HMRC have recently explained that Customs Freight Simplified Procedure (CFSP) will now be operating under the new name of Simplified Customs Declaration Processes (SCDP) going forward.
While there are no major changes to how Simplified Customs Declaration Processes (CFSP) operates since the UK transition, HMRC have highlighted that anyone currently operating as an Indirect Rep can also opt to operate as a Direct Rep for clients based in GB, if they already hold an appropriate CFSP authorisation. Those that have done this or intend on doing this, should update the supervising office by email at: leeds.citexarteam@hmrc.gov.uk
Who can use SCDP?
Traders and customs agents need to be authorised by HMRC to use Simplified Customs Declaration Processes. It is possible for a customs agent to act as either a direct (GB only) or indirect representative for import declarations. This may be important because it affects who’s liable for any customs debt:
Self-representation (SR) – there is self-representation (SR) where an authorised importer acts on their own behalf.
Direct representation (DR) – this is where the representative acts in the name of and on behalf of the importer. If the trader is the SCDP authorisation holder, the representative doesn’t need to be.
In this case the importer remains solely responsible for any Customs debt.
Indirect representation (IR) – this is where an authorised agent acts in their own name and on behalf of the importer. Examples of this are the fast parcel operators who act in their own name when importing goods for their customers.
With indirect representation the agent and importer are jointly and severally liable for any Customs debt. This means that the agents could be sued independently for any debts incurred by the importer.
Warehouse Entry
SDP is by far the most common way for goods using SCDP to enter a customs warehouse.
The trader submits an SFD which shows that the goods are entering a warehouse and giving details. So, the goods enter the customs warehouse procedure at the frontier.
When the goods physically enter the warehouse, they are entered into the warehouse stock records. These records must include details of the Declaration Unique Consignment Reference (DUCR) and SFD entry numbers and dates.
The trader submits an SDI by the fourth working day of the following month that shows that the goods are in warehousing. The warehouse keeper records the SDI entry number in the warehouse stock records.
Although EIDR can be used to import goods and move them into a customs warehouse, it’s very rare. This is because the customs warehouse procedure itself provides a similar (and unlimited) business benefit to the 20-day delay provided by temporary storage. Most entries into a customs warehouse therefore use SDP.
Warehouse Removal
EIDR is more commonly used in connection with customs warehousing to remove goods from the customs warehouse. Traders must be authorised to do it.
It allows traders to make an entry in their local inventory records and means they can remove goods from a warehouse without having to submit an electronic declaration to HMRC for the goods before they can leave.
The trader needs to follow up the local clearance entry by sending a supplementary declaration to HMRC, in this case called a Supplementary Declaration Warehouse (SDW) to HMRC within the normal time period of the fourth working day of the following month.
Under this system, the use of EIDR must be allowed for in the customs warehouse authorisation and the procedure for removals is as follows.
The trader notifies HMRC before the removal (if specified in their authorisation).
The warehouse keeper enters details of the removal to a customs procedure in the local inventory records. This must include the tax point date, which establishes the base date for the submission of the SDW.
If standing/dwell time is needed, it will be specified in the authorisation letter. Dwell time is a period of time between noting the local inventory records and physically releasing the goods. This time gap gives HMRC an opportunity to examine the goods – some of which (like certain CAP goods) may require regular mandatory examinations.
The trader submits the SDW by the fourth working day of the month after the base date month.
How can we help?
If you require further information or would like assistance in applying for Simplified Customs Declaration Processes (SCDP) or customs warehousing, then please contact us to discuss your needs further.
Published: 7th February 2022