline fast approaching for export declarations moving to the Customs Declaration Service HMRC are highlighting a worrying trend at the border, with misuse of valid documents leaving innocent exporters potentially non-compliant and exposed to penalties.
In their latest Customs Declaration Service (CDS) update HMRC remind traders that all export declarations must move from their legacy Customs Handling of Import and Export Freight (CHIEF) system to CDS by Saturday 30th March 2024.
We are continuing to work with our customers, setting them up on CDS for all export routes and the different types of export declaration submitted at the UK border, including Transit (TAD) and the Goods Vehicle Movement Service (GVMS).
It is these latter two that HMRC focused on, in highlighting Goods Movement Reference (GMR) errors by hauliers that are leading to issues at the UK and EU border.
Consistent misuse of valid export CDS documents where the transit document is being used for the convenience of the haulier means that shipments are not arrived in the correct manner.
Exporters have a legal obligation to pre-lodge declarations if they are moving their goods through a location using GVMS and pass evidence of this for a haulier to complete a GMR.
Hauliers have a legal obligation to carry evidence that pre-lodged customs declarations or reference numbers for Simplified Customs Procedure authorised traders are in place for all the goods they are moving.
This is met by hauliers completing a GMR which must include a declaration reference for each consignment as proof that a pre-lodged declaration has been made.
Carriers require a valid GMR to be presented at the port of departure before allowing the vehicle or trailer to board.
HMRC’s issue is that hauliers are inappropriately using TAD MRN (transit document) as suitable evidence for the export MRN reference, irrespective of what else is loaded to the trailer, which is not the case when a DUCR has been issued..
The correct use of DUCR or MUCR being advised to customs allows the authorities to “arrive” the customs entry, which means that there is a permanent record of the despatch of the goods so the VAT liability for the shipment is discharged and the zero rated document raised by the shipper becomes validated.
Incorrect GVMS entries by hauliers leads to missing data on exporters MSS reports, missing critical data in terms of managed Customs facilities such as stock records for CFSP locations, which leads to extra admin and inventory shortages, both serious matters.
These export process are incredibly complex and should be of no concern to exporters, but unfortunately many (non-Metro customers) are being caught out by the carriers’ non-compliance.
We work closely with our road transport partners to ensure they have the correct documentation and submit the correct information to GVMS through CDS.
Our CuDoS customs platform automatically monitors the status of export declarations and will flag potential non-compliance issues.
If you have any concerns or questions, regarding CDS or export compliance please EMAIL Andy Fitchett, Brokerage Manager.