Our own experiences show that HMRC have been processing the move to CDS in a way that may prevent freight forwarders having access to the importer’s/exporter’s CDS.

HMRC have now issued a document setting out “known workarounds” for “issues” with CDS. HMRC have said that this is necessary “as the platform proceeds through the final stages of its development”. A platform that was initially due to be implemented in early 2019.

The document issued by HMRC is an excel spreadsheet. It would be impractical to go through all the issues raised here, the tab “Known_Differences_-_Workaround” has nearly 70 different entries. However, the fact that one these states “Commodity codes for aircraft parts do not currently permit the use of any VAT rate other than 20%” shows how far CDS is from being a workable platform for certain sectors. (There is a significant Z/R relief for the supply of parts for qualifying aircraft).

Equally, another line states: “There is no current provision in the CDS Trade Tariff for application of VAT treatment to goods liable to supply VAT in the UK” which seems to demonstrate how far CDS is from being able to deal with every day transactions.

In addition to the known workarounds there are also tabs for “Known error logs”, “Migration Blockers” and “Authorisation by Declaration”

Businesses and freight forwarders experiencing issues with the CDS should refer to this guide to see if their problem (and work around) are highlighted.

https://www.gov.uk/government/publications/known-error-workarounds-for-the-customs-declaration-service-cds

If you have any other issues regarding CDS registration, EORI, clearing goods, or other import/export issues please contact Ian Marrow .