Consultation outcome

The future of customs declarations - call for evidence

Updated 7 December 2023

This was published under the 2022 to 2024 Sunak Conservative government

Summary

Subject of this call for evidence

This call for evidence seeks views on how customs declaration requirements can be streamlined and how technology can be used to make meeting these requirements as easy and cost effective as possible. This is part of the government’s vision within the 2025 UK Border Strategy for the UK border to be the most effective in the world by simplifying processes for traders and embracing innovation.

Scope of this call for evidence

This call for evidence invites respondents’ views on 2 areas:

1. streamlining customs declarations
2. use of technology to complete declarations

Who should read this

The government welcomes engagement from any individual or business with views on the future of the UK’s customs regime. This call for evidence is likely to be of particular interest to traders, intermediaries, freight forwarders, hauliers, and customs software providers. Business representative organisations (including those who represent businesses that do not currently trade internationally, but may consider doing so in future), trade bodies or customs consultancies that help traders with their customs affairs will also have an interest.

Duration

The call for evidence will run for 10 weeks starting on 29 June 2023 and ending on 8 September 2023.

Lead official

This is a joint call for evidence led by HM Revenue and Customs (HMRC) and HM Treasury customs policy teams.

How to respond or enquire about this call for evidence

Any responses or queries about this call for evidence should be sent to [email protected].

Respondents may choose to respond to some or all the questions in this document. HMRC and HM Treasury welcome partial responses, focused on the aspects of the call for evidence most relevant to the respondent.

Additional ways to be involved

HMRC and HM Treasury are keen to collaborate with a wide range of stakeholders and will organise several engagement opportunities to ensure that views are heard from across the range of sectors who interact with the customs system. Please contact us using the details above if you would like to be involved.

After the call for evidence

The government will publish a summary of responses shortly after the call for evidence closes. Evidence submitted will be considered as part of the customs policy-making process, and this may lead to further consultation in the future.

Ministerial foreword

In the 2023 Spring Budget, the government announced a package of customs measures intended to simplify customs import and export processes for traders, taking advantage of new freedoms following EU exit. This package is a key element of the government’s vision for a UK customs system that is at the cutting edge globally in terms of its openness, dynamism and capacity to advance the UK’s status as a leading hub for international trade in goods. Central to this package was a review of customs declarations.

Customs declarations are a crucial part of the UK government’s ability to protect our fiscal and trade interests and uphold the UK’s internationally recognised high regulatory and security standards at the border, but in so doing they can impose burdens on the border industry. Through this review, we are looking to ensure that customs declarations are as streamlined as they possibly can be to minimise any burdens they impose on traders, while still delivering on the UK’s vital interests. This builds on the announcements we made on simplifications to Safety and Security and Sanitary and Phytosanitary declarations as part of the draft Border Target Operating Model, ensuring that we are delivering the best possible experience for businesses across all our key border declarations.

But our ambitions for the future of customs declarations go further. Through taking advantage of cutting-edge technologies and real-time data, we believe there is potential to further reduce trade frictions and the burdens on industry, while maintaining a robust and effective border. As part of this we are reviewing the opportunities that technologies provide for making customs processes easier for businesses to comply with.

Key to this is understanding the perspectives of businesses across the border industry. We want the views of traders of all sizes and levels of experience, from the largest high-volume traders to the small infrequent traders who are just starting out on their trading journey, as well as the views of intermediaries and software providers. I am aware that businesses across the border industry are currently undergoing a series of changes, from completing Customs Declaration Service (CDS) migration to preparing for the launch of the Single Trade Window, and I thank you for continuing to work so closely with government as we build a customs system that is fit for the future.

Your insight on customs declarations will ensure that we can draw on the very best ideas and further develop our customs system to underpin the government’s ambition to make the UK the best place in the world to do business.

Rt Hon Victoria Atkins MP
Financial Secretary to the Treasury

1. Introduction

The 2025 UK Border Strategy sets out the government’s vision for the UK border to be the most effective in the world. A border which enables innovation, simplifies processes for traders and travellers and improves the security and biosecurity of the UK.

The government’s core function at the border is to ensure the smooth and predictable movement of goods and people, while also keeping citizens safe. Our border policies and processes not only enable businesses to trade with other countries in a fair and competitive way, including through the collection of tariffs and duties, but also protect domestic markets and consumers from illicit goods and unfair trading practices. A robust system of controls at the border is essential to prevent smuggling, implement international standards for trade in goods that uphold the UK’s reputation for integrity and fairness, and protect the UK from crime and biosecurity threats.

When moving goods across the border, businesses need to navigate the rules around what data they must provide, how to submit it, and when. As announced at Spring Budget 2023, the government is undertaking a review of the data that we ask businesses to provide and investigate opportunities to streamline customs declaration requirements. As a key part of this review, in chapter 3 of this call for evidence we want to hear from businesses about the benefits and burdens of certain data elements and test proposals for simplifications. The information you provide will be used in conjunction with internal analysis to ensure we strike the right balance between minimising burdens and effectively delivering the government’s core border functions.

The government also recognises the role new technologies could play in improving traders’ interaction with border processes. In chapter 4 of this call for evidence, we wish to understand traders’ and intermediaries’ current use of technology to aid meeting customs requirements and expectations around how technology could be deployed in the future.

Simplifying the core customs data requirements is only one part of the government’s strategy for the UK border. The government has committed to building a UK Single Trade Window, which will streamline ‘how’ businesses share information to meet declaration and other regulatory requirements with border agencies. This will allow parties involved in trade and transport to lodge standardised information and any documents within a single electronic entry point to fulfil all UK import, export, and transit related requirements.

Pilots have been recently conducted on the ‘Ecosystem of Trust’ concept that seeks to definitively test whether new capabilities across supply chain security and technology can provide greater assurance of goods crossing the border, which in turn could unlock the potential to develop world-leading Trusted Trader Schemes that are able to provide even greater facilitations to trade without jeopardising security. We are in the process of evaluating the pilots and will publish our findings in due course.

We know that many traders employ the services of a customs intermediary, businesses that help traders to move goods across borders by ensuring they meet their obligations, and that impacts of changes made to improve and simplify the customs system may therefore be indirect in terms lower core data requirements and/or reduced costs rather than direct. Alongside this call for evidence, respondents may also wish to contribute to the Introducing a voluntary standard for customs intermediaries consultation which is proposing the introduction of a voluntary standard for customs intermediaries to improve the quality of service provided across the sector.

Not all questions within the call for evidence will be relevant to you, but we would encourage you to read all chapters and each chapter signposts where questions are for the consideration of specific actors (such as traders, intermediaries, software providers).

2. About your business

Questions about the respondents (type of business, such as trader, intermediary, software provider), size of business, number of movements (if trader), type of technology supplying) 

2.1 Business processes/about your business

The following introductory questions will help us understand more about the nature of your business or organisation and the main interactions you currently have with the UK’s customs regime:

Questions for all respondents

Question 1: What is the name of your business/organisation?

Question 2: What type of business/organisation are you? (for example, trader, intermediary, fast parcel operator, haulier, software provider, trade association etc).

Question 3: What is the size of your business?

• micro (0 to 9 employees)
• small (9 to 49 employees)
• medium (50 to 249 employees)
• large (over 250 employees)

If you are a trade body, please state your membership size instead.

Question 4: How long has your business been importing or exporting goods, or supporting traders to import/export if you are an intermediary?

Question 5: Please describe the goods that you trade, the nature of your trade (import, export, or both) and where you move goods from and to?

Question 6: Approximately how many movements do you make per year, what is the total value of these movements and how many declarations does your business submit (directly or through an intermediary) per year?

Question 7: Do you make declarations in jurisdictions other than the UK? If so, do you find making customs declarations for the UK more or less burdensome than for other countries?

Question 8: What software/systems (if any) do you have in place to support your completion of customs declarations? What other software are you aware of? And what criteria did you use when deciding which software package to use?

Questions for traders only

Question 9: How long does it take for your staff to complete a declaration, or to provide the information required to an intermediary, and how does this vary by type or length of declaration? What processes/automation do you use to make this faster (if any)?

Question 10: What proportion of the data required for a customs declaration is data you already hold in your systems for commercial purposes? Is there any data you only hold for customs purposes (please specify)?

Question 11: If you use an intermediary(/ies), how much are you charged per declaration? Does this vary by type or length of declaration, and if so, how? What other factors influence how much your intermediary(/ies) charge you?

Question 12: If you use an intermediary(/ies), what information do you have to provide to the intermediary(/ies) to complete a declaration, and how are you sharing this information with your intermediary(/ies)?

Questions for intermediaries only

Question 13: On average, how long does it take for your staff to complete a customs declaration, and how does this vary by type or length of declaration?

Question 14: How much do you charge per declaration, and how does this vary by type or length of declaration? How much do you charge for any other services you provide? What factors influence the price of the declarations and any other services that you offer?

3. Streamlining customs declarations

3.1. Examining declaration datasets

Background

Each of the 6 declarations in scope of this section (full import and export declarations, import and export supplementary declarations, and import and export Simplified Frontier Declarations (SFD)) require traders to provide a significant quantity of information through a large number of data elements.

We know due to the uptake of simplifications such as the Simplified Customs Declaration Process (SCDP), which is a 2-stage electronic declaration process, that many traders and intermediaries value the flexibility to provide a reduced amount of data upfront.

There is a significant set of data elements on customs declarations that are fundamental to the UK’s customs regime and protecting our fiscal interests and upholding high regulatory and security standards at the border. We are not considering these as part of this review. However, there are some data elements where we would value the views of the border industry on the benefits and burdens that these data elements impose. We will use the information you provide in this section to inform our review of customs declaration datasets to ensure that they are striking the right balance between minimising burdens on the border industry while still enabling the government to effectively deliver our core responsibilities at the border.

When answering the questions below, we are interested in your views on the benefits or burdens that your business faces in completing the following data elements. We expect that the nature of the burdens will be different for different types of businesses – for example, traders who use intermediaries are likely to be responsible for sourcing the relevant information, while intermediaries will have to convert this information into a format that is compatible with the CDS and submit it. Traders who complete declarations in house are likely to experience any burden directly themselves.

Note: Annex A provides a list of all data elements mentioned in this document, including their CDS codes and CHIEF (Customs Handling of Import and Export Freight) box numbers for reference, with a brief description of the data elements and the declaration types that they appear on.

Questions for traders and intermediaries only

Question 15: Please rate the data elements in table 1.1 to table 1.5 on a scale of 1 to 5 by the degree of burden that providing them imposes on your business. If you can, please provide an explanation for why you have rated these data elements as you have, and what the benefit would be for your business if they were removed?

Rating key:

1 – Not at all difficult to provide
2 – Moderately easy to provide
3 – Somewhat difficult to provide
4 – Difficult to provide
5 – Very difficult to providen
N/A – Not relevant to your business

As mentioned in Question 15, please use ‘Explanation’ (in the final column) to state:

• why did you select this burden rating
• what would be the benefit to your business if this data element was removed

Table 1.1. Customs declaration data elements – for all declaration types

CDS Code	CHIEF Box	Name	Description	Rating (1-5)	Explanation
1/6	32	Goods item number	Number of specific goods items in relation to total number of items contained in the declaration.
1/9	05	Total number of items	Total number of items declared on the customs declaration.
5/26	44	Customs office of presentation	Name and address of UK customs office of presentation.
5/27	44	Supervising customs office	Name and address of UK supervising customs office.
6/18	06	Total packages	Total number of packages across all goods items on the declaration.
7/5	26	Inland mode of transport	Inland mode of transport, such as maritime, rail, road, air.
7/9	18	Identity of means of transport at the border	Identity of the means of transport on which the goods are directly loaded at the time of presentation at the customs office of import. The identity of the means of transport at the point when the goods are presented and the customs formalities for their release are to be completed.
7/15	21	Nationality of active means of transport	Nationality of active means of transport crossing the border.
8/2	44 and 52	Guarantee type	Determine whether cash, guarantee waiver, or type of guarantee is used.
8/3	52	Guarantee reference	Reference number for the guarantee.
8/5	24	Nature of transaction	The type of transaction for the goods moved, such as transfer of ownership.

Table 1.2. Customs declaration data elements – for export declarations only:

CDS Code	CHIEF Box	Name	Description	Rating (1-5)	Explanation
4/11	22	Total amount invoiced	Total invoice price/amount for all goods declared in the declaration, in the currency stated on the commercial invoice.
4/15	23	Exchange rate	The rate of exchange fixed in advance by a contract between the parties concerned.
5/8	17a	Country of destination code	The country to which the goods are to be delivered.
5/12	29	Customs office of exit	The customs office by which it is intended that the goods should leave the territory.
5/14	15a	Country of dispatch/export code	The country in which the goods are located at the time they are declared for the export procedure.
7/14	21	Identity of active means of transport crossing the border	The identity of the active means of transport to be used for crossing the external border, where known.

Table 1.3. Customs declaration data elements – for Simplified Frontier Declarations (import) only:

CDS Code	CHIEF Box	Name	Description	Rating (1-5)	Explanation
2/6	48	Deferred payment	The Deferment Account Numbers (DANs) of the deferment accounts to be used.
4/8	47e	Calculation of taxes – method of payment	Determine how payment will be taken, such as immediate payment in cash.
4/9	45	Additions and deductions	Factors to be added to the overall value.

Table 1.4. Customs declaration data elements – for Simplified Frontier Declarations (import and export) only:

CDS Code	CHIEF Box	Name	Description	Rating (1-5)	Explanation
6/2	41	Supplementary units	Only required when the commodity code specifies a supplementary unit.

Table 1.5. Customs declaration data elements – for Supplementary Declarations (import and export) only:

CDS Code	CHIEF Box	Name	Description	Rating (1-5)	Explanation
6/9	31	Type of packages	The package type of the smallest external packing unit, such as bag, container, barrel etc.
6/10	31	Number of packages	Number of packages making up the consignment covered by the declaration, based on the smallest external packing unit.
6/11	31	Shipping marks	Marks and numbers on transport units or packages.
7/2	19	Container	Indicate whether the goods will be in a shipping container when crossing the external border.
7/4	25	Mode of transport at the border	Mode of transport used to arrive at the external border, such as rail, road, air, maritime etc.
7/10	31	Container ID number	Marks (letters and/or numbers) that identify the transport container.

Question 16: For the data elements listed in tables 1.1 to table 1.5, does completing any of these data elements provide a business/commercial benefit to you, and do you perceive any risks associated with removing any of these data elements? If so, please explain.

Question 17: Do you typically complete the optional data elements DE 2/4 reference number/UCR (Unique Consignment Reference), DE 3/37 additional supply chain actor, and (for import declarations only) DE 4/11 total amount invoiced and if so, why?

Question 18: Where actor information can be provided as either a name or identification (ID) number, how much value does this flexibility provide for your business? How often do you complete the following data elements, and how often do you do this as well as completing their complement (for example, you provide both the actor name and ID no.):

• (for import declarations) DE 3/2 exporter ID number
• (for export declarations) DE 3/10 consignee ID number
• (for SCDP declarations only) DE 3/17 declarant
• (for all declaration types) DE 3/19 representative?

Questions for import declarations only

Question 19: How challenging would it be for your business to provide the following data elements on import declarations, using the scale provided in table 1 if helpful (note: the requirement to provide these data elements is currently waived): DE 3/24 seller; DE 3/25 seller ID number; DE 3/26 buyer; and DE 3/27 buyer ID number? Would you envisage any benefits if these data elements were required? Please explain your answer.

Question 20: What do you understand to be the difference between DE 5/15 country of origin and DE 5/16 country of preferential origin? What information do you use to complete these fields? Are there any circumstances in which you provide different codes in these 2 fields? If so, why?

Question 21: When completing the data elements DE 6/5 gross mass and DE 6/1 net mass, do you find it easy to provide accurate information for both data elements, or do you sometimes use one figure to approximate the other?

Question for businesses that move chemicals:

Question 22: When moving chemicals, how often do you complete the data element DE 6/13 CUS (Customs Union and Statistics) code? If you do use this data element, how burdensome is it to provide this code, and do you find it easier to provide this information than the commodity code? Have you tried using the new Online Tariff Service for CAS (Chemical Abstracts Service registration number), CUS, and commodity code correlation?

Questions for businesses using both SCDP and full declarations

Question 23: What would be the impact on your business, in terms of data collection, processing and submission, if some data elements were removed from the supplementary declaration but retained on the full declaration?

Question 24: Are there any data elements not raised above that provide a particular burden on your business that you would like us to be aware of?

Questions for traders, intermediaries and software providers only

Question 25: Would changes to the customs declaration dataset require changes to your systems or processes, and if so, how long would this take and how expensive would it be for you to make these changes? In cases where we may consider removing data elements, would it be better for your systems for data elements to be removed entirely from declarations or to be made optional?

Question 26: Noting the broader landscape of ongoing changes to the customs regime, such as the launch of the Single Trade Window and potential future utilisation of technology (see chapter 4), would you support simplifications to customs datasets being brought in over the next few years? How extensive would any simplifications need to be in order to make the systems and process changes required worthwhile for your business?

3.2. Changes to supplementary declaration aggregation rules

Background

SCDP (previously known as Customs Freight Simplified Procedures (CFSP)) is a 2-stage electronic declaration process which moves fiscal and statistical controls inland. Traders provide less data than a full customs declaration at the frontier and then a supplementary declaration later. This gives flexibility to traders and supports the flow of trade at the border.

When using SCDP to clear goods through ports on import (the first SCDP stage) traders will use one of 2 different options:

• Simplified Declaration Procedure: used for releasing goods at the frontier to most customs procedures, including free circulation and special procedures, by submitting a reduced data set
• Entry in Declarant’s Records (EIDR): also used for releasing goods at the frontier but allows traders to retain data in the declarant’s own records rather than sending it to HMRC. EIDR cannot be used for controlled goods, and at inventory-linked ports, a C21 customs clearance request is required to release goods

After goods cross the border, a supplementary declaration is then made within a month of import to complete the process. Any tax or duty owed is not paid until after the supplementary declaration is submitted to HMRC.

Declarants operating SCDP may need to submit large volumes of individual supplementary declarations per day. Individual submission of these declarations can cause data processing issues and increase messaging costs. Traders can reduce the number of declarations submitted to HMRC by aggregating multiple consignments of goods into a single supplementary declaration, even when the goods cross the border separately. There are 3 types of aggregation: daily; across tax point; and customs period.

• Daily aggregation is particularly used where many removals from customs warehousing occur at different times of the same day. These removals can be rolled up into an aggregated message.
• Across tax point aggregation allows declarations to be rolled up to a maximum message size of 3MB. This allows consignments imported over several days to be accounted for on the same supplementary declaration.
• Customs period aggregation allows supplementary declarations to be combined where the tax point falls within the same 10-day period of the month. These aggregation periods are day 1 to 10; day 11 to day 20; day 21 to month end. [Changes announced in Spring Budget 2023 will allow traders to submit one aggregated supplementary declaration for goods imported over the course of the month].

Feedback suggests that the rules around aggregation are seen as complex and may deter SCDP authorised traders from applying and using the facilitation. We are therefore interested in understanding the level of awareness of aggregation, and what can be done to reduce complexity and increase take-up.

The table in Annex B outlines the aggregation rules that apply to certain data elements.

Questions for businesses using SCDP only

Question 27: Do you use aggregation when submitting supplementary declarations? If you use aggregation, please explain which type you use and the value it provides to your business. If you do not use aggregation at all, why not?

Question 28: Would it be beneficial to your business for changes to be made to the rules in Annex B? What changes would you like to see and how beneficial would they be to your business? Are there any aggregation rules mentioned in Annex B that should remain as they currently are?

3.3. Flexibility at header/item level

Background

Data elements on declarations are entered at either header (applying to the whole declaration) or item (applying to one commodity code on the declaration) level.

For most data elements, whether they should be entered at header or item level is prescribed by the declaration system. However, there are currently several data elements where declarants have the flexibility to choose whether to enter information at header or item level as the declarant sees fit, such as DE 7/10 containers.

Where data elements can be entered flexibly at header or item level, the following rules apply:

• it may only be entered at header level where it applies equally to every goods item
• information must be entered at item level where it differs for even a single goods item
• it must be entered at item level where it would result in an incorrect duty calculation if entered at header level, for example, a proportional reduction in air freight charges by gross weight

We want to know what impact this currently has on the ease of completing and submitting declarations and what changes could be made to reduce the burden of declaration submission.

The table below provides an overview of data elements that are currently either header or item completion level only that we are considering making flexible at both header and item level. To note, if any changes were made, they might only apply on certain declaration types and would not be applicable to all.

Header only

Item only

DE 2/6 – Deferment DE 2/7 – Warehouse ID DE 3/39 – Holder of the Authorisation DE 4/1 – Delivery Terms DE 4/9 – Additions and Deductions DE 5/23 – Location of Goods DE 5/27 – Supervising Office DE 7/4 – Mode of Transport DE 7/5 – Inland Mode of Transport DE 7/7 – Identity of Transport at Departure DE 7/9 – Identity of Transport at Arrival DE 7/14 – Identity of Active Means of Transport crossing the Border DE 7/15 – Nationality of Active Means of Transport crossing the Border DE 8/2 – Guarantee Type DE 8/3 – Guarantee ID

DE 2/2 – Additional Information DE 2/3 – Document Codes DE 4/13 – Valuation Indicators DE 4/16 – Valuation Method DE 5/15 – Country of Origin DE 5/16 – Country of Preferential Origin

Questions for traders and intermediaries only

Question 29: Where declarants currently have flexibility to choose whether to enter data elements at header or item level, such as for DE 7/10 containers, does your business value and make use of this option, and if not, why? Would it be beneficial for your business if this flexibility was extended to additional data elements, and if so, why?

Question 30: Looking at the table above, are there any data elements included that you believe should not be made flexible? Are there any data elements that the review should consider making flexible that are not included in the table above?

3.4. Changes to grouping rules

Background

To reduce the number of items that need to be included on a customs declaration, traders moving consignments containing multiple goods items can use a simplification that allows them to group together multiple goods items on their declaration if:

• the goods fall under different tariff sub-headings
• separating them into each individual goods item would involve disproportionate work or expense in relation to the duty chargeable

Certain conditions must be met, such as goods may not be subject to prohibitions or restrictions or subject to any licencing requirements.

If a grouping simplification approach is taken, the consignment must be grouped under the single commodity code that attracts the highest rate of duty (and duty, where due, will be charged on that basis).

Questions for traders and intermediaries only

Question 31: Do you use grouping when submitting declarations? If you use grouping, please explain the circumstances in which you use it. If you do not use grouping but would like to, why not?

Question 32: What type of goods, and how many different types of goods, do you typically move when using grouping?

Question 33: What is the value of the movements you make when you use grouping?

4. Use of technology to complete declarations

Background

To deliver ambitions set out in the 2025 UK Border Strategy, we are reviewing the role technology could have in making border processes easier for businesses to comply with.

When answering the questions below we are interested in your views on the current market presence and use of customs technology. We also aim to understand where the burdens sit within existing border processes and how these could be improved through the application of technology, while still meeting core government border requirements.

Throughout this section, we will refer to ‘technological solutions’, which we define as customs management or compliance software which specifically deal with customs processes and IT systems that help manage supply chain information, for example Enterprise Planning Resource systems, Warehouse Management systems, Inventory Management systems, or Customer Relationship Management systems. Some of these functions may be provided by in-house developed systems, agents or by commercial software products. Further solutions refer to technology based on Artificial Intelligence (AI) or Machine Learning (ML) used for the automated creation of customs-specific data (using commodity code software) or audit and compliance monitoring software, among others.

4.1. Availability of technology to support the completion of declarations

Background

This section aims to build our evidence base around the availability of technological solution offerings and their range and reach; in effect scoping the supply side of the market.

Questions for software providers and intermediaries only

Question 34: How do the technological solutions currently on offer help in meeting customs declaration requirements?

Question 35: Are these technological solutions available for all types of businesses or are they targeted at specific sizes and sectors? Have you identified any gaps in a particular product’s user base?

Question 36: Which customs processes are not currently supported by technological solutions? Do you foresee future products supporting the completion of these processes?

4.2. Uptake and use of technology to support the completion of declarations

Background

This section aims to build our evidence base on who is using technology, which technological solutions are used and how this might differ between self-declarants and intermediaries; in effect scoping the demand side of the market.

Questions for traders and intermediaries only

Question 37: What technological solutions are you aware of being available in the market for meeting declaration requirements (even if you don’t use them)? Which, if applicable, are you currently using?

Question 38: What are you using these technological solutions for, and what factors did you consider when deciding which solution(s) to use? If you are not using them, why not?

Question 39: What was the initial or upfront investment cost for these technological solutions?

Question 40: How much does the implementation and maintenance of these solutions cost on a yearly basis?

Question 41: Are there any other technological solutions you expect or want to use in the future? For example, using AI and/or ML-based technology for the automated creation of customs-specific data (using commodity code generators) to support you in meeting customs declaration requirements.

4.3. Benefit(s), including the reduction in burden, of using technology to meet declaration requirements

Background

This section aims to build our understanding over the range of benefits, both perceived and experienced, from the use of technology by traders and intermediaries, and understand the blockers in the uptake of technological solutions.

Questions for traders and intermediaries only

Question 42: What benefits are technological solutions bringing to your business?

Question 43: How, and to what extent, do you think technology improves current customs processes and meeting declaration requirements?

Question 44: Does technology help reduce internal cost of meeting customs declaration requirements? If so, where is the internal cost reduction?

Question 45: Does technology improve the processes required to make a customs declaration? For example, in generating data required for customs declarations, collating data from various actors in the supply chain, or submitting declarations themselves (or sending the information to your intermediary). If so, how?

Questions for intermediaries only

Question 46: Do technological solutions support you in meeting declaration requirements and/or help your customers share relevant information?

Question 47: Does the usage of technology result in any changes to your role or function?

4.4. Potential barriers to using technology to meet declaration requirements

Background

This section aims to build our understanding about why traders and intermediaries are not using technological solutions to meet their declaration requirements.

Questions for traders and intermediaries only

Question 48: What is the biggest barrier to the uptake in and use of technological solutions, both currently and in any future plans? Such as, upfront, implementation or maintenance costs; integration to own systems; data migration across systems; training staff.

Question 49: Are there any legal and/or policy reasons that might discourage you from using these technologies?

5. Further suggestions

HMRC and HM Treasury are interested in hearing other ideas from a wide range of stakeholders about how customs declarations can be simplified and the role of technology and innovation in the UK customs system.

Questions for traders, intermediaries and software providers

Question 50: Are there any further suggestions that you have?

6. Summary of call for evidence questions

Chapter 2: About your business

Questions for all respondents

Question 1: What is the name of your business/organisation?

Question 2: What type of business/organisation are you? (for example, trader, intermediary, fast parcel operator, haulier, software provider, trade association etc).

Question 3: What is the size of your business?

• micro (0 to 9 employees)
• small (9 to 49 employees)
• medium (50 to 249 employees)
• large (over 250 employees)

If you are a trade body, please state your membership size instead.

Question 4: How long has your business been importing or exporting goods, or supporting traders to import/export if you are an intermediary?

Question 5: Please describe the goods that you trade, the nature of your trade (import, export, or both) and where you move goods from and to?

Question 6: Approximately how many movements do you make per year, what is the total value of these movements and how many declarations does your business submit (directly or through an intermediary) per year?

Question 7: Do you make declarations in jurisdictions other than the UK? If so, do you find making customs declarations for the UK more or less burdensome than for other countries?

Question 8: What software/systems (if any) do you have in place to support your completion of customs declarations? What other software are you aware of? And what criteria did you use when deciding which software package to use?

Questions for traders only

Question 9: How long does it take for your staff to complete a declaration, or to provide the information required to an intermediary, and how does this vary by type or length of declaration? What processes/automation do you use to make this faster (if any)?

Question 10: What proportion of the data required for a customs declaration is data you already hold in your systems for commercial purposes? Is there any data you only hold for customs purposes (please specify)?

Question 11: If you use an intermediary(/ies), how much are you charged per declaration? Does this vary by type or length of declaration, and if so, how? What other factors influence how much your intermediary(/ies) charge you?

Question 12: If you use an intermediary(/ies), what information do you have to provide to the intermediary(/ies) to complete a declaration, and how are you sharing this information with your intermediary(/ies)?

Questions for intermediaries only

Question 13: On average, how long does it take for your staff to complete a customs declaration, and how does this vary by type or length of declaration?

Question 14: How much do you charge per declaration, and how does this vary by type or length of declaration? How much do you charge for any other services you provide? What factors influence the price of the declarations and any other services that you offer?

Chapter 3: Streamlining customs declarations

3.1. Examining declaration datasets

Questions for traders and intermediaries only

Question 15: Please rate the data elements in table 1.1 to table 1.5 on a scale of 1-5 by the degree of burden that providing them imposes on your business. If you can, please provide an explanation for why you have rated these data elements as you have, and what the benefit would be for your business if they were removed?

Question 16: For the data elements listed in tables 1.1 to table 1.5, does completing any of these data elements provide a business/commercial benefit to you, and do you perceive any risks associated with removing any of these data elements? If so, please explain.

Question 17: Do you typically complete the optional data elements DE 2/4 reference number/UCR (Unique Consignment Reference), DE 3/37 additional supply chain actor, and (for import declarations only) DE 4/11 total amount invoiced and if so, why?

Question 18: Where actor information can be provided as either a name or identification (ID) number, how much value does this flexibility provide for your business? How often do you complete the following data elements, and how often do you do this as well as completing their complement (for example, you provide both the actor name and ID no.):

• (for import declarations) DE 3/2 exporter ID number
• (for export declarations) DE 3/10 consignee ID number
• (for SCDP declarations only) DE 3/17 declarant
• (for all declaration types) DE 3/19 representative?

Question for import declarations only

Question 19: How challenging would it be for your business to provide the following data elements on import declarations, using the scale provided in table 1 if helpful (note: the requirement to provide these data elements is currently waived): DE 3/24 seller; DE 3/25 seller ID number; DE 3/26 buyer; and DE 3/27 buyer ID number? Would you envisage any benefits if these data elements were required? Please explain your answer.

Question 20: What do you understand to be the difference between DE 5/15 country of origin and DE 5/16 country of preferential origin? What information do you use to complete these fields? Are there any circumstances in which you provide different codes in these 2 fields? If so, why?

Question 21: When completing the data elements DE 6/5 gross mass and DE 6/1 net mass, do you find it easy to provide accurate information for both data elements, or do you sometimes use one figure to approximate the other?

Question for businesses that move chemicals

Question 22: When moving chemicals, how often do you complete the data element DE 6/13 CUS (Customs Union and Statistics) code? If you do use this data element, how burdensome is it to provide this code, and do you find it easier to provide this information than the commodity code? Have you tried using the new Online Tariff Service for CAS (Chemical Abstracts Service registration number), CUS, and commodity code correlation?

Questions for businesses using both SCDP and full declarations

Question 23: What would be the impact on your business, in terms of data collection, processing and submission, if some data elements were removed from the supplementary declaration but retained on the full declaration?

Question 24: Are there any data elements not raised above that provide a particular burden on your business that you would like us to be aware of?

Questions for traders, intermediaries and software providers only

Question 25: Would changes to the customs declaration dataset require changes to your systems or processes, and if so, how long would this take and how expensive would it be for you to make these changes? In cases where we may consider removing data elements, would it be better for your systems for data elements to be removed entirely from declarations or to be made optional?

Question 26: Noting the broader landscape of ongoing changes to the customs regime, such as the launch of the Single Trade Window and potential future utilisation of technology (see chapter 4), would you support simplifications to customs datasets being brought in over the next few years? How extensive would any simplifications need to be in order to make the systems and process changes required worthwhile for your business?

3.2. Changes to supplementary declaration aggregation rules

Questions for businesses using SCDP only

Question 27: Do you use aggregation when submitting supplementary declarations? If you use aggregation, please explain which type you use and the value it provides to your business. If you do not use aggregation at all, why not?

Question 28: Would it be beneficial to your business for changes to be made to the rules in Annex B? What changes would you like to see and how beneficial would they be to your business? Are there any aggregation rules mentioned in Annex B that should remain as they currently are?

3.3. Flexibility at header/item level

Questions for traders and intermediaries only

Question 29: Where declarants currently have flexibility to choose whether to enter data elements at header or item level, such as for DE 7/10 containers, does your business value and make use of this option, and if not, why? Would it be beneficial for your business if this flexibility was extended to additional data elements, and if so, why?

Question 30: Looking at the table above, are there any data elements included that you believe should not be made flexible? Are there any data elements that the review should consider making flexible that are not included in the table above?

3.4. Changes to grouping rules

Questions for traders and intermediaries only

Question 31: Do you use grouping when submitting declarations? If you use grouping, please explain the circumstances in which you use it. If you do not use grouping but would like to, why not?

Question 32: What type of goods, and how many different types of goods, do you typically move when using grouping?

Question 33: What is the value of the movements you make when you use grouping?

Chapter 4: Use of technology to complete declarations

4.1. Availability of technology to support the completion of declarations

Questions for software providers and intermediaries only

Question 34: How do the technological solutions currently on offer help in meeting customs declaration requirements?

Question 35: Are these technological solutions available for all types of businesses or are they targeted at specific sizes and sectors? Have you identified any gaps in a particular product’s user base?

Question 36: Which customs processes are not currently supported by technological solutions? Do you foresee future products supporting the completion of these processes?

4.2. Uptake and use of technology to support the completion of declarations

Questions for traders and intermediaries only

Question 37: What technological solutions are you aware of being available in the market for meeting declaration requirements (even if you don’t use them)? Which, if applicable, are you currently using?

Question 38: What are you using these technological solutions for, and what factors did you consider when deciding which solution(s) to use? If you are not using them, why not?

Question 39: What was the initial or upfront investment cost for these technological solutions?

Question 40: How much does the implementation and maintenance of these solutions cost on a yearly basis?

Question 41: Are there any other technological solutions you expect or want to use in the future? For example, using AI- and/or ML-based technology for the automated creation of customs-specific data (using commodity code generators) to support you in meeting customs declaration requirements.

4.3. Benefit(s), including the reduction in burden, of using technology to meet declaration requirements

Questions for traders and intermediaries only

Question 42: What benefits are technological solutions bringing to your business?

Question 43: How, and to what extent, do you think technology improves current customs processes and meeting declaration requirements?

Question 44: Does technology help reduce internal cost of meeting customs declaration requirements? If so, where is the internal cost reduction?

Question 45: Does technology improve the processes required to make a customs declaration? For example, in generating data required for customs declarations, collating data from various actors in the supply chain, or submitting declarations themselves (or sending the information to your intermediary). If so, how?

Questions for intermediaries only

Question 46: Do technological solutions support you in meeting declaration requirements and/or help your customers share relevant information?

Question 47: Does the usage of technology result in any changes to your role or function?

4.4. Potential barriers to using technology to meet declaration requirements

Questions for traders and intermediaries only

Question 48: What is the biggest barrier to the uptake in and use of technological solutions, both currently and in any future plans? Such as, upfront, implementation or maintenance costs; integration to own systems; data migration across systems; training staff.

Question 49: Are there any legal and/or policy reasons that might discourage you from using these technologies?

Chapter 5: Further suggestions

Questions for traders, intermediaries and software providers

Question 50: Are there any further suggestions that you have?

7. Glossary of terms

Term	Description
Aggregation	When using SCDP traders can reduce the number of declarations submitted to HMRC by aggregating multiple consignments of goods into a single supplementary declaration, even when the goods cross the border separately.
Customs Declaration Service (CDS)	The CDS supports making import and export declarations when moving goods into and out of the UK. CDS replaced CHIEF for imports on 01 October 2022 and will fully replace CHIEF for exports from 1 December 2023.
Customs Handling of Import and Export Freight (CHIEF)	The UK’s legacy customs system used for managing the declaration and movement of goods into and out of the United Kingdom. The last day to make import declarations through CHIEF was 30 September 2022. The last day for making export declarations on CHIEF will be 30 November 2023, after which CHIEF will be decommissioned.
Customs intermediary	Customs intermediaries help traders to move goods across borders. Most traders hire a person or business to deal with customs on their behalf. Examples of intermediaries include freight forwarders, customs agents, brokers or fast parcel operators.
Simplified Customs Declarations Process (SCDP)	This is a 2-stage electronic declaration process which moves fiscal and statistical controls inland. Traders provide less data than a full customs declaration at the frontier and then a supplementary declaration later.

The consultation process

This consultation is being conducted in line with the Tax Consultation Framework. There are 5 stages to tax policy development:

Stage 1: Setting out objectives and identifying options.

Stage 2: Determining the best option and developing a framework for implementation including detailed policy design.

Stage 3: Drafting legislation to effect the proposed change.

Stage 4: Implementing and monitoring the change.

Stage 5: Reviewing and evaluating the change.

This consultation is taking place during stage 1.

How to respond

A summary of the questions in this consultation is included at chapter 6.

Responses should be sent by 8 September 2023, by email to [email protected].

Please do not send consultation responses to the Consultation Coordinator.

Paper copies of this document or copies in Welsh and alternative formats (large print, audio and Braille) may be obtained free of charge from the above address.

All responses will be acknowledged, but it will not be possible to give substantive replies to individual representations.

When responding please say if you are a business, individual or representative body. In the case of representative bodies please provide information on the number and nature of people you represent.

Confidentiality

HMRC is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law, including the UK GDPR and the Data Protection Act (DPA) 2018.

Information provided in response to this consultation, including personal information, may be published or disclosed in accordance with the access to information regimes. These are primarily the Freedom of Information Act 2000 (FOIA), the DPA 2018, UK GDPR and the Environmental Information Regulations 2004.

If you want the information that you provide to be treated as confidential, please be aware that, under the Freedom of Information Act 2000, there is a statutory Code of Practice with which public authorities must comply and which deals with, amongst other things, obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on HM Revenue and Customs.

Consultation Privacy Notice

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the UK GDPR.

Your data

We will process the following personal data:

Name
Email address
Postal address
Phone number
Job title

Purpose

The purposes for which we are processing your personal data is: The future of customs declarations.

Legal basis of processing

The legal basis for processing your personal data is that the processing is necessary for the exercise of a function of a government department.

Recipients

Your personal data will be shared by us with HM Treasury.

Retention

Your personal data will be kept by us for 6 years and will then be deleted.

Your rights

You have the right to request information about how your personal data are processed, and to request a copy of that personal data.

You have the right to request that any inaccuracies in your personal data are rectified without delay.

You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.

You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.

You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.

Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 [email protected]

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Contact details

The data controller for your personal data is HMRC. The contact details for the data controller are:

HMRC
100 Parliament Street
Westminster
London
SW1A 2BQ

The contact details for HMRC’s Data Protection Officer are:

The Data Protection Officer
HMRC
14 Westfield Avenue
Stratford
London
E20 1HZ

[email protected]

Consultation principles

This call for evidence is being run in accordance with the government’s Consultation Principles.

The Consultation Principles are available on the Cabinet Office website.

If you have any comments or complaints about the consultation process, please contact the Consultation Coordinator.

Please do not send responses to the consultation to this link.

Annex A – Data elements

Import declarations

CDS code	CHIEF box	Name	Description
1/6	32	Goods item number	Number of specific goods items in relation to total number of items contained in the declaration.
1/9	05	Total number of items	Total number of items declared on the customs declaration.
2/6	48	Deferred payment	The Deferment Account Numbers (DANs) of the deferment accounts to be used.
4/8	47e	Calculation of taxes – method of payment	Determine how payment will be taken, such as immediate payment in cash.
4/9	45	Additions and deductions	Factors to be added to the overall value.
4/11	22	Total amount invoiced	Total invoice price/amount for all goods declared in the declaration, in the currency stated on the commercial invoice.
4/15	23	Exchange rate	The rate of exchange fixed in advance by a contract between the parties concerned.
5/8	17a	Country of destination code	The country to which the goods are to be delivered.
5/14	15a	Country of dispatch/export code	The country in which the goods are located at the time they are declared for the export procedure.
5/15	34a	Country of origin	The country of non-preferential origin of the goods.
5/16	34b	Country of preferential origin	The country of preferential origin of the goods.
5/26	44	Customs office of presentation	Name and address of UK customs office of presentation.
5/27	44	Supervising customs office	Name and address of UK supervising customs office.
6/2	41	Supplementary units	Only required when the commodity code specifies a supplementary unit.
6/9	31	Type of packages	The package type of the smallest external packing unit, such as bag, container, barrel etc.
6/10	31	Number of packages	Number of packages making up the consignment covered by the declaration, based on the smallest external packing unit.
6/11	31	Shipping marks	Marks and numbers on transport units or packages.
6/18	06	Total packages	Total number of packages across all goods items on the declaration.
7/2	19	Container	Indicate whether the goods will be in a shipping container when crossing the external border.
7/4	25	Mode of transport at the border	Mode of transport used to arrive at the external border, such as rail, road, air, maritime etc.
7/5	26	Inland mode of transport	Inland mode of transport, such as maritime, rail, road, air etc.
7/9	18	Identity of means of transport at the border	Identity of the means of transport on which the goods are directly loaded at the time of presentation at the customs office of import. The identity of the means of transport at the point when the goods are presented and the customs formalities for their release are to be completed.
7/10	31	Container ID number	Marks (letters and/or numbers) that identify the transport container.
7/15	21	Nationality of active means of transport	Nationality of active means of transport crossing the border.
8/2	44 and 52	Guarantee type	Determine whether cash, guarantee waiver, or type of guarantee is used.
8/3	52	Guarantee reference	Reference number for the guarantee.
8/5	24	Nature of transaction	The type of transaction for the goods moved, such as transfer of ownership.

Export declarations

CDS code	CHIEF box	Name	Description
1/6	32	Goods item number	Number of specific goods items in relation to total number of items contained in the declaration.
1/9	05	Total number of items	Total number of items declared on the customs declaration.
4/11	22	Total amount invoiced	Total invoice price/amount for all goods declared in the declaration, in the currency stated on the commercial invoice.
4/15	23	Exchange rate	The rate of exchange fixed in advance by a contract between the parties concerned.
5/8	17a	Country of destination code	The country to which the goods are to be delivered.
5/12	29	Customs office of exit	The customs office by which it is intended that the goods should leave the territory.
5/14	15a	Country of dispatch/export code	The country in which the goods are located at the time they are declared for the export procedure.
5/15	34a	Country of origin	The country of non-preferential origin of the goods.
5/26	44	Customs office of presentation	Name and address of UK customs office of presentation.
5/27	44	Supervising customs office	Name and address of UK supervising customs office.
6/2	41	Supplementary units	Only required when the commodity code specifies a supplementary unit.
6/9	31	Type of packages	The package type of the smallest external packing unit, such as bag, container, barrel etc.
6/10	31	Number of packages	Number of packages making up the consignment covered by the declaration, based on the smallest external packing unit.
6/11	31	Shipping marks	Marks and numbers on transport units or packages.
6/18	06	Total packages	Total number of packages across all goods items on the declaration.
7/2	19	Container	Indicate whether the goods will be in a shipping container when crossing the external border.
7/4	25	Mode of transport at the border	Mode of transport used to arrive at the external border, such as rail, road, air, maritime etc.
7/5	26	Inland mode of transport	Inland mode of transport, such as maritime, rail, road, air etc.
7/10	31	Container ID number	Marks (letters and/or numbers) that identify the transport container.
7/14	21	Identity of active means of transport crossing the border	The identity of the active means of transport to be used for crossing the external border, where known.
7/15	21	Nationality of active means of transport	Nationality of active means of transport crossing the border.
8/2	44 and 52	Guarantee type	Determine whether cash, guarantee waiver, or type of guarantee is used.
8/3	52	Guarantee reference	Reference number for the guarantee.
8/5	24	Nature of transaction	The type of transaction for the goods moved, such as transfer of ownership.

Annex B – Aggregation rules

Data element (DE) number	DE name	Aggregation rule
1/1	Declaration type	Cannot mix IM and CO on an aggregated declaration.
1/2	Additional declaration type	Cannot aggregate across additional declaration types.
1/10	Procedure	All codes must apply to the goods, for example, all Inward Processing (IP) at item level. The same DE 1/10 procedure code must apply to the goods being aggregated.
1/11	Additional procedure	All codes must apply to the goods, for example, all Community System of Duty Reliefs (CSDR) at item level. DE 1/11 can be declared up to 99 times per item to cover single goods item scenarios.
2/1	Simplified declaration and previous documents	DE 2/1, 4th component, goods item no. (n..3): where the previous document contains more than 999 items, this component should be left blank. The audit trail of the previous document will be established through the declarant’s commercial records instead.
2/1	Simplified declaration and previous documents	When aggregating across 39 DUCRs or less use the following: SDP YSDE + the simplified declaration MRN YDCR + the DUCR used as the commercial audit trail between the simplified declaration, records and supplementary declaration YDCS + the DUCR part number (if appropriate) EIDR YCLE + date of the EIDR entry in records followed by the goods item number if appropriate YDCR + the DUCR reference number used as the commercial audit trail between the EIDR entry, commercial records and the supplementary declaration. YDCS + the DUCR part number (if appropriate)
2/1	Simplified declaration and previous documents	If aggregating across 40 or more DUCRs use the following: SDP YSDE + the simplified declaration MRN (Last MRN of the declarations being aggregated) YDCRAGGDUCRGB + the EORI number + a unique reference number + 1 — to provide a reference that tracks back to the record of all DUCRs aggregated across the supplementary declaration. (The DUCRs held in the records should comply with the WCO recommended format as detailed in CDS Declaration and Customs Clearance Request Instructions.) EIDR YCLE + the last date of the aggregation period YDCRAGGDUCRGB + the EORI number + a unique reference number + 1 — to provide a reference that tracks back to records of all DUCRs aggregated across the supplementary declaration. (The DUCRs held in the records should comply with the WCO recommended format as detailed in CDS Declaration and Customs Clearance Request Instructions.) Note: If aggregating across tax points none of the elements that affect the duty calculation may change.
2/2	Additional information	Where an AI code requires explicit information to be declared on the declaration this cannot be aggregated, as specific information is required against the code. Where a ‘range’ may be declared, provide a reference number that tracks back to the commercial records breakdown.
2/3	Documents produced, certificates and authorisations, additional references	Where a Doc code requires specific information to be declared on the declaration — this cannot be aggregated, as specific information is required against the code. Where a ‘range’ may be declared, provide a reference number that tracks back to the commercial records breakdown. BTIs: Declare C626 and a single BTI code, you must have records showing an audit trail for all other BTIs which apply to that item. Invoice details: Where N935 is required — insert a reference that allows a cross reference back to the individual invoices in the commercial records.
2/6	Deferred payment	Enter the codes DAN 1 or DAN 2 (or both). In DE 2/3 declare Doc code 1207, if indirect representative is used and the DAN belongs to the importer. Note: Mandatory when deferment is used.
2/7	Identification of warehouse	If a Customs Warehousing (CW) or Free Zone (FZ) Procedure Code is declared enter the Type, Warehouse Identification Number and Country Code. All goods on an aggregated declaration must relate to the same CW, EW or FZ. Note: If CW, EW or FZ are not used leave blank.
3/1	Exporter	All goods declared at item level must be for a single exporter. Enter the full name and address of the third country exporter or EORI. More than one exporter is allowed on a supplementary declaration as header level covered by AI code 00200. Note: Only provided where DE 3/2 is not completed.
3/2	Exporter identification number	All goods declared at item level must be for a single exporter. More than one Exporter allowed on a supplementary declaration as header level covered by AI code 00200. Note: Mandatory where a recognised Identification number is held or where DE 3/1 is not completed.
3/15	Importer	Single importer at header level. All goods on an aggregated supplementary declaration must relate to a single importer. Note: Only provided where DE 3/16 is not completed.
3/16	Importer identification number	All goods on an aggregated supplementary declaration must relate to a single importer.
3/18	Declarant identification number	Single declarant at header level.
3/20	Representative identification number	Single representative (where declared) at header level. Note: Only required when different from DE 3/18.
3/21	Representative status code	No aggregation across representation types. Note: Only required where a representative is used.
3/24	Seller	Enter code 00200 – Various-AGG. Details of different sellers for specific declarations must be kept in the commercial records.
3/25	Seller identification number	If aggregating across Sellers, code 00200 – Various-AGG must be entered in 3/24. Details of different sellers for specific declarations must be kept in the commercial records.
3/26	Buyer	Enter code 00200 – Various-AGG. Details of different buyers for specific declarations must be kept in the commercial records.
3/27	Buyer identification number	If aggregating across Buyers, code 00200 – Various-AGG must be entered in 3/26. Details of different buyers for specific declarations must be kept in the commercial records.
3/39	Holder of the authorisation identification number	EORI numbers for authorisations are declared at header level. Cannot aggregate across different parties for a single authorisation type, that is, IP for 2 different importers.
3/40	Additional fiscal references identification number	Where required each separate OSR recipient must be declared, that is, 99 times at header or item level. Note: Only required where the requested procedure is 42 (Onward Supply Relief – OSR).
4/1	Delivery terms	Cannot aggregate across delivery terms. Where goods are removed from a customs warehouse, the customs value may be converted to CIF for the purposes of aggregation prior to being declared.
4/3	Calculation of taxes – tax type	Same tax types must apply to the aggregated goods at item level.
4/4	Calculation of taxes – tax base	Where measurement units are required, the same measurement unit code must apply to all the goods aggregated at item level.
4/6	Calculation of taxes – payable tax amount	Where using OVR01 in DE 2/2, all aggregated items must have a manual tax calculation at item level for all tax types.
4/8	Calculation of taxes – method of payment	Aggregated goods must use the same MOP code at item level.
4/9	Additions and deductions	Any addition or deduction declared at header or item level must apply to all the aggregated goods. Where goods are removed from a customs warehouse, the customs value may be converted to CIF and additions and deductions may be left blank.
4/10	Invoice currency	This box does not require completion however a currency must always be declared against any monetary amount entered on the declaration.
4/13	Valuation indicators	Goods may be aggregated across DE 4/13 codes providing that there is a full breakdown in the commercial records.
4/14	Item price amount	Declare the aggregated value for the item. Where goods are being removed from a customs warehouse, the customs value may be converted to CIF for the purposes of aggregation. Declare the converted customs value ensuring all necessary additions and deductions have been made to the aggregated value entered in DE 4/14.
4/15	Exchange rate	If a fixed rate of exchange applies, this must apply to all the aggregated items.
4/16	Valuation method	The same valuation method must apply to all the aggregated goods at item level.
4/17	Preference	Cannot aggregate across preference codes.
5/18	Country of destination code	If goods are being entered to Onward Supply Relief (OSR) – cannot aggregate across destination Member States.
5/14	Country of dispatch and export code	If declared at header level, all goods must be from same country. If different countries apply, this must be declared at item level and aggregation can only be used where all the goods declared on a single item are from the same country.
5/15	Country of origin code	Cannot combine preference and non-preference on same item. Cannot aggregate across preference codes. Note: Single code at item level.
5/16	Country of preferential code	Cannot combine preference and non-preference on same item. Cannot aggregate across preference codes.
5/21	Place of loading	The same adjustment or airport zone must apply to everything in the declaration. Note: Only used if an airfreight adjustment code is declared in DE 4/9.
5/23	Location of goods	Single goods located at header level. For warehousing must declare – GBBYCW + Warehouse Identification number. For Free Zones declare – GBBYFZ + Free Zone Identification number. For other location types where more than one location applies, declare GBBYAGG + reference number to link breakdown in the commercial records.
5/27	Supervising customs office	All items on the declaration must have the same supervising office.
6/2	Supplementary units	Whilst an aggregated quantity may be declared, the supplementary unit measurement type or code must be the same for all aggregated goods.