HMRC have reported that they are aware of some temporary issues with licence data flows between the Custom Declaration Service (CDS) and the Department for Business and Trade’s (DBT) electronic licensing systems (SPIRE/LITE). These issues occur when a CDS exports declaration contains errors which affect the licence. As a result, the declaration cannot progress to a cleared status.
Best practice when submitting a CDS declaration and declaring a licence
Ensure you are citing the correct license reference in Data Element (DE) 2/3 and have input the exact characters, omitting any whitespace such as spaces.
Avoid using document status codes 'EE' (Electronic Exhausted) or 'ES' (Electronic Surrendered) on CDS (DE 2/3) unless your intention is to exhaust or surrender the license. You should use the document status code 'EP' (Electronic Partial) instead.
Furthermore, declarants must verify that the details in DE 2/3 are accurate before submitting the declaration, confirming that:
- The license quantity must not be zero unless the intention is to cancel an existing reservation; if there is no existing reservation, an issue will arise, and the declaration cannot be modified or deleted, necessitating a new submission.
- The measurement unit for the quantity should correspond with the measurement unit linked to the license.
- If a document status code is relevant, it must be consistently applied to all goods items in the declaration.
If you need to declare a commodity that requires two document status codes for the same license, follow the instructions provided for DE 2/3.
What to do if your declaration is ‘stuck’ in a registered state (no DMSACC received)
Should a discrepancy arise with DE 2/3, your declaration will not be rejected but will instead remain in a 'received' status. Furthermore, in the event that your goods have reached the frontier, neither the Community System Provider (CSP) nor the carrier will receive any response notifications, and your goods will not proceed to P2P.
At this juncture, you may receive notification from the carrier regarding an issue that requires your attention. It is imperative that you refrain from attempting to modify the declaration, as doing so will not resolve the issue and may lead to incorrect storage of your license usage.
Instead, it is necessary to invalidate your current declaration and submit a new one using a fresh Declaration Unique Consignment Reference (DUCR) and Local Reference Number (LRN).
If your goods have been consolidated under a Master Unique Consignment Reference (MUCR), invalidating your declaration will automatically disassociate your (DUCR) from the MUCR. You should promptly inform your carrier and make arrangements for the removal of your goods from the consolidation. If needed, seek guidance from your carrier, freight forwarder, or intermediary.
In the event that you have tried to amend a declaration with a license error, the declaration will remain in a 'received' status and will not progress to 'registered' or 'accepted'. A new declaration must be submitted, and it is advisable to contact HMRC to rectify the license reservation.
If a discrepancy arises with DE 2/3 during the declaration of a commodity that necessitates 2 document status codes for the same license, your declaration will be rejected. In such cases, you must refer to the corrective guidance provided below for error code 'CDS70719 Licence Error: Electronic license quoted although Document Status Code indicated paper license'.
Contact HMRC should you encounter error codes.
Hammad Baig has expertise in providing guidance to those exporting under license, please do not hestiate to contact his clerks as outlined bleow.
HAMMAD BAIG © 2024
BARRISTER, MIEx
33 BEDFORD ROW
Hammad Baig practices international trade law, tax law and commercial litigation with a specific interest in VAT and Customs and Excise Law.
Further articles on topics relating to his practice areas can be read under his Insights and on his blog. Should you wish to instruct Hammad Baig then please do not hesitate to contact his clerk Mark Byrne.
NOTICE: This article is provided free of charge for information purposes only; it does not constitute legal advice and should not be relied on as such. No responsibility for the accuracy and/or correctness of the information and commentary set out in the article, or for any consequences of relying on it, is assumed or accepted by any member of Chambers or by Chambers as a whole.
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