This is an enhancement to the CDS release from late December last year, and it will double-check that the country codes are entered accurately in these data elements.

Background:

CDS update 4.9.0 released on 27^th December 2026 included an update to data elements 5/15 & 5/16 with the following instructions:

• Country Code ‘EU’ is only permitted to be used to declare the Country of Preferential Origin in DE 5/16.
• It should not be declared in DE 5/15.
• When ‘EU’ is declared in DE 5/16, DE 5/15 should be completed with the Country Code of the EU member state where the goods originated.

Alert

Any stored data used for previous CDS declarations may now be rejected if it was historically inaccurate. CDS may have accepted inaccurate information before validation was implemented.

The coding in these data elements should be checked for compliance before a declaration is submitted.

HMRC also advise ensuring that any pre-lodged declarations submitted before this next CDS release are updated to take the new validation into account.

For Clarity

The obligation is to ensure that DE 5/15 and DE 5/16 are completed accurately and that preference codes, especially for movements involving NI, are completed as follows:

• Continue to provide the standard country-of-origin code within DE 5/15.

This is the standard two-digit ISO country code.

• Do not use new country-group codes, expanded formats, or four-digit codes

These will not be accepted

Preferential codes must be used correctly

Continue to use the correct preference codes:

• Preference codes starting with a ‘1’ - no preferential treatment will apply.
• Preference codes starting with any number other than 1 indicate that the preference is being claimed.

Sample preference codes:

• 100- no preference is being claimed
• 300- preference is being claimed

Claiming preference in CDS

Country of Preferential Origin (DE 5/16):

DE 5/16 must be completed when a preferential tariff claim is being made. This will support the validation of the preference claim.

If NOT claiming preference using the 100 code -   DE 5/16, will not require completion.

Explanation: CDS checks DE 5/15 country of origin and, if applicable, DE 5/16 to determine the correct tariff measures

Northern Ireland (NI) Declarations 

In an instance where a preference code of 100 has been declared in DE 4/17, meaning that no UK preference is to be claimed, with an EUPRF AI code other than a 100 series being declared in DE 2/2, DE 5/16 must be completed. 

This will support the validation of the NI/EU preferential claim.

If DE 5/16 is excluded in these scenarios, the declaration will be rejected.

This is due to CDS requiring DE 5/16 to validate any NI/EU preference claims.

Evidencing Preference

There is no change to the necessity to retain records and supporting compliance evidence.

As a trader, it is essential to ensure that evidence is appropriately retained and that valid evidence is on file to support the preference declaration.

The above changes were implemented on the 28^th of March 2026.