The new UK Customs Declaration Service (CDS) began its rollout in July, at a time when UK forwarders face uncertainty over Brexit, both in terms of trade and possible new Customs regulations. We catch up with Peter MacSwiney, Co-Chair of the Joint Customs Consultative Committee (JCCC) Brexit Sub Group, Chairman of Agency Sector Management, and non- governmental member of the CDS Programme Board.
How is the new Customs Declaration Service roll-out going and what changes does it bring?
The new CDS has started to be rolled out, but it is too early to tell how it is going. not many people are using it because there were a few problems with functionality; people realized it does not have everything it needs to have, so they had to make a few tweaks to the software and this has delayed uptake. it is a big change.
Ideally you change processes and the system at different times, but this is all being done together, so it is more for people to get used to.
The new system uses the Union Customs Code, so it has XML instead of EDIFACT and that is a completely different way of doing things. It makes electronic inputting mandatory and brings everything up to date. People will get used to it. Once they understand it, it will be business as usual.
Of course, there is political pressure to get everyone to migrate quickly and switch the old CHIEF system off, for financial reasons, but Customs is rolling CDS out over a period and managing it well. It is difficult, but it will get there.
What is the latest from the JCCC Brexit sub-group?
At the moment it is trying to work out whether there will be a UK-EU deal or not, and what to do if there is a no-deal scenario. We will not know until the end of October. So, the work is mainly to outline plans in case of a no deal. However, in my view, Customs is working out how to enforce plans but not asking business what is feasible, and what can be done; the mistake is that the plans do not necessarily follow the trade, but we hope to get a solution.
For instance, we know that if we have to process consignments at Dover and the Channel Tunnel there would be chaos within hours, so we have to work out a way to get everything ﬂowing freely.
The latest White Paper i think is a good position – it is a pity we did not have that 18 months ago – questioning whether we want Customs entries at all. To which the answer is frankly, no. Nobody wants them. We have 250 million shipments going through with no form of declaration at the moment, so bringing in Customs entries would be an enormous burden for no good reason.
Technically it can be done within the CDS, but adding upwards of 60 data elements, as we would for non-EU exports, for each shipment is not ideal. In fact, introducing Customs entries would serve no purpose. If the EU agrees to that position then we would have a chance of putting together a deal on the other stuff – a trade agreement, and beginning trade negotiations.
Of course, the biggest problem is not knowing. We are planning for all sorts of scenarios, but it is all theoretical and has not been tried out in practice. Obviously, there is reluctance to spend money on testing scenarios that might never happen. So how feasible are the plans? i do not think they have been explored with the trade as much as they might have done.
The next milestone is the UK-EC meeting on October 31, so we will see what the outcome of that is.