It became apparent some time ago (and agreed by HMRC) that CDS was unlikely to be rolled out, to the extent that CHIEF could be turned off, before the end of 2021. Accordingly, ASM planned our developments to deliver fully functioning, smart CDS functionality, in September 2021.
However, HMRC recently announced that import declarations, required for all goods moving from GB to NI, must be completed on CDS. (CHIEF is still the system that will be used for other EU shipments.)
The trade do not accept that this is achievable for a number of reasons which include:
- Whilst some of the software providers (including us) have some working CDS functionality, there is little confidence in rolling out a full solution.
- There are still blocking issues on export declarations, revenue creating import declarations and export dual running (inventory linking etc. when both CHIEF and CDS are in use)
- Traders are not familiar with the data requirements for CDS and there is still no tariff guidance available online.
- CDS has not been tested sufficiently, is not robust enough to handle the expected volumes and we are not confident that HMRC support is adequate.
- There is no definitive list of ‘Goods at risk’ (those that will attract the EU rate of duty) and the data elements for declarations appear to be undefined.
- There are too many unanswered questions and gaps in understanding.
ASM therefore cannot support or participate in the roll out of CDS for NI for 1.1.21.
We have written to HMRC to officially inform them of this position. We will work with them to agree contingency measures for NI and to publish the available workarounds when they become clear.
One option would be, for goods moving from GB to NI, to:
- process goods at risk (of moving to the Republic of Ireland) on CDS using the government provided Trader Support Service (TSS) and;
- process all the rest on CHIEF.