Industry update, December 2025

CDS: HMRC implemented CDS release 5.0.0 on Saturday, 13 December. Updates include changes relating to NI movements, to ensure NI traders can meet legal obligations from 1 January.

ICS2: HMRC continues to publish guidance and readiness encouragement for the 31 December deadline, with a focus on goods moving into Northern Ireland. However, ICS2 is an EU system, and exports from GB by road into Europe also require an ENS declaration to ICS2. If this isn’t done, trucks could be delayed or even prevented from crossing the channel. This would arguably be an even bigger issue for GB trade. 

The functionality to submit ENS declarations to ICS2 has been available in Sequoia since September 2025. We urge you to start submitting at least some ENS declarations now. This will allow you to familiarise yourselves with what you need to do ahead of the 31 December deadline. 

Information on how to create ENS declarations in Sequoia is available on the ASM Resource Centre. The functionality, for road movements to the EU, is free to use, with no licence fee or transaction charges, although a Sequoia licence key is required. 

If you have not yet requested a licence for ICS2, simply create a Service Request on the ASM Service Desk Portal with the subject 'ICS2 licence required'. 

Autumn Budget 2025: The Government will remove the customs duty relief on goods imported into the UK valued at under £135. These low-value imports will, in future, be subject to customs duty. A public consultation has now opened, covering the proposed design of the new arrangements, including data requirements for LVI, tariff application, a possible administration fee, and potential changes to VAT collection. The consultation runs until 6 March, 2026.  

HMRC has confirmed that the data processing of these 600m+ annual consignments will not be carried out on CDS. This would require a new solution, which could have a negative effect on the funding of improvements to CDS.