Steve Bartlett AFSS Chairman
After too many years and several delays, the Customs Declaration Service (CDS) finally went live for almost everyone late last year. Now, almost all import declarations are processed though CDS, and only a handful through the legacy CHIEF system.
So, some may see this as a success story, right? Well, not quite. The journey to get here was a long and painful one, and whilst many traders are now getting used to using CDS and its quirks, it will be many months before they can say they were near the same productivity that they were at using CHIEF. Now, the attention is focused on migrating everyone to using CDS for their export declarations, and so both the trade organisations and HMRC have been in many discussions to see what lessons can be learned from the import experience.
A key lesson was that practical and achievable timescales to complete the migration must be agreed by both parties. It has felt in the past that Government and HMRC seem to underestimate the scale, complexity and time it takes to move thousands of traders from a platform they have used for decades to a new one. This is what caused multiple delays for imports and risked doing the same for exports.
Last year, after much debate with AFSS and other trade groups, HMRC finally admitted that the final cutover date for exports of April 2023 was not achievable. We now have a new deadline that all export declarations must be made through the CDS by 30 November 2023. There remain some key fixes and functionality updates to be delivered in March, which must be thoroughly tested. It is essential to track and monitor the success of this testing because problems identified that require software fixes will impact the overall programme. AFSS chairs a regular meeting with all trade groups including the Community Service Providers, BIFA and AICES, together with HMRC, to keep all parties on track, and ensure that any blockers to migration are quickly identified and resolved.
CDS reliability has certainly been an issue recently. By HMRC’s own admission it has been ‘wobbly’. Initially we began to see more outages than usual for the service, with no real pattern for causes, ranging from outages at the datacentre provider, issues with the Government Gateway and some within CDS itself. In January, the incident where traders were charged VAT twice for the same transaction caused enormous problems. Sadly, it seems that the trader is the first to notice (rather than any Government monitoring) and this in turn puts huge strain on software supplier’s own helpdesks. We have been assured by HMRC that extensive root cause analysis is performed on each outage, and it has pledged to get better at communicating to the wider trade when this happens. We hope this will be the case.
The way the migration to exports is communicated is a key lesson for all, not just in terms of the timescales, but also on the way CDS functions. The imports experience has shown CDS to be far tighter on completion rules than CHIEF was. Those rules have always been there but somehow CHIEF did not always force compliance. Traders must educate themselves on the changes to ensure they are ready for September. And this education needs to be spread throughout Government agencies too so that, for example, Border Force staff do not insist on a printed copy of something when it is not required, or even have access to the CDS system.
What is refreshing is that HMRC are sharing their communication plans and material with us prior to publication, so allowing trade to review to ensure the right message is sent at the right time.
For a long time, we have consistently put pressure on HMRC to have a contingency plan for those who cannot migrate to CDS in time. With less than a month to go last year, HMRC finally announced that traders that could not move to CDS in time could apply for an extension to continue using CHIEF. This was very well received by trade, giving a bit more breathing space to migrate but more importantly, to continue for the journeys where CDS itself could not be used. We hope that this kind of contingency is considered for exports, because it is inevitable that more oddities that CDS does not support will emerge as migration ramps up.
As we continue to build our software for CDS exports, I am pleased to see noticeable increase in consultation and involvement of the trade from HMRC. We have a programme board to debate progress, and weekly technical calls between software providers and HMRC, which will maintain the momentum so that we can jointly achieve the deadline.
We cannot afford to delay progress with CDS, as development work on NCTS5, ICS2 and Single Trade Window to name a few, will keep everyone very busy in 2023.
Formed in 1993, the Association of Freight Software Suppliers (AFSS) brings together and represents many of the leading suppliers of software to the freight and transportation industry. The Association is recognised by HM Customs and by BIFA and is represented on several Customs and EU consultations and working groups.
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