Yesterday, the British International Freight Association (BIFA) expressed its concern over the new “Customs Declaration System” (CDS) that will replace the existing “Customs Handling of Import and Export Freight” (CHIEF) system used for processing customs declarations in the United Kingdom. BIFA said it is concerned that the progress with the development of the new system has been inconsistent and that updates on the system’s development have been scarce. 

While the new system currently is being developed by several stakeholders, including Her Majesty’s Revenue and Customs (HMRC), IBM, community systems providers (CSPs), numerous software providers and representatives, BIFA said its “single greatest concern” is that currently the development process does not involve end-user representatives. 

“This is a dangerous oversight because it is the end-user who will determine what actually will work in practice, particularly as IT developers have been flagging up a lack of clarity regarding data elements,” said BIFA Director General Robert Keen. “To give a simple example, LIC 99, which indicates a license waiver for all types of goods, is to be replaced. The new requirement will be for a license waiver for individual types of licenses, which potentially adds complexity and makes entry completion more difficult in practice.” 

The new system also will require more significant changes to commercial software systems than previously envisaged, BIFA contented in its statement. It argued that the new CDS will consist of 78 data fields for import and 65 for export declarations, while the existing CHIEF requires the completion of 59 data fields total. 

HMRC recently announced its proposed plan for completing delivery of the new CDS and requiring migration of traders to the new platform by September 2020, in order for HMRC to meet its requirement to shut down CHIEF by March 2021 at the end of its current contract. 

“We have heard from CSPs and other software developers, and HMRC itself, that this timeline is challenging and understand that HMRC has requested software developers and CSPs to expedite their plans to deliver and assure the necessary changes to IT systems and business processes without compromising the integrity of the border or the flow of international trade,” Keen said. “On top of all these issues, we have to factor in the increasing likelihood of a no-deal Brexit, and the demands that it will put on our sector.” 

Based on these concerns, BIFA is challenging HMRC and the IT sector to identify all problem areas of CDS and to formulate a plan to resolve them. BIFA also calls on those entities to agree to a realistic time frame in rolling out the new system once it is “fully developed, stable and tested” and urges the groups to involve end-users in this process.