Sean Turner – VAT and Transport and Logistics Specialist
DD: +44 (0)207 465 1908
Update on transition from CHIEF to CDS
Further to previous Government announcements and proposed timelines, HMRC’s new system for the submission of customs declarations, the Customs Declaration Service (CDS), is due to be phased in during 2022, as a replacement to the Customs Handling of Import and Export Freight (CHIEF) system.
Under current proposals, CHIEF is due to be switched off for imports by the end of September 2022, although exports will continue until March 2023 and HMRC have stated that these dates are unlikely to change. However, it is understood that some CDS functionality is not quite ready and so whether there will be a delay to migration from CHIEF during 2022, remains to be seen. CHIEF and CDS will run side by side, during the transition period.
Note that, in the first instance, importers using customs brokers, will be required to provide a new authority to use CDS and a deferment account, plus deferment direct debits will need to be amended for CDS.
As always, the timeframe for transition may well change, as we move through 2022 and we will update here accordingly.
What has changed?
In addition to the extended CHIEF cut-off date, transition to CDS, originally scheduled for the start of 2021, will now be delayed. It is understood that CHIEF will continue to operate beyond 2020, with both CHIEF and CDS accepting declarations. Businesses will only be able to commence migration to the new service, when CDS achieves the target Minimum Viable Product (MVP) and Community Systems Providers (CSPs) and software houses are then able to interface their product to it.
Once a business has started transitioning from CHIEF, this is expected to take three months. However, businesses have expressed concern that, to begin transitioning, if CDS is not fully ready, with a three month requirement to complete the transition, this offers little incentive to commence the process, if it ties them to a system that is not fit for purpose. Businesses require clarity on the transitioning arrangements and flexibility from HMRC in the event that CDS offers only partial capability. In conjunction with this, time must be allowed for the link-up with the inventory side, which must also be ready and thoroughly tested by the software houses building software bridges between systems.
HMRC removed the migration timetable from its CDS toolkit on 15 April 2020 and a new timetable is to be published shortly.