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Policy & Compliance


BIFAlink


New data elements and how they work


The transition to the EU CDM data elements will certainly require some time for Members to adjust, but in itself it should not cause too many issues


In the previous editions of BIFAlink we have tried to draw Members’ attention to the differences between the CHIEF and CDS tariffs as this is one of the most significant changes CDS users will notice when transitioning to the new system. One of the main differences between the two


documents is the fact that the CDS tariff moves away from the 54-box SAD format to the new data model using data elements. The CDS declaration model will be built on the


EU Customs Data Model (EU CDM), which in practice forms the basis for every customs declaration and notification. The EU CDM legally defines how to complete a declaration and it also defines the specifications for the IT systems and consequently requires significant updates to existing software or new types of software for both Customs and Traders. The EU CDM is not limited to import and


export declarations but it affects all EU customs systems including NCTS, ICS, AES etc. There are eight main groups of data elements


that define all the data required to be declared. These groups are: Group 1 – Message information (including


April 2020 procedure type),


Group 2 – References of messages, documents, certificates, authorisations,


Group 3 – Parties, Group 4 – Valuation information/taxes, Group 5 – Dates/times/periods/places/ countries/regions,


Group 6 – Goods identification, Group 7 – Transport information (modes, means and equipment),


Group 8 – Other data elements (statistical data, guarantees, tariff related data).


Data element groups These data element (D/E) groups do not align to a declaration in the same way as the old legislation (header then items). Looking at how many D/E there are, it quickly becomes clear that the new model requires more data than the current SAD declaration. How different, in reality, are D/Es compared with SAD boxes? The simple answer is, not that different. In fact,


most D/Es are directly correlated with SAD boxes and the EU CDM/SAD correlation table makes it very clear that in most cases individual SAD


boxes are translated into more than one D/E. To use an example, Box 1 Declaration


becomes D/E 1/1 Declaration Type and 1/2 Additional Declaration Type. This looks like an additional piece of information is added to a declaration, but in the current declaration model Box 1 is in fact split into Box 1(1) and Box 1(2). A more striking example is Box 14


Declarant/Representative, which under the EU CDM is broken down into D/E: 3/17 – Declarant, 3/18 – Declarant identification no, 3/19 – Representative, 3/20 – Representative identification no, 30/21 – Representative status code. Again, today all the information specified


under D/Es 3/17 to 3/21 is provided under single Box 14, so the EU CDM D/E are more precisely defined.


CDS tariff The CDS tariff will use data elements as the first reference for the information required on a declaration but it will link to the SAD boxes to help users understand the context of the requirement. The Secretariat understands that at least some


software providers will try to keep the layout of the declaration and the interface as close to their current products as possible with correlation tables or similar tools available to users within the product. The transition to the EU CDM data elements


will certainly require some time for Members to adjust, but in itself it should not cause too many issues. The real challenge lies in the amount of data required for a CDS declaration, which we will touch upon in the coming months.


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