www.bifa.org


Policy & Compliance


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recently announced its proposed plan for completing delivery of the new Customs Declaration System and migrating traders to the new platform. “The schedule of the plan reflects HMRC’s requirement to


turn off CHIEF in March 2021 when the current contract ends. “This timeline requires all traders to migrate from CHIEF to


CDS by September 2020, with trade migration available to all traders from March 2020. HMRC has recognised that this timeline is challenging. “HMRC has asked software developers and CSPs to


expedite their plans to deliver and assure the necessary changes to IT systems and business processes without compromising the integrity of the border or the flow of international trade. “Software developers and CSPs will be responding to HMRC


accordingly and will update customers and partners as these discussions progress.” Read in conjunction with the ASM (UK) Ltd statement, there


is a clear indication that the IT sector has concerns regarding the programme and the suggested timeframes. Based on currently available information, BIFA has the following key points to make: • HMRC, in conjunction with the IT sector, needs to identify all the problem areas and formulate a plan to resolve them.


• All parties involved in the CDS development should agree a realistic timeframe to deliver the new system.


• Urgent consideration should be given to involve end-users to ensure that the outcomes actually work in practice.


news. Last year, in conjunction with ASM and HMRC, BIFA hosted numerous seminars around the country which attracted approximately 850 attendees.


Greatest concern Our single greatest concern is that currently the development process as far as we can ascertain does not involve representatives of the end-user. This is a dangerous oversight because it is the end-user who will determine what will actually work in practice. To give a simple example, LIC 99, which indicates a licence waiver for all types of goods, is to be replaced. The new requirement will be for a licence waiver for individual types of licences, which potentially adds complexity and makes entry completion more difficult in practice. We have recently noted an article on the ASM (UK) Ltd


website highlighting the difficulties in developing the new system, the distinct lack of clarity regarding some of the data elements and the incomplete nature of some of the development work. Additionally, we have heard from CSPs and other software developers that the proposed timelines are challenging. The IT industry is working with HMRC on a plan to expedite the delivery of CDS without compromising the integrity of the border or the flow of international trade or frontier security. Additionally, we became aware of the following: “HMRC has


September 2019


On top of all these issues, we have to factor in the increasing likelihood of a hard Brexit, and the demands that it will put on our sector


Bigger picture People have to remember that developing the new core system is only one part of a much bigger jigsaw. Customs agents will have to collect significantly greater amounts of data from their customers. Also, within individual data fields we see an increase in options. For instance, as previously indicated, LIC99 is a single licence waiver covering all goods. It is thought that this code will be replaced by multiple options dependent on the type of licence waiver being claimed. Members should be considering how they will collect and


store this additional information from clients, who often are not fully aware of the new requirements. On top of all these issues, we have to factor in the increasing


likelihood of a no-deal Brexit, and the demands that it will put on our sector. In this scenario it has to be accepted by all that the implementation of CDS will have to be delayed, whilst we are using existing systems to facilitate cargo movements and communicating with the various government agencies to allow them to perform their role to collect revenues and protect the frontier. BIFA, as the trade body representing forwarders who are end


-users of customs systems, encourages all parties involved in developing CDS to work together closely to ensure its successful development. It is essential to only release the new system within agreed timeframes, when it is a fully developed, stable and tested system. End-users must be advised of the start date of the new system and allowed sufficient time to migrate from CHIEF to CDS.


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