International Trade Updates – Strong and Herd

Notices to exporters - GOV.UK

Telephone 020 7215 4594

Exporters are advised to register to receive email alerts for notices to exporters. Registration for the notices and links to previous notices to exporters can be found at the link below:

Notice to Exporters 2026/08

Mon, 13 Apr 2026 11:38:18 GMT

The Export Control Joint Unit published 2026/08 on April 1 ^st 2026. The notice relates to the “General trade licence Russia sanctions: sectoral software and technology” advising that the licence has been updated and the previous version has been revoked.

The updated licence is due to expire on 17 ^th April 2026.

The licence relates to the Prohibitions under Chapter 4N of The Russia (Sanctions) (EU Exit) Regulations 2019 on business enterprise software and technology to multinational clients headquartered outside of Russia (with global subsidiaries and affiliates, including in Russia) under certain conditions.

Specifically, the licence authorises the following activities

the transfer of technology of business enterprise software and technology
the making available of business enterprise software and technology
ancillary services relating to business enterprise software and technology, subject to certain terms and conditions

The licence was first published in July 2025, subsequently revoked and updated in October 2025, and then updated again before the latest update.

“Business enterprise software and technology” is defined in Schedule 3IA of the Regulations, detailed as follows

(a)enterprise resource planning software;

(b)customer relationship management software;

(c)business intelligence software;

(d)supply chain management software;

(e)enterprise data warehouse software;

(f)computerised maintenance management systems;

(g)project management software;

(h)product lifecycle management software;

(i)any component of the software described in sub-paragraphs (a) to (h), including human resource, accounting or fleet management components;

(j)any other information comprised in the software described in sub-paragraphs (a) to (h); and

(k)technology required for the development, production or use of the software described in sub-paragraphs (a) to (h);

Notice to Exporters 2026/08 advises that the decision to extend the licence was made to provide additional time for licensing processes to be completed, ensuring the legitimate use of sanctioned software and technology can continue without disruption.

There is a link on gov.uk specifically for guidance on selling goods or services to Russia, Ukraine, or Belarus.

Notice to Exporters 2026/09

Thu, 09 Apr 2026 14:24:54 GMT

The Export Control Joint Unit published 2026/09 on March 30 ^th 2026. The communication relates to OIEL (Open Individual Export Licence) applications and a change to how the ECJU will accept amendment requests.

In the following circumstances, the Export Control Joint Unit will accept amendment requests.

Changes to exporter details (such as the site or registered address)
Amendments or additions to named recipient details for an existing destination (name and address)
Request to extend an extant OIEL, where a renewal application has already been submitted

The Notice advises that the ECJU will no longer accept amendment requests for the following circumstances

Amendments or additions to goods
Amendments or additions to destinations

The ECJU has advised the reasons for the changes to OIEL applications, confirming that processing substantive amendments takes as long as, or longer than, assessing a new licence application.

NTE 2026/09 is also detailed on the SPIRE login page, the Shared Primary Information Resource Environment, which has been the ECJU Portal for registering and applying for Strategic Export Licences since 2007. SPIRE’s replacement, LITE, was released in Public Beta in September 2024. LITE's first service was to enable SIEL (Standard Individual Export Licence) applications to be submitted on the new portal, with some exceptions for classifications or destinations where a SPIRE application would still be required.

LITE was originally titled Licensing for International Trade and Enterprise and is also referred to as the 'Apply to export-controlled goods' (LITE) service.

The transition from SPIRE to LITE for Open Individual Export Licence applications has begun. On March 11 ^th , the ECJU delivered a one-hour webinar titled “OIEL Functionality in LITE”. The webinar shared details about the screens and data required to apply to the new portal. It is my understanding that OIEL applications on LITE are currently in the Private Beta stage, meaning that certain exporters can apply for licences. This mirrors the transition from SPIRE to LITE for SIEL applications. It is important to highlight that the ECJU have confirmed that amendments or additions to goods and destination are currently not possible on the LITE system.

As with the SIEL application process, SPIRE and LITE share similarities and differences. The OIEL application screens and format will look familiar to exporters who have applied for a SIEL on the new LITE system. The process is split into two sections. Firstly, preparing the application by providing a reference and asking if the exporter has been asked to apply by HMRC or Border Force.

The second section, completing the application, requires a variety of information. The LITE OIEL application process asks “Why are you applying for an OIEL and (roughly) how often do you expect to use the licence to export products”, together with details of the end project that the OIEL exports will relate to, if applicable. The application requires the destinations (countries), Sector type and specific sector, for example, Sector type Non-Government, Sector Anti-Piracy and Destination type, which confirms if the item will be supplied to a country as the first destination of the goods or via a re-export.

We await further details on the release to Public Beta for OIEL applications on LITE.

HMRC Preparation to Implement NCTS6 Phase 2

Tue, 07 Apr 2026 13:54:55 GMT

HMRC have confirmed that phase 2 of the New Computerised Transit System (NCTS6)

will be ready for implementation on 1 ^st June 2026, NCTS6 Phase 1 having been successfully deployed on 1 ^st September 2025.

The final release of NCTS6 is set to go live, with service downtime to be confirmed closer to the go‑live date.

Changes to Come in NCTS6 Phase 2

 Security Types

There will be changes to the available Security Types.

At the moment, the available options in the Data Group (DG) Transit Operation > Data Element (DE) Security > Transit Operation – Security are as follows:

0. No security

1. Entry Summary declaration (ENS) for importing goods into Great Britain or Northern Ireland, or from Great Britain to Northern Ireland

2. Exit Summary declaration (EXS) for exporting goods from Great Britain to any

country, or from Northern Ireland to any non-EU country

3. Both Entry and Exit Summary Declarations (ENS and EXS)

Updates to the Security Options from 1 June 2026

From 1 ^st June, only one of the following options will be available for selection:

0. No security

2. Exit Summary Declaration (EXS) – for exporting goods from GB to any country, or

from XI to any non‑EU country

Using security option (1) or (3) will result in rejection. Therefore, the HMRC web portal has been updated to reflect the options for selection as follows:

“No security” or

“Exit Summary Declaration (EXS)”.

Users of Third-Party Software

These changes should already be reflected in third‑party software products.

Where this is not the case, the user is advised to limit selection to Security Type 0 or 2 to avoid system rejection and subsequent delays to movements.

Authorised Consignees – Reporting an Incident

A new Office of Incident Registration role was introduced in September 2025, with the NCTS5 implementation. This was introduced to facilitate the reporting and recording of incidents directly into NCTS should an incident occur between Departure and Destination.

HMRC confirm that incidents must be reported to the Office of Incident Registration in line with existing guidance, as qualified in section 4.5 Office of Incident Registration.

A link to the guidance is available here: Transit Manual Supplement - 4. Common/Union Transit - Guidance - GOV.UK

From 1 June 2026, Incident Flags will no longer be visible in NCTS screens relating to IE007.

What to do

Make sure that business processes are updated to reflect the upcoming changes.

Only select Security types ‘0’ – No Security or ‘2’ Exit Summary Declaration (EXS), when completing Transit declarations.
Ensure your drivers and/or haulage contractors are aware that they must report any incidents at the nearest customs office on their route to the destination.

Incident Flags will no longer be available from 1 ^st June 2026. It will no longer be possible to record an incident with goods once the goods have arrived.

Users are advised to follow the existing guidance to report any incidents.

If using third-party software, HMRC recommend communicating with the software provider in advance of the 1st June implementation of NCTS6 to determine when the software product will be updated to the new specification.

What’s next

NCTS will be offline as NCTS6 Phase 2 is implemented.

HMRC have confirmed that communications will be issued regarding service downtime, and that downtime details will be communicated on the NCTS availability page in due course.

CDS Validation of Origin and Preferential Origin in Update 5.1.0

Tue, 07 Apr 2026 13:09:40 GMT

The latest release of the CDS, version 5.1.0, released on the 28th of March 2026, included an update to the validation cross-check function between Data Elements 5/15 and 5/16.

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.

Possible Delay to NCTS Declarations on Saturday 28 March, 20:00–00:00, Due to CDS Maintenance

Wed, 25 Mar 2026 14:58:43 GMT

HMRC have advised that some delay may be experienced with NCTS declarations while the CDS is updated.

NCTS declarations will be queued during the following time period:

Sunday 28 ^th March: Between the hours of 20.00 and Midnight.

The NCTS will remain available during this CDS update, and queued declarations will be held and processed once the CDS maintenance activity has concluded.

HMRC recommend that customers submit declarations before the downtime to avoid delays to movements.

HMRC Advice for CDS Update 5.1.0 Scheduled for March 28th 2026

CDS Update 5.1.0.1 Scheduled for Release 29th April

Wed, 25 Mar 2026 14:23:00 GMT

The CDS will be updated on the 29 ^th April with release 5.1.0.1, without requiring downtime.

Users are to note the following.

During this period, any pre-lodged declarations affected by the changes should be changed or amended prior to the goods arriving.
If customs declarations are not corrected prior to arrival, they will be rejected.

ALL MOVEMENTS UPDATE

Warning of possible declaration rejections if inaccurate data is submitted in the following circumstances

Container Identification Number

A maximum of 99 Container Identification Numbers may be entered at the header level, and 99 at the goods item level.

Should more than 99 Container Identification Numbers be entered within DE 7/10 at either the header or item level, the declaration or CCR will be rejected.

This is a known issue and will be added to the Known Error Log.

Document Code C673

Document Status Code XW is no longer valid for use with Document Code C673.

If Document Code C673 is entered in DE 2/3 with a Status Code of XW, the declaration will be rejected.

Commodity Codes

There have been instances of commodity codes being declared within DE 6/14 and 6/15 beginning with 0000.

These are not valid commodity codes, and entering them will cause declarations to be rejected.

To avoid declarations being rejected, you must ensure that only commodity codes from the UK or NI Online Tariffs are declared.

Total Number of Packages

When entering the total Number of Packages declared in DE 6/18 at the header level, it cannot be a negative amount.

Only a value greater than or equal to zero must be entered in DE 6/18.

Should a negative value be entered in DE 6/18, the declaration will be rejected accordingly.

Good Location Codes

New Goods Location Codes have been added, and Appendix 16 will be updated with the details of these GLCs ASAP after the release.

Error Code Changes

CDS errors, which currently generate error codes CDS10002, CDS10044, CDS11004, CDS12056, CDS12070, CDS12072, CDS12077, CDS12092 & CDS12120, will now generate an alternative error code which is considered more appropriate to the specific error.

The above codes remain valid error codes, but are not the best option for some of the errors currently being generated

IMPORT DECLARATION UPDATE

Additional Procedure Code F44

Declaration Categories: H4

Declaration Types: A, D, Y, Z

Should Additional Procedure Code F44 be entered in Data Element (DE) 1/11, then a Valuation Method must also be entered in DE 4/16.

The Valuation Method entered in DE 4/16 can be any of the 6 valid Valuation Methods listed in the Declaration Completion Instructions for DE 4/16.

If F44 is declared in DE 1/11 and DE 4/16 is not completed, then the declaration will be rejected.

If valuation method 1 is declared on an H4 declaration, CDS will no longer incorrectly mandate the declaration of Additional procedure Code F44.

Additional Information Code TOR01

Additional Information (AI) Code TOR01, when entered in DE 2/2, must also be completed with one of the following APCs: C01, C42, or C43 in DE 1/11.

If AI Code TOR01 is entered in DE 2/2 and DE 1/11 does not contain one of C01, C42 or C43, the declaration will be rejected.

AI code TOR01 will no longer be permitted on the same item as additional procedure codes of C02, C03, C06, C60, and C61.

Document Code 920C

Document Status Codes XA and XB are no longer valid to use with Document code 920C

If Document Code 920C is entered in DE 2/3 with Status Code XA or XB, the declaration will be rejected.

Document Codes Y889 and 9Y16

Document Codes ‘Y889’ and ‘9Y16’ have been added to the CDS Code List.

See Appendix 5A for completion instructions when using these codes.

AI Code VATIC

This AI Code VATIC should only be used for F35 Military Authorised-Use Imports under the International Collaboration Defence Arrangement (ICDA).

See Appendix 4B for completion instructions when using this c ode.

EXPORT DECLARATION UPDATE

Quota Order Numbers
Affected Declaration Categories : B1, B2, B4, C1, C21E, C21EEIDR, B1MOU

You should not declare Quota Order Numbers in DE 8/1 on Export movements.

Should DE 8/1 be completed with a Quota Order Number on an Export movement, the declaration or CCR will be rejected.

Commodity Code - 99050000
Commodity code 99050000 is permitted only on import declarations.

An error in the validation introduced in Release 5.1.0 has enabled the continued declaration of commodity code 99050000 on export.

This will now be corrected, and CDS will reject export declarations which include this commodity code.

NTE 2026/07: Submitting Export Licence Applications Under the Agreement on Defence Export Controls

Wed, 25 Mar 2026 08:57:24 GMT

Further to the notice to exporters 2025/32 ECJU has published guidance on how to submit export licence applications for consideration under articles 1, 2 and 3 of the Agreement on Defence Export Controls.

Applications submitted for consideration under Article 3 must be supported by an integration certificate. This records information on the goods and parties involved, end user details, and whether it falls below the minimum threshold.

A template integration certificate and guidance to help complete it have also been published.

Guidance on submitting licence applications for consideration against the Agreement on Defence Export Controls is available on GOV.UK .

Foot and Mouth Disease (FMD) in Greece

Mon, 23 Mar 2026 13:25:01 GMT

The Animal and Plant Health Agency (APHA) has advised that controls will be implemented immediately on the import of products from Greece affected by the recent outbreak of Foot and Mouth Disease (FMD). This control follows a similar outbreak in Cyprus in February this year.

Imports of the following commodities are now suspended.

live (including non-domestic) ruminants and porcine animals, including wild game and their germplasm
fresh meat from ruminants and porcine animals (including chilled and frozen), including wild game
meat products from ruminant and porcine animals that have not been subject to specific treatment D1, D, C or B (including wild game)
milk, colostrum and their products unless subject to treatment as defined in Article 4 of Regulation 2010/605
certain animal by-products.
hay and straw
casings

Further information on controls impacting the cross-border movements and trade in animal and animal products can be found at the following link:

Imports, exports and EU trade of animals and animal products: topical issues - GOV.UK

NTE 2026/06: Resolved Licence Transmission Issues with the Customs Declarations Service (CDS)

Mon, 23 Mar 2026 13:09:33 GMT

HMRC have published NTE 2026/06 which is an update to information released earlier in March confirming a communication issue between the UK Export Licencing systems LITE and SPIRE with the Customs Declaration Service, or CDS.

NTE2026/04 detailed that licence transfer issues were being experienced by the CDS, impacting customs declarations and, in some instances, causing cross-border traffic of controlled goods to stall.

NTE2026/06, published 13 March 2026, details that the issues have been resolved and that no further action should be necessary

Users are advised to make contact through official channels should they still be facing declaration or goods movement issues caused by the transmission issue

Support can be found at the following links:

Report a problem using the Customs Declaration Service

And for urgent cases, users can also email cds.operations@hmrc.gov.uk .

For general queries about strategic export licensing, contact the ECJU

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Email: exportcontrol.help@businessandtrade.gov.uk

Telephone: 020 7215 4594

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NTE 2026/05: Update to Open General Export Licence Project Typhoon

Mon, 23 Mar 2026 12:56:28 GMT

The Export Control Joint Unit (ECJU) has issued a notification of an update to the Open General Export Licence (OGEL) for Military Goods: Collaborative Project Typhoon.

Türkiye has been added to the licence as a permitted destination.

Users are reminded that exports to Türkiye are provisioned for maintenance purposes only and that appropriate compliance evidence is required to support the use of the licence for audit.

An additional condition has been added to the OGEL confirming that the licence reference must be added to a customs declaration in CDS. The licence format should be presented as follows: GBOGE 20XX/XXXXX.

The customs declaration should be filed and available for review at the ECJU audit.

A link to the OGEL can be found at the following link

Open General Export Licence (Military Goods: Collaborative Project Typhoon)

Additional note: reference licence registration requirements

Exporters are reminded of their obligation to review new releases of the OGELs they are registered for on the SPIRE system. New licence conditions should be reviewed carefully as they are subject to change.

A link to the notice can be found here:

Notice to exporters 2026/05: open general export licence (OGEL) updated - GOV.UK

Contact ECJU for General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

https://consult.defra.gov.uk/eudp-evidence-and-analysis/uk-eu-sps-agreement-call-for-information/consultation/

Telephone 020 7215 4594

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HMRC Advice for CDS Update 5.1.0 Scheduled for March 28th 2026

Mon, 23 Mar 2026 12:00:39 GMT

The upcoming CDS update version 5.1.0 is scheduled for release on the 28 ^th of March 2026.

Important note : Any pre-lodged declarations that will be affected by the changes detailed below should be changed/amended prior to the goods arriving.

If Customs declarations are not correct prior to arrival, they will be rejected.

Changes for all Movements

Previous Document Code

Previous Document Code 356 has been added for declaring the Movement Reference Number (MRN) of an Exit Summary Declaration EXS.

CDS does not mandate the Declaration on an EXS MRN, but it can be completed if necessary.

Document Codes

When completing DE 2/3 with a Document Code, the instructions in Appendix 5A must be followed.

Northern Ireland Imports: Some SPS Document Codes should be completed in the CERTEX-compatible Document ID format.

Value for Supplementary Units and Packages

When a Value is declared for Supplementary Units in DE 6/2 or Number of Packages in DE 6/10, the value declared must be equal to or greater than Zero (0).

Any value declared in DE 6/2 and DE 6/10 that is less than Zero (0) will be rejected.

Appendix 16C Maritime Ports and Wharves

The format of Appendix 16C has been updated to better identify location owners and addresses.

The codes in Appendix 16C have not changed.

Continue to use Appendix 16C to identify the correct Maritime Port or Wharf to be declared in DE 5/23 on a Declaration, as required.

Good Location Code amendments

New Goods Location Codes have been added to the CDS code list, and some codes have been deleted.

The codes that have been deleted are:

GBAUAGNLHRRRL

GBAUHAFBHXGBL

GBAUSLLLHRGBL

GBAUADGBHXMCL

GBAUHGRLTNBON

GBAUSTWFXTGRS

GBAUASFLHRIMI

GBAUHYNLIVJMI

GBAUSFDMANAPI

GBAUBGKLHRRRL

GBAULANBARWAC

GBAUSURLHRBIS

GBAUBOYSTNWAC

GBAULBALBACWG

GBAUSWBTHPSRS

GBAUBMYLBAGBL

GBAUTONEDICWG

GBAUTEFBHXWAC

GBAUBRAFXTAMS

GBAULYNDOGSSW

GBAUTFDFXTARR

GBAUBRAFXTLOX

GBAUME5LGWBMI

GBAUTLGSTNFOX

GBAUBRAFXTSHW

GBAUMLLFXTEGI

GBAUUDDGLWAPI

GBAUBSHNHVGBL

GBAUMLLFXTPFS

GBAUUXBLHRAGS

GBAUCLTAVOGBL

GBAUPYALHRCTL

GBAUWACLONWAC

GBAUCWMCDFFOX

GBAUPYALHRSFR

GBAUWAFLTNERL

GBAUDFDTHPBON

GBAUPCUEDIBIS

GBAUWBYLHRAPI

GBAUENFLSACWG

GBAUPESNHVRWL

GBAUWBYLHREIM

GBAUENFLSADOL

GBAUPMEPTMWAC

GBAUWBYLHRPIC

GBAUFBOLHRWAC

GBAURDDBHXRRL

GBAUWNESTNWAC

GBAUGTMIMMFNW

GBAURMFLONGCC

GBAUWIHLONGRS

GBAUGFRLHRSMS

GBAURUILHRCWG

GBAUWOHCVTEGI

GBAUHHELTNJMI

Changes for Import and Export movements

Amendment of Document Codes

When either Document Code U117 or Y146 are declared in DE 2/3 at the item level, a Document ID must be declared.

Document codes

Document Codes N356, Y320, Y321, Y322, and Y500 have been added to the CDS Code list.

Changes for Inventory Imports/Exports

Additional Procedure Codes 19Z, 21G, 23A, 24S, 25D, and 26D

Declaration Categories: C21E & C21I

Additional Declaration Types: C, F,

Important information regarding Additional Procedure Codes where prohibitions or restrictions apply to a commodity code declared in DE 6/14-DE 6/15

When declaring Additional Procedure Codes: 19Z, 21G, 23A, 24S, 25D, 26D in DE 1/11, any Commodity code declared in DE 6/14 – DE 6/15 must not be subject to any prohibitions or restrictions.

If Additional Procedure Codes 19Z, 21G, 23A,24S,25D,26D are entered in DE 1/11, and Commodity code declared in DE 6/14 – DE 6/15 are subject to prohibitions or restrictions, the Declaration will be rejected.

Further detailed information on Additional Procedure Codes

If any of Additional Procedure Codes 19Z, 21G, 23A, 24S, 25D, 26D are declared in DE 1/11 on a CCR then DE 2/3 must not contain any of the following codes:

9104, 9105, 9106, 9107, 9108, 9005, 9100, 9101, 9102, 9103, 9111, 9112, 9113, 9114, 9115, 9116, 9118, 9119, 9120, C001, C034, C056, C085, C635, C638, C639, C640, C641, C656, C670, C673, C678, C690, I004, L001, L079, L100, L116, N002, N851, N853, X001, X002, Y915

Import Declaration Update

Country of Origin and Country of Preferential Origin

When making a Declaration in which DE 4/17 has been completed with a Value that does not belong to the 100-series, DE 5/16 must also be completed with the Country of Preferential Origin.

When DE 5/16 is declared with a Country of Preferential Origin, DE 5/15 must also be declared with the Country of Origin, even if the Country codes declared are identical.

If DE 4/17 has been completed with a Preference code that is not in the 100-series and DE 5/16 is declared, but DE 5/15 is not completed, the Declaration will be rejected.

The Declaration will also be rejected if DE 5/16 has not been completed, if a non-100-series Preference code is declared in DE 4/17.

Container Code on I1 B&E

When making an I1 B&E Declaration, DE 7/2 must be completed to indicate whether the goods are shipped by container or are non-containerised.

If goods shipped by containers are not declared at the header level in DE 7/2, the Declaration will be rejected.

Additional Information Code

A new Additional Information (AI) Code

AI Code – “VLDIS” has been added to the CDS Code list.

This should only be used when instructed by HMRC.

Country of Dispatch

Declaration Categories: H1, H2, H3, H4, H5, I1 B&E

Additional Declaration Types: A, B, D, E, Y, Z

When a Country of Dispatch is declared in DE 5/14 at either the header level or the item level, and AI code NIDOM is declared in DE 2/2, then the Country of Dispatch declared in DE 5/14 must be one of the following: GB, IM, ZU.

If a Country of Dispatch is not GB, IM, or ZU while declaring AI Code ‘NIDOM’ in DE 2/2, the Declaration will be rejected.

Additional Code X399 and Excise Tax Type 399.

X399 and Excise Tax Type 399 are to be used for cooking alcohols with an alcohol strength of 5% or less.

Where the Additional Code X399 and Excise Tax Type 399 have been declared, then no Excise Duty will be charged on that Goods item.

Simplified Declaration Procedures

Affected Declaration Types: C, F, J, K, Y, Z

When using Simplified Declaration Procedures (SDP) Regular Use or Entry in Declarant’s Records (EIDR), the DUCR must be entered in DE 2/1 at the header level.

If the DUCR is not entered in DE 2/1 at the header level on a Declaration using Simplified Declaration Procedures (SDP) Regular Use or Entry in Declarant’s Records (EIDR), the Declaration will be rejected.

Known Difference KD154 has been withdrawn.

Duplicated VAT on Postponed VAT Accounting (PVA) Statements

When making a claim to Quota and using Postponed VAT Accounting (PVA), duplicate VAT lines should no longer appear under certain Declaration conditions.

Therefore, any manual workarounds to adjust the VAT return due to these duplicated PVA lines are no longer needed.

PVA statements should continue to be saved as evidence in the normal way for VAT purposes

Definitive Anti-Dumping Duty (ADD) and Countervailing Duty (CVD).

A manual C285 repayment request to HMRC is no longer required for provisional Anti-Dumping Duty (ADD) or Countervailing Duty (CVD).

Continue to declare provisional ADD/CVD as usual - CDS will now confirm definitive outcomes.

It is advised that this information be communicated to finance teams, as HMRC repayments linked to ADD/CVD outcomes will be processed automatically through CDS in the future, rather than under ex gratia arrangements.

Preferential Quota Claims

Error Message: CDS returns the following error: CDS40010 – Data element value does not apply.

This error message will be displayed when a trader submits an Import Declaration that includes different Country code values in both DE 5/15 and DE 5/16, where the trader wants to claim a UK First-Come, First-Served (UKFCFS) quota, and the declaration is subsequently rejected.

The following workaround may be used until this issue is resolved:

If the Preferential quota being claimed is for EU goods:

DE 5/15 and DE 5/16 should be completed with the same Country code for the Country of Preferential Origin.

Both DEs should be completed with the member state's country code. Country Code ‘EU’ should not be declared.

This issue will be resolved in CDS Release 5.2.0, with an expected delivery date of June 2026.

Excise Additional Codes in the X3 series (excluding X399)

Applicable Excise Additional Codes: X321, X322, X323, X324, X331, X333, X334, X335, X341, X343, X344. X345, X366, X367, X368, X369

When declaring one of the above in DE 6/16 or DE 6/17, Measurement Unit Code ‘ASV’ must also be declared in DE 4/4.

Should ASV not be completed with the measurement unit code ‘ASV ’, the Declaration will be rejected.

Export Declaration Update

Amendment to Document Code

Document Code Y229 must only be used on an Export Declaration.

If Document Code Y229 is used on an Import Declaration, the Declaration will be rejected.

Document code 9229 should be used on an Import Declaration

See Appendix 5A for full completion instructions for these codes.

Country Group Code

Country Group Codes should not be declared on an Export Declaration.

If a Country Group Code is declared on an Export Declaration, the Declaration will be rejected.

Commodity Codes

Transfer of Residence Relief (ToR):

Commodity Codes 99050000 and 99190000 may only be used on Import declarations when applying for Transfer of Residence (ToR) relief, and prior authorisation is required from HMRC.

Commodity Codes 99050000 or 99190000 must not be declared in DE 6/14 for Export declarations, as this will cause the declaration to be rejected.

UK Businesses Encouraged to Take Simple Steps for Smoother Trade with the EU

Mon, 09 Mar 2026 14:22:48 GMT

As the UK and EU progress toward a new Sanitary and Phytosanitary (SPS) agreement, businesses across the agri-food, manufacturing, and wider supply chain landscape face a pivotal moment. Understanding what lies ahead and preparing early will be essential for businesses that want to remain competitive, compliant, and resilient.

Background and Overview

On 19 May 2025, the UK government and the European Union (EU) agreed to pursue a new Sanitary and Phytosanitary (SPS) agreement. This, together with the Windsor Framework, was designed to make it easier, cheaper, and more predictable for goods to move not just between the UK and the EU, but also within the UK itself, including smoother movements from Great Britain to Northern Ireland.

The agreement covers a broad scope of regulatory areas, including:

Trade, production, and movement of plants, animals, and related products
Food and feed safety
Nutrition-related regulations (e.g., supplements, fortified foods, compositional standards)
Wider agrifood rules (labelling, marketing standards, organics)
Regulation of pesticides and biocides

This step represents a significant shift toward reducing friction for agri-food businesses and enhancing opportunities for both domestic and international trade.

Benefits

It was set out today (Monday 9 March) how UK exporters and importers are expected to benefit from the new Sanitary and Phytosanitary (SPS) agreement as the government negotiates to make trade with the UK’s biggest market and closest neighbour easier, cheaper, and quicker.

These changes will deliver practical benefits for businesses and consumers:

Businesses will save money .
Trade will flow faster
New markets will be unlocked .

Many small and medium-sized businesses stand to gain from this agreement. For example, the costs of paperwork and certification have hit smaller businesses hardest, with many abandoning EU trade entirely because the complexity and cost of completing the paperwork and formalities were onerous and outweighed the benefits.

The deal is also designed to create new opportunities for those businesses that import food products for processing or wholesale before selling them on.

Businesses will benefit from a simpler, cheaper process for moving most agrifood goods between Great Britain and Northern Ireland, protecting consumer choice in Northern Ireland and strengthening the UK internal market.

The scheme is designed to free British food and farming businesses from the mountains of paperwork, unnecessary delays, and spiralling costs of current arrangements; cut red tape; open opportunities for growth for large and small importers and exporters across the country; and help put British produce back on the European market.

More great British produce will be on European tables thanks to this agreement, which will reduce barriers for exporters and create new opportunities for farmers and businesses across all parts of the UK.

Timeline

The government is working toward a mid-2027 start date for the new agreement and is aiming to finalise negotiations on smoother trade and secure the best deal for UK businesses later this year . The government wants businesses in the agri-food sector to start getting ready now. This includes those that do not currently trade with the EU.

While negotiations remain ongoing, businesses are being encouraged to take early steps to prepare for the changes ahead.

Businesses should continue to follow the current trading requirements until any new agreement takes effect. This includes continued compliance with the Windsor Framework until the agreement removes the need for it.

Benefits

Costs expected to be removed:

Export Health Certificates cost up to £200 for agri-food goods
Phytosanitary Certificates cost approximately £25 alongside inspection fees of at least £127.60
Organic Certificates of Inspection, required for the export of organic lamb and cheese, cost on average £35
Identity check fees on meat and dairy exports add £31 per load on average
Sampling can add approximately £1,200 to a cheese load, £1,400 to a salmon shipment, £440 to a load of apples, and £1,200 to a beef load

Costs are expected to be reduced

For beef and salmon, queueing times for checks can add costs of up to £149 per load
Additional driver charges, paid to hauliers for border-related friction, are typically £200 per shipment

Under the deal, the government has committed UK businesses involved in the production or processing of plants, food, animals, and animal products to align with EU rules. This applies to domestic producers and those trading with the rest of the world, meaning businesses that do not currently export may also need to adapt their practices.

What businesses can do now?

While negotiations continue, businesses can take practical steps to get ready:

Engage with their relevant trade body or industry association : They will be key partners in providing sector-specific guidance, and many are already working with government to help members prepare.
Engage with your supply chain: Understand any changes that may affect them.
Sign up for Defra email alerts for regular updates : To receive the latest information on negotiations, implementation timelines, and details of guidance and support available.
Respond to the Call for Information : And share views on what support their business needs to prepare.

Detailed guidance will be published as negotiations progress to ensure businesses – from farmers and processors to retailers and hauliers – are ready to benefit from day one.

Call for information

To help with preparations, the government has today launched a six-week Call for Information to understand how best to support businesses to make the most of this opportunity. Details of this and a link to participate can be found via the link below

The government is keen to hear when and what support might be useful, so that businesses large and small, whether they currently trade with the EU or not, can be ready. The link to the call for information is as follows:

This Call for Information will run for 6 weeks, opening on 9 ^th March 2026 and closing on 23 ^rd April 2026.

Knowledge or Suspicion: A Case Study in Export Control Due Diligence

Mon, 09 Mar 2026 13:53:39 GMT

This case study highlights how minor design changes and informal project updates can reveal significant export control risks when not fully examined through a structured due diligence process. A subtle design change and an off‑hand comment during a routine project meeting may seem insignificant until they expose hidden risks that could compromise export control compliance.

Background

This UK business has been exporting its UK-manufactured components to an aircraft manufacturer in Italy for years, with the Italian manufacturer integrating the UK-supplied goods into aircraft parts for a known commercial aircraft end use. The goods are classified as dual-use, and an Open General Export Licence for dual-use goods supports their exports. Contracts for new deliveries have followed one after the other, but something has changed.

The customer has requested slight design changes. The Italian manufacturer has supplied updated, unclassified drawings, and the goods have been built to print in the UK. But something is off.

The request for minimal design change was agreed upon at the commercial level in the last contract amendment, with support from the engineering and manufacturing leads.

The design changes are slight, there will be minimal disruption to the UK manufacturing schedule, and the customer is well known. The required contract acceptance process for due diligence to end use was completed when the contracts were first contracted; the contracts are well established, and the supply route is well known.

The trade compliance manager questioned the design change as manufactured goods moved to supply; the inventory system flagged a design change to components for Italy, end use Italy. She asked about the purpose of the design changes; the trade compliance due diligence process has made it necessary to classify the new component before the goods are prepared for export.

What changed, and why?

The business holds monthly trade compliance briefings, a catch-up with the commercial, procurement, manufacturing, finance, trade compliance and logistics teams.

This forum has historically proven useful for the project managers to catch up on any business risks to their individual projects.

It was the project manager for the business supply for Project Typhoon who flagged a potential change in the supply route. A project manager at the Italian business mentioned, in passing, the potential supply of their Italian aircraft components to the Middle East.

A business opportunity had opened up 18 months before, a new sales opportunity for the Italian business. They had recently commenced supplying spares for Project Typhoon in Germany; the Middle East was a game-changer for the Italian business.

Since this could only be good news for the UK manufacturer, the project manager mentioned the conversation at the next monthly trade compliance meeting.

This information, coupled with a request for a manufacturing design change in the supplied goods, raised the following due diligence questions from the trade compliance team:

Had anyone documented the reasoning behind the design change for trade compliance purposes, and had the information been recorded, or had the supply documentation been updated?
The inventory system was programmed to raise a trade compliance flag to a design change, but due diligence to end use should be part of any contract amendment process. This had been missed.

Had anyone been told officially that the end use of the original supply of goods was now Germany, not just Italy, and that the ultimate end use may now include Middle Eastern countries in the future?
Any change to end-use supply could influence compliance with UK export licences.
The original component classification is dual use. Any change to this component or change to the end use could alter both the tariff classification and impact on export licence provision.

The importance of good team communication and the application of due diligence

The trade compliance lead raised a business risk flag to all senior business leads. This resulted in the following:

The commercial lead took urgent action to communicate the due diligence requirement to the procurement lead at the Italian company. This was to confirm any change to the reason for supply and alteration in the ultimate end use of UK-supplied goods, even after incorporation in Italy.
An updated due diligence document was completed by the Italian customer, confirming.
The original supply design would continue to be Italian, with German end use added going forward.
The supply of components with the altered design would be to support the maintenance of Typhoon aircraft in the Middle East from now on.
The changes to end use were captured on the inventory system
The updated design of the component for military end use caused a reclassification of the item to Military Goods, and an application was submitted for a UK export licence (OGEL, Military Goods: Collaborative Project Typhoon) to cover the ultimate end use of the goods supplied to Italy
The conditions of the licence require confirmation that the supply of goods for end use in Kuwait, Qatar and Saudi Arabia is for maintenance purposes only, and evidence to support this, whether goods incorporated or not, must be on file for audit

Best practice is to ensure good communication across all areas of an export business, whether verbal in regular comms meetings or electronic via inventory system alerts.

In this instance, end-use and design-change flags built into the inventory system alerted the trade compliance team to potential reclassification requirements and end-use issues.

The business is reviewing the due diligence process.

Update to HMRC Guidance Page for the Get Customs Data for Import and Export Reports

Mon, 09 Mar 2026 12:35:54 GMT

HMRC have updated the guidance page detailing the Get Customs Data for Import and Export reports, now available free of charge for download from the CDS (Customs Declaration Service).

The reports are replacing the Management Support System (MSS) reports used by businesses to verify that imports and exports have been appropriately declared on the CDS. The MSS reports were previously available only by subscription .

The new reports have been in development for some time, with new functions added on 5th February and a further update due on 1 ^st April to add XI EORI data.

What has changed

The reports have been updated to address declaration detail and some formatting concerns raised by users.

The update on February 5 ^th includes the following changes:

412 order and name changes across the four reports.
15 new fields in three reports (detailed in Appendix A below).
Reports are now produced using the date of clearance for their start and end dates instead of the date of entry . This aligns with the MSS paid service.
The import item report now displays the declaration-level country of origin when it is not specified in the search criteria. This update was also applied to the newly added invoice currency, which previously only showed the declaration-level currency in the old reports.

Appendix A: New fields added from 5 February 2026:

XI EORI Data

The Service has been updated to allow users to run reports that include XI EORI data. This addresses a gap in the service, allowing users to view all their EORI data reports through the Get Customs Data for Import and Export Declarations Service.

A link to the updated guidance page can be found here:

Get customs data for import and export declarations - GOV.UK

NCTS Downtime Planned Between 20:00-22:00hrs 10th March 2026

Wed, 04 Mar 2026 15:16:25 GMT

HMRC have advised of planned downtime for the New Computerised Transit System (NCTS), scheduled for Tuesday, 10 ^th March 2026.

The NCTS will be affected as follows:

Tuesday 10 ^th March 2026 20:00 – 22:00 hrs:

NCTS XI will be unavailable between 20.00 – 21.00 hrs

NCTS GB will be unavailable between 21.00 – 22.00 hrs

NCTS GB and NCTS XI data submitted during the affected time period will be held and processed once the maintenance activity is complete and the service returns to normal operation.

NCTS service availability can be found at the link below:

NCTS service availability page

NTE 2026/04: Licence Transmission Issues Between LITE/SPIRE and CDS

Wed, 04 Mar 2026 14:59:47 GMT

The Department for Business and Trade has issued Notice to Exporters 2026/04, published 27th February 2026, confirming communication issues between the two export licencing systems, LITE and SPIRE, with the Customs Declaration Service (CDS) database . Published 27 ^th February 2026. The communication issue has resulted in export licence information being missing from the CDS.

Summary

If you experience a problem whilst submitting a declaration, please use the link to

Report the problem to CDS .

The DBT has confirmed its awareness of an ongoing issue affecting the transmission of export licences from LITE and SPIRE to HMRC’s Customs Declaration Service (CDS), resulting in controlled goods stalling at the border because essential licence data is missing from the CDS database.

The DBT has advised that a resolution to the issue is being investigated as a matter of urgency. In the meantime, if goods stall at the border or there are any issues with the ability to present licences at the border, businesses are asked to report the problem using the following link:

Report a problem using the Customs Declaration Service - GOV.UK

Urgent enquiries should be addressed to the following email address: cds.operations@hmrc.gov.uk , including the following information:

What type of organisation is reporting the problem
Business name of the agent or agency
contact name and number
Your email address to reply to
Business name of the trader
What type of problem are you encountering
imports or exports
What type of goods
If the goods are stuck at the border

Contact ECJU for General queries about strategic export licensing at the following address:

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Federal Register:: Imposing a Temporary Import Surcharge To Address Fundamental International Payments Problems

Telephone 020 7215 4594

Subscribe to notices to exporters

The Foreign, Commonwealth and Development Office Adds 300 New Targets to the Russian Sanction List

Fri, 27 Feb 2026 14:58:05 GMT

The Foreign, Commonwealth and Development Office have published a list of 300 additional Russian-sanctioned targets . The list was published on 24 ^th February, and the UK Sanctions List has been duly updated.

A press release from the FCDO states that nearly 300 newly sanctioned parties, mainly those involved in trade in oil, have been added to the UK Sanctions list .

The action for UK businesses is to review the updated lists and take any necessary action. It is also important to consider the risk of diversion of commodities supporting the sanctioned trade industries.

The additional sanctioned targets are aimed at further restricting Russian energy revenues, the export and movement of oil, and the supply of key military equipment . The impact on Russian revenues is intended to hamper funding for the war against Ukraine.

Over half of the additions to the UK Sanctions List are those involved in the trade and movement of Russian oil, including PJSC Transneft, one of the world’s largest oil pipeline companies . The business facilitates the export of over 80% of Russian oil.

The new measures are also aimed at Russian illicit oil traders, adding 175 companies in the ‘2Rivers’ oil network, which is one of the largest shadow fleet operators globally and a major trader of Russian crude oil.

Other measures include restrictions on the supply of technology and commodities used directly in the war with Ukraine, restrictions on Russian nuclear installations overseas that could generate future revenue, and restrictions on the Liquefied Natural Gas industry.

The updated UK Sanctions List can be found here: UK Sanctions List.

A full list of additional Russian sanctions targets published on 24 ^th February 2026 is available here.

Foreign Secretary Yvette Cooper said:

“Russia is now four years into what Putin believed would be a three-day invasion. As the Kremlin continues its barbaric assault against innocent civilians that have suffered their most brutal winter in a decade, the courage and determination of the Ukrainian people endures.

The UK has today taken decisive action to disrupt the critical financing, military equipment and revenue streams that sustain Russia’s aggression, in our largest raft of measures since the early months of the invasion.

Today I’m in Kyiv announcing £30 million in funding to strengthen Ukrainian energy resilience and support recovery, taking the total UK support to £21.8 billion since the start of the war.

We will continue to stand with the people of Ukraine and defend European security - Ukraine’s security is our security.”

Full Press Release - https://www.gov.uk/government/news/uk-announces-biggest-sanctions-package-against-russia-four-yearson-from-full-scale-invasionof-ukraine

US Tariffs Changes - Update

Thu, 26 Feb 2026 14:11:03 GMT

On February 20 ^th 2026, the United States Supreme Court found President Donald Trump’s imposed IEEPA tariffs to be unlawful. The Court ruled 6–3 that the President had exceeded his legal authority under the International Emergency Economic Powers Act (IEEPA).

Following the Supreme Court's decision, President Trump issued Proclamation 11012.

This proclamation outlined the following: Under section 122 of the Trade Act of 1974, the President is to implement an additional 10% ad valorum rate for a period of 150 days. This applies to imported articles of every country for a period of 150 days, unless specifically exempt.

When does this apply?

This 10% ad valorem rate has been implemented for imports from any country for which the goods are entered for consumption or withdrawn from the warehouse for consumption. This is on or after 12:01 a.m. Eastern Standard Time on the 24 ^th of February 2026, and through to 12:01 a.m. Eastern Daylight Time on the 24 ^th of July 2026.

What about exclusions?

There are, however, some exemptions to this; section 232 goods are excluded, as are a number of the following items:

Certain critical minerals.
Metals used in currency and bullion.
Energy and energy products.
Natural resources and fertilisers that cannot be grown, mined, or otherwise produced in the United States or grown, mined, or otherwise produced in sufficient quantities to meet domestic demand.
Certain agricultural products, including beef, tomatoes, and oranges.
Pharmaceuticals and pharmaceutical ingredients.
Certain electronics.
Passenger vehicles, certain light trucks, certain medium- and heavy-duty vehicles, buses, and certain parts of passenger vehicles, light trucks, medium- and heavy-duty vehicles, and buses.
Certain aerospace products.
Information materials, donations, and accompanied baggage.
All articles and parts of articles currently or that later become subject to additional import restrictions imposed pursuant to section 232 of the Trade Expansion Act of 1962, as amended ( 19 U.S.C. 1862 ) (section 232).
Articles that are entered free of duty as a good of Canada or Mexico under the terms of general note 11 to the Harmonized Tariff Schedule of the United States (HTSUS), including any treatment outlined in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTSUS, as related to the Agreement between the United States of America, United Mexican States, and Canada.
Textile and apparel articles that are entered free of duty as a good of Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua under the Dominican Republic-Central America Free Trade Agreement.

What Happens Next?

For UK exporters, it is necessary to determine how we are affected and if our goods are affected by the changes.

Where can we find the information from? The ‘Check how to export’ webpage can help you understand the duty rates, clearly showing the MFN rate and the additional 10% if applicable. - Check how to export goods - GOV.UK

You will, however, need to know the Commodity Code at the time of import into the United States, so please speak with your customers.

What about refunds? You may ask. There is always the possibility of refunds for businesses that have paid tariffs under IEEPA—potentially over $175 billion.

There could also be more changes for the US administration to use other statutory powers, such as Section 301 or changing the Section 232 tariffs, which are already in place.

CDS Update 5.1.0

Wed, 25 Feb 2026 11:36:33 GMT

The upcoming CDS update, version 5.1.0, is scheduled for release on the 28 ^th March 2026.

During this period, please note that any pre-lodged declarations that will be affected by the changes should be changed/amended prior to the goods arriving.

If customs declarations are not corrected before arrival, they will be rejected.

Changes for all movements

Previous Document Code

Previous Document Code 356 has been added for declaring the Movement Reference Number MRN of an Exit Summary Declaration EXS.

CDS does not mandate the declaration on an EXS MRN, but it can be completed when appropriate.

Document Codes

When completing DE 2/3 with a Document Code, the instructions in Appendix 5A must be followed accordingly.

Northern Ireland Imports certain SPS Document Codes should be completed with the CERTEX-compatible Document ID format.

Value for Supplementary Units and Packages

When a value is declared for Supplementary Units in DE 6/2 or Number of Packages in DE 6/10, the values declared must be equal to or greater than Zero (0).

Any value declared in DE 6/2 and DE 6/10 that is less than Zero (0) will be rejected.

Appendix 16C Maritime Ports and Wharves

The format of Appendix 16C has been updated to identify location owners and addresses better. The codes in Appendix 16C have not changed.

Please continue to use Appendix 16C to identify the correct Maritime Port or Wharf to be declared in DE 5/23 on a declaration, as required.

Good Location Code amendments

New Goods Location Codes have been added to the CDS code list, and some codes have been deleted.

The codes that have been deleted are:

GBAUAGNLHRRRL

GBAUHAFBHXGBL

GBAUSLLLHRGBL

GBAUADGBHXMCL

GBAUHGRLTNBON

GBAUSTWFXTGRS

GBAUASFLHRIMI

GBAUHYNLIVJMI

GBAUSFDMANAPI

GBAUBGKLHRRRL

GBAULANBARWAC

GBAUSURLHRBIS

GBAUBOYSTNWAC

GBAULBALBACWG

GBAUSWBTHPSRS

GBAUBMYLBAGBL

GBAUTONEDICWG

GBAUTEFBHXWAC

GBAUBRAFXTAMS

GBAULYNDOGSSW

GBAUTFDFXTARR

GBAUBRAFXTLOX

GBAUME5LGWBMI

GBAUTLGSTNFOX

GBAUBRAFXTSHW

GBAUMLLFXTEGI

GBAUUDDGLWAPI

GBAUBSHNHVGBL

GBAUMLLFXTPFS

GBAUUXBLHRAGS

GBAUCLTAVOGBL

GBAUPYALHRCTL

GBAUWACLONWAC

GBAUCWMCDFFOX

GBAUPYALHRSFR

GBAUWAFLTNERL

GBAUDFDTHPBON

GBAUPCUEDIBIS

GBAUWBYLHRAPI

GBAUENFLSACWG

GBAUPESNHVRWL

GBAUWBYLHREIM

GBAUENFLSADOL

GBAUPMEPTMWAC

GBAUWBYLHRPIC

GBAUFBOLHRWAC

GBAURDDBHXRRL

GBAUWNESTNWAC

GBAUGTMIMMFNW

GBAURMFLONGCC

GBAUWIHLONGRS

GBAUGFRLHRSMS

GBAURUILHRCWG

GBAUWOHCVTEGI

GBAUHHELTNJMI

Changes for IMPORT and Export movements

Amendment of Document Codes

When either of the Document Code U117 and Y146 is declared in DE 2/3 at the item level, a Document ID must be declared.

Document codes

Document Codes N356, Y320, Y321, Y322, and Y500 have been added to the CDS Code list.

Changes for Inventory Imports/Exports

Additional Procedure Codes 19Z, 21G, 23A, 24S, 25D, and 26D

Declaration Categories: C21E & C21I

Additional Declaration Types: C, F, ’

When declaring either of Additional Procedure Codes 19Z, 21G, 23A, 24S, 25D, 26D in DE 1/11, any Commodity code declared in DE 6/14 – DE 6/15 must not be subject to any prohibitions or restrictions.

If any of the Additional Procedure Codes 19Z, 21G, 23A,24S,25D,26D are entered in DE 1/11, and the Commodity code declared in DE 6/14 – DE 6/15 are subject to prohibitions or restrictions, the declaration will be rejected.

If any of Additional Procedure Codes 19Z, 21G, 23A, 24S, 25D, 26D are declared in DE 1/11 on a CCR then DE 2/3 must not contain any of the following codes:

9104, 9105, 9106, 9107, 9108, 9005, 9100, 9101, 9102, 9103, 9111, 9112, 9113, 9114, 9115, 9116, 9118, 9119,9120,C001,C034, C056, C085, C635, C638, C639, C640, C641, C656, C670, C673, C678, C690,I004, L001, L079, L100, L116, N002,N851, N853, X001,X002 ,Y915

IMPORT DECLARATION UPDATE

Country of Origin and Country of Preferential Origin

When making a declaration in which DE 4/17 has been completed with a value that does not belong to the 100-series, then DE 5/16 must also be completed with the Country of Preferential Origin.

When DE 5/16 is declared with a country of Preferential Origin, DE 5/15 must also be declared with the Country of Origin, even when the Country Codes declared are identical.

If DE 4/17 has been completed with a preference code that is not in the 100-series and DE 5/16 is declared, but DE 5/15 is not completed, the declaration will be rejected.

The declaration will also be rejected if DE 5/16 has not been completed when a non-100-series preference code is declared in DE 4/17.

When DE 4/17 has been completed with a Preference Code in the 100-series, DE 5/16 should not be completed, or the declaration will be rejected.

Container Code on I1 B&E

When making an I1 B&E Declaration, DE 7/2 must be completed to indicate whether the goods are shipped by container or non-containerised.

If goods shipped by containers are not declared at the header level in DE 7/2, the Declaration will be rejected.

Additional Information Code

A new Additional Information (AI) Code

AI Code – “VLDIS” has been added to the CDS Code list.

This should only be used when instructed by HMRC.

Country of Dispatch

Declaration Categories : H1, H2, H3, H4, H5, I1 B&E

Additional Declaration Types: A, B, D, E, Y, Z

When declaring a Country of Dispatch in DE 5/14 at either the header or item level, and AI code NIDOM is declared in DE 2/2, the Country of Dispatch must be GB, IM, or ZU.

If a Country of Dispatch that is not one of either GB, IM, or ZU while declaring AI Code ‘NIDOM’ in DE 2/2, the declaration will be rejected.

Additional Code X399 and Excise Tax Type 399.

Additional Code X399 and Excise Tax Type 399 have been added to CDS.

These Codes are to be used with cooking Alcohols with an alcohol strength equal to or less than 5%.

Where the Additional Code X399 and Excise Tax Type 399 have been declared, no Excise Duty will be charged on that Goods item.

When Additional Code X399 and Excise Tax Type 399 are declared, DE 4/4 must also be completed with the Alcohol Strength (ASV) value of the goods, or the declaration will be rejected.

Please see the Integrated Online Tariff for Commodity codes eligible to use Additional Code X399 and Excise Tax Type 399.

Simplified Declaration Procedures

Affected Declaration Types: C, F, J, K, Y, Z

When using Simplified Declaration Procedures SDP Regular Use or Entry in Declarant’s Records EIDR, the DUCR must be entered in DE 2/1 at the header level.

If the DUCR is not entered in DE 2/1 at the header level on a declaration using Simplified Declaration Procedures (SDP) Regular Use or Entry in Declarant’s Records (EIDR), the declaration will be rejected.

Known Difference KD154 has been withdrawn.

Duplicated VAT on Postponed VAT Accounting (PVA) Statements

When making a claim to Quota and using Postponed VAT Accounting (PVA), duplicate VAT lines that previously appeared under certain declaration conditions will no longer occur.

Any manual workarounds to adjust your VAT return due to duplicated PVA lines are no longer needed.

You should continue to store your PVA statements as evidence for VAT purposes in the normal way.

Definitive Anti-Dumping Duty (ADD) and Countervailing Duty (CVD).

A manual C285 repayment request to HMRC is no longer required for provisional Anti-Dumping Duty (ADD) or Countervailing Duty (CVD).

Continue to declare provisional ADD/CVD as usual - CDS will now provide a confirmation of definitive outcomes.

Please ensure your finance teams understand that HMRC repayments linked to ADD/CVD outcomes will be processed automatically through CDS rather than via ex gratia arrangements.

EXPORT DECLARATION UPDATE

Amendment to Document Code

Document Code Y229 must only be used on an Export Declaration.

If Document Code Y229 is used on an Import Declaration, the Declaration will be rejected.

On an Import Declaration, use Document code 9229 instead.

Please see Appendix 5A for full completion instructions for these codes.

Country Group Code

Country Group Codes should not be declared on an Export Declaration.

If a Country Group Code is declared on an Export Declaration, the Declaration will be rejected.

Commodity Codes

Commodity Codes 99050000 and 99190000 are only to be used on Import declarations. To use these codes, you must seek authorisation from HMRC.

When completing an Export Declaration, Commodity Codes 99050000 or 99190000 must not be declared in DE 6/14.

If either of the Commodity Codes 99050000 or 99190000 is declared on an Export Declaration, the declaration will be rejected.

NTE 2026/03 Company Director Jailed for Attempting Illegal Export

Mon, 23 Feb 2026 13:23:58 GMT

Highlighted in the most recent Notice to Exporters (NTE), why compliance matters. A company director has received a prison sentence after attempting to export controlled military-grade equipment without the required UK licence. The case, published in the UK government’s Notice to Exporters 2026/03 19-02-2026, highlights the seriousness with which UK authorities enforce export controls and Customs.

At Leeds Crown Court on February 6 ^th 2026, Steven Gates, 47, of Wakefield, received a 2-year and 1-month prison sentence after being convicted under the Customs and Excise Management Act 1979 for trying to export eight thermal imaging rifle sights — classified as military equipment — to Hong Kong without authorisation.

HM Revenue & Customs (HMRC) investigators found that Gates had misdescribed the goods as “low-value cameras” on export documentation to disguise their true nature and evade licensing requirements. Border Force officers intercepted the shipments at Manchester Airport in two separate seizures in February 2022 and April 2023, and a subsequent search of his home uncovered evidence of further unlicensed shipments.

In announcing the sentence, HMRC officials emphasised that this was a deliberate attempt to bypass the UK’s strict export controls. “Anyone seeking to export military items without a licence will be detected and brought to justice,” said a senior enforcement representative.

This case is a clear demonstration that intent is a central factor in export control prosecutions. Actively concealing the true nature of the goods and attempting to avoid the regulations is very different from a trader making an error or being unaware that the goods require a licence, although both are major non-compliances . Export control and Customs compliance are not limited to the most serious or obvious cases, such as military hardware or sending goods to sanctioned destinations. They encompass a broad range of regulatory requirements, including:

Export licensing regimes (strategic, dual-use and military lists)
Customs and trade declarations
Complying with the three pillars of Customs compliance - Tariff Classification, Origin and Valuation law
End-use and end-user obligations
Sanctions and trade restriction rules

Even in scenarios where goods might appear low risk, deliberately mis-declaring goods to avoid controls or misinforming authorities undermines legal frameworks designed to protect national and international security. The law treats deliberate circumvention as an aggravating factor, often resulting in heavier penalties than purely administrative mistakes.

Businesses must know their responsibilities. Not just identify whether your products fall under controlled regimes and whether a licence is required but also be transparent and accurate . And if in doubt, seek guidance early: If unsure whether a licence is needed, consult official guidance or seek a voluntary disclosure rather than risk concealment.

So be clear: intent matters. Deliberate attempts to circumvent controls, even in less serious cases, can turn an administrative breach into a criminal offence.

This prosecution reinforces that UK enforcement agencies are stepping up investigations and will pursue cases where there’s evidence of deliberate non-compliance. Exporters should treat compliance as an integral part of their business processes, not an optional or bureaucratic exercise.

NTE 2026/03

Military Mobility: Customs Technical Handbook Published

Mon, 23 Feb 2026 13:09:48 GMT

HMRC have published a further Technical Handbook for Military Mobility to provide comprehensive guidance for visiting military forces and the UK Ministry of Defence on the application of NATO form 302 and the UK Armed Forces Declaration process.

It provides details on the import, export, and transit of military freight using NATO Form 302, as well as guidance on the UK armed forces declaration process and associated customs procedures.

A link to the handbook can be found below:

https://www.gov.uk/guidance/guidance-on-military-mobility

Call for Evidence on Ownership and Control in Financial Sanctions Regulations

Fri, 20 Feb 2026 07:57:19 GMT

The Office of Financial Sanctions Implementation has launched a call for evidence seeking the industry’s views on how the UK financial sanctions regulations governing ownership and control are applied in practice by UK businesses.

This call for evidence is intended to illustrate how industry implements the regulations and the challenges UK businesses face in ensuring their business practices comply with them.

The basis of the concept of ownership and control regulation is to prevent sanctioned entities and individuals from being concealed behind complex corporate structures, third parties, or trusts.

UK businesses that employ due diligence on sanctioned parties as part of their day-to-day processes have indicated the increasing difficulty of identifying where a designated party may influence, control, or stand behind what appears to be a genuine business.

Evidencing sufficient due diligence into working practice creates additional costs and often legal risk.

OFSI are therefore asking UK businesses, representative bodies and other interested stakeholders to share evidence and practical examples of the following:

How often is ‘hypothetical control’ present in real financial sanctions cases
The cost impact of compliance, any legal risk and business impact decisions (including derisking)
Whether existing legal concepts and typologies of control are useful in working practice when addressing ownership and control regulations.

The collation of referenced business practice information is intended to help OFSI understand whether their current approach is clear enough, effective, and proportionate, ensuring that sanctions remain tough on those being targeted while being practicable in the workplace for those trying to run a compliant and legitimate business.

The Call for Evidence is open until 13th April 2026.

Call for evidence: A summary of the Ownership and Control Test in UK Financial Sanctions Regulations can be found at the link below:

Ownership and Control Test in UK Financial Sanctions Regulations - GOV.UK

A link to the HMG Call to Evidence Page itself can be found here:

Executive Summary Page 1 of 6 | Call for evidence on ownership and control in financial sanctions regulations

A link to the full information on the reasoning behind the call for evidence can be found on the OFSI blog, link below:

Call for evidence on ownership and control in financial sanctions regulations – Office of Financial Sanctions Implementation

ECJU Announces Export Control Webinars for 2026

Thu, 19 Feb 2026 07:10:16 GMT

On Monday, 9 ^th February 2026, the Department of Business and Trade, Export Control Joint Unit announced a series of webinars to be held between March and May to “address important topics to help you navigate the ‘Apply to export controls goods’ service, also known as LITE, Licensing for International Trade and Enterprise”.

The ECJU has provided details on the four webinars as follows.

Applying for an OIEL Open Individual Export Licence

With step-by-step guidance on the application process, this webinar will demonstrate the LITE update, which will enable OIEL applications to be submitted through the SPIRE replacement.

How to use the 'Apply to Export Controlled Goods Service': Determining Ultimate End Users

This webinar will provide “A practical guide to identifying end users vs ultimate end users in LITE, with scenario walkthroughs, a live demo, and Q&A” The content suggests alignment with the updated End User Stocking Undertaking, which was issued in September 2025, which requires information on the “export journey” that the goods on the application will take.

How to use the 'Apply to Export Controlled Goods Service ': Editing Applications

This webinar will help delegates improve their understanding of which information can and cannot be provided at different stages of licence applications. An application may be subject to an ECJU request for information or clarification based on the details provided. The webinar will provide information on how to respond to this type of query, which includes a request to edit the application. There will also be information on what constitutes a “best practice” for thoroughly reviewing applications before submission, as well as advice on when and how to withdraw an application.

How to use the 'Apply to Export Controlled Goods Service': Understand End Users, Consignees and Third Parties

Focusing on other entities that may need to be declared on the application, this webinar will address the definitions and distinctions between consignees, third parties, and additional contacts.

The webinar has been advertised as “may be best suited to users who handle complex supply chain exports involving intermediaries”.

In addition, a link has been provided for attendees to submit questions in advance of the four-hour webinars.

The ECJU webinar information states that experts from the Department of Business and Trade’s Programme Management Team, Digital Data & Technology team, and Licensing Unit will lead each session.

Details of all the webinars can be found here .

UK CBAM Secondary Legislation Consultation Period Launched

Tue, 17 Feb 2026 15:55:44 GMT

UK CBAM is set to come into force on the 1st January 2027, with the primary legislation announced in the Finance (No 2) Bill 2025 –2026. We know from the first stage of legislation that the UK CBAM will be implemented differently from its EU counterpart.

Although both carbon border adjustment mechanisms serve the same purpose, lowering carbon leakage on imports, the UK CBAM will operate as an indirect tax requiring the importer (liable persons) to complete CBAM tax returns. In contrast, the EU CBAM operates as a policy tool. Both, however, rely on the same school of thought to ensure importers pay the same costs as businesses that produce the goods domestically.

On the 10 ^th of February, the draft secondary legislation was published for a 6-week technical consultation.

If you import goods into the UK from the following sectors, you may wish to review the draft legislation and provide your feedback to the CBAM Policy team before 24th March 2026 , when the consultation period closes.

Sectoral Scope of UK CBAM

Aluminium
Cement
Fertiliser
Hydrogen
Iron and steel

Full Annex of Commodity Codes in the UK CBAM

The draft legislation focuses on the administration of UK CBAM and its various aspects as a tax, including the registration process for CBAM, CBAM tax returns, reimbursement arrangements, and record-keeping.

The open consultation link is provided below

Draft Regulations | CBAM

Vaping Products Duty and Vaping Duty Stamps: The Government Publishes Guidance on the New Duty and Excise Control Schemes Relating to Vaping Products

Fri, 13 Feb 2026 17:01:30 GMT

The UK Government is introducing two new control schemes to cover Vaping Products Duty (VPD) and Vaping Duty Stamps (VDS) .

Vaping products are subject to excise duty by virtue of being a tobacco product and have historically been treated lightly in comparison to cigarettes and other tobacco products when it comes to excise duty payable . The new schemes will introduce new vape controls into the marketplace.

Non-excise duty will also be imposed on vaping products that do not contain an excisable product .

The new schemes, both requiring HMRC authorisation to operate, come into force on 1 ^st October . Affected businesses are required to register to run the new schemes, with applications opening on 1 ^st April 2026.

Details

Vaping Products Duty will be introduced at a flat rate of £2.20 per 10ml of vaping liquid, with duty stamps on vaping products.

Vape goods for import could therefore attract 6% duty and an additional £2.20 per 10ml of liquid if the liquid is subject to excise duty.

HMRC Business Approvals Required:

From 1 ^st April 2026: Businesses will be required to apply for HMRC approval if involved in any of the following:

The manufacture of vaping products
Importing vaping products
Storage of duty-suspended vaping products

Approvals must be in place well before the Vaping Products Duty and the Vaping Duty Stamps Scheme come into effect .

Approval registration opens on 1 ^st April . With approval lead times of up to 45 days and a requirement to be in place before the end of September, HMRC is urging all affected businesses to prepare immediately to avoid potential disruption to their trading activities.

Guidance Published 10 ^th February 2026

To support the introduction of the two new schemes, HMRC have published a comprehensive Stakeholder Communication Pack on their guidance page.

The guidance and Pack can be found at the link below:

Stakeholder Communications pack .

The pack includes an HMRC YouTube video that can be found here: video , with further guidance information to be found here: www.gov.uk/vaping-duty

OFSI Update: Financial Sanctions Enforcement and Monetary Penalties Guidance

Wed, 11 Feb 2026 12:05:42 GMT

The Office of Financial Sanctions Implementation (OFSI) is part of His Majesty’s Treasury. It is responsible for enforcing financial sanctions and regularly updates guidance on how financial sanctions regulations are implemented in practice.

The Regulations

The OFSI, as part of HM Treasury, are afforded powers through the Policing and Crime Act 2017 (the ‘2017 Act’) to impose monetary penalties for breaches of financial sanctions.

The regulations can be found here:

Policing and Crime Act 2017

The Sanctions and Anti-Money Laundering Act is intended to amend the Policing and Crime Act 2017 and to ensure that the OFSI applies sanctions in a robust, fair, and effective manner. A link to the SAMLA can be found here:

Sanctions and Anti-Money Laundering Act 2018

After a consultation period, new guidance was published on 9 ^th February 2026 to provide clarity on OFSI's enforcement powers and the improvements made to the enforcement framework. The intention is to provide clarity on the implementation of OFSI obligations into working practice.

The new guidance sets out the following:

A clear explanation of the powers given to the Treasury in the 2017 Act
A summary of the OFSI compliance requirements and their approach to enforcement of the regulations
An overview of how a monetary penalty will be enforced, and what criteria will be taken into consideration
An overview of the process that is used to judge the level of monetary penalty to be imposed
An explanation of how a monetary penalty will be imposed and the relevant timescales for each stage of the process, and the rights of review and appeal.

A link to the guidance published on the 9 ^th February can be found here:

Financial sanctions enforcement and monetary penalties guidance - GOV.UK

Northern Ireland Common Health Entry Document (CHED) Completion

Tue, 10 Feb 2026 13:13:32 GMT

A CHED (Common Health Entry Document) would be required for movements that must be presented at a BCP (Border Control Post) in Northern Ireland or the European Union.

It is required for the following types of products:

Animals or Products of Animal Origin (POAO)
Plant or Plant Products
Feed and Food Products of Non-Animal Origin

The CHED document must be presented at the Border Control Post (BCP) to conduct safety and security checks. This would be a presentation alongside any other documentary requirements, such as an Export Health Certificate or Phytosanitary Certificate.

The CHED must be submitted at least 24 hours prior to arrival in NI, and the CHED reference must be included in the Customs Declaration. This is to ensure that the Customs Declaration is linked correctly to the CHED reference so the goods can clear Customs electronically.

A new reference format was introduced on the 15th of September 2025 for common health entry documents covering these movements.

Due to the new reference format now in place, it is vital to understand the requirements for declaring a CHED, given the validation process and the potential for delays at the BCP for the goods in question.

As these items may have a limited shelf life, it is important to ensure that declarants of the Common Health Entry Documents do so correctly to avoid any delay.

Whether you are registered for TRACES and submit the Common Health Entry Documents yourself or use a third party to complete them for you, you must ensure that the following is used.

Further guidance on Traces can be found here: https://webgate.ec.europa.eu/imsoc-guide/tracesnt-help/Content/en/documents-certificates/ched.html.

Non-Northern Ireland Retail Movement Scheme (NIRMS) declarations

These are pre-notified to the Trade Control and Expert System (TRACES), and the CHED reference format must include letters followed by numbers, and the 3 '.' characters.

The reference number will be provided on the TRACES NT platform. This reference is then included in DE 2/3 on CDS (Customs Declaration Service).

These are as follows, depending on the CHED type that is being used :

Document code - 'C640’ for Live Animals – CHEDA.XI.yyyy.nnnnnnn
Document code - 'C085' for Plant Products – CHEDPP.XI.yyyy.nnnnnnn
Document code - 'N853' for Products of Animal Origin – CHEDP.XI.yyyy.nnnnnnn
Document code - 'C678' for Feed and Food of Non-Animal Origin – CHEDD.XI.yyyy.nnnnnnn

This is broken down into the following:

'yyyy' represents the year the licence was issued, for example, 2026
'nnnnnnn' represents the CHED reference number, for example, 1234567
The 3 '.' characters must be included

For POAO (Products of Animal Origin), this would be displayed as:

Document code in DE 2/3 N853 followed by the CHED reference from TRACES ‘ CHEDP.XI.2026.1234567’

What about NIRMS movements?

NIRMS movements under the Northern Ireland Retail Movement Scheme from Great Britain to Northern Ireland, the CHED reference must state NIRMS.

The format under NIRMS is as follows - 'GBCHDyyyy.NIRMS'.

This is broken down into the following:

'yyyy' represents the year the movement took place
The '.' after the year must be included
For example, ‘GBCHD2026.NIRMS’

CERTEX and multiple CHED documents.

Certificates Exchange System (CERTEX) is the system that validates licences against the Customs declarations.

It cannot validate multiple CHEDs declared against a single item unless the original write-off quantities are declared against each document code.

This could potentially cause an issue with validation. For example, it would fail and show an insufficient quantity message if the mass of an item were declared as 100 kg and there were two CHEDS in place. That would be one CHED for 40 kgs and another for 60 kgs, so we must ensure that the information provided for each CHED is correct.

We must ensure the quantities and measurements are accurate so they can be validated and included in DE 2/3 in CDS.

Where to find more information

Moving licensed goods into or out of Northern Ireland

For those users of the Trader Support Service

Northern Ireland Department of Agriculture and Rural Affairs (DAERA) on 0300 200 7852 or email daera.helpline@daera-ni.gov.uk

UK Trade Tariff Changes for 2026

Tue, 03 Feb 2026 14:12:12 GMT

The UK Global Trade Tariff is updated regularly to keep up with World Customs Organisation (WCO) Harmonised System and EU Combined Nomenclature compliance changes, as well as local UK technical and operational updates, to ensure the flow of trade remains consistent with national and international regulations.

It is therefore important for trade professionals to keep up with these tariff updates to ensure trade compliance and business operations.

HMRC publish an annual tariff correlation table, intended to provide trade professionals with guidance on an impactful tariff classification change and an opportunity to consider whether any inventories or business records may need to be changed or amended.

A proactive approach is preferable to having to reverse-engineer an import declaration instruction that has been bounced by CDS and returned by the declaring agent.

The UK Tariff is also changing to reflect UK trade policy and align the UK Global Tariff with the EU TARIC. There are changes, too, including the creation, amendment, and ending of specific 8-digit UK commodity codes, some of which took effect in December last year.

In addition to EU alignment, there are changes to origin compliance statements and documentation that support the use of the preference origin.

The devil is in the details, and this detail will need to be checked before a preference claim is made or a goods classification is assumed for the affected tariff chapters.

2025–2026 Correlation Table

HMRC have issued a correlation table to help traders identify where 8-digit commodity codes may have been split, merged or completely replaced. The table publishes details for the affected commodity codes in chapters 28, 29, 38, 73, 84 and 85

A link to the table can be found below:

Mapping 2025 codes to their 2026 equivalents

Further codes that were amended or merged in December 2025 can be found at the links below

24 December 2025

31 December 2025

Further updates are expected as 2026 progresses, and traders should ensure they are registered for these updates by selecting "Get Emails About this Page" at the link below.

Tariff notices - GOV.UK

Preferential Trade and Quota Reference Data Updates

Updates have been made to a substantial amount of preferential reference data and quota measures across a wide range of UK trade agreements and arrangements.

These changes affect how preference eligibility and tariff quotas are applied in practice, even when higher-level duty rates appear unchanged.

Autonomous Tariff Quotas and Duty Suspensions

The tariff now reflects the continuation, expiry, or amendment of Autonomous Tariff Quotas (ATQs) and duty suspensions for the 2025–26 period.

Traders are therefore prompted to check where suspensions may have expired or quotas have been amended. The risk of exposure to unexpectedly higher duty rates can be greatly reduced if classification changes are reviewed in good time and a business approach to quota measures is adjusted accordingly.

Getting it right the first time is preferable to the risk of exposure to declaration amendments or rejections. However, the evolutionary approach to tariff changes this year may put trade professionals on the backfoot going forward.

The advice is to take a fresh approach to the tariff. Do not be caught out by outdated assumptions about tariff measures or changes to tariff codes. Make a note to check.

Notice to Exporters January 2026 – NTE 2026/01 and NTE 2026/02

Mon, 02 Feb 2026 11:42:00 GMT

On 29 January 2026, the Export Control Joint Unit released the first Notice to Exporters updates for 2026.

NTE 2026/01 provides a link to ECJU training sessions for 2026. Compliance and Open Licence workshops are running as half-day face-to-face events between February and April. This notice also provides details on how we can stay updated on notices and e-alert subscriptions. This information has been provided due to issues accessing export control updates in late 2025, which affected some users. A link is provided to the UK Government’s ECJU e-alert service for UK sanctions and direct strategic export controls, which will enable you to subscribe to Notice to Exporters, training, and export control requirement updates.

NTE 2026/02 relates to updated Open Licence Returns guidance. This includes an updated list of licences that require returns, a revised explanation of the information to be recorded, and guidance on how returns should be submitted on SPIRE. The notice highlights the importance of Open Licence Returns as a compliance responsibility and asks exporters to review the update to ensure they understand the exporter requirements ahead of the next cycle, which will be for exporters made in calendar year 2026.

The link to the updated guidance is available here . The list of Open Licences which require a return is listed in the guidance and can be found in Appendix I on Page 14.

The guidance provides details on the definition and types of end-users. “The ‘end user’ on Open Licence Returns is the first person/organisation using the goods (in the form that they left the source country). Therefore, the 'End User Type' relates to the nature of business of the 'End User' organisation; 'Government' or 'Commercial' unless a Private Individual ('Pvt Individual') or for academic institutions 'Other.’

January 31st was the deadline for 2025 Open Licence Returns and the last day to submit the information.

The update references “quality assurance”, advising that once an exporter has submitted their returns, the Export Control Joint Unit, Department of Business and Trade, can check the data and request an amendment to the exporter’s SPIRE administrator. If required, the administrator can reassign this role to another SPIRE user by visiting the ‘Manage My Registration’ link from the workbasket and clicking the ‘Organisation Security’ tab. The user who has been reassigned the task needs to log in to SPIRE and go to the Open Licence Returns screen via the workbasket. The icon in the ‘Info’ column will be a yellow warning triangle. By hovering over the yellow icon, you can see why the ECJU/DBT returned the return. The user can make the necessary changes to enable the return to be resubmitted on SPIRE. If a return has been made in error, the exporter can withdraw the information. This removal can be made by clicking the red cross icon in the ‘Cancel’ column. The user will need to justify returning the item to submit the cancellation in SPIRE.

Invest 2035: UK Modern Industrial Strategy

Wed, 21 Jan 2026 13:18:01 GMT

The UK launched the Modern Industrial Strategy in 2025, which aims to boost exporters by focusing on eight key growth sectors (such as Digital, Clean Energy, and Life Sciences) through targeted support, simplified regulations, improved infrastructure, and global partnerships.

In a speech on January 14th, the Business Secretary, Peter Kyle, set out the ambition to go toe-to-toe with the United States on economic growth.

The strategy focuses on eight key sectors, each with its own sector plan. The targeted sectors are:

Advanced manufacturing
Clean energy industries
Creative industries
Defence
Digital and technologies
Financial services
Life sciences
Professional and business services

The government is seeking to reduce regulatory burdens, remove trade barriers, and expand access to finance. The strategy aligns with the existing Trade Strategy to attract export-led investment.

https://www.gov.uk/government/collections/the-uks-modern-industrial-strategy-2025

The strategy seeks to achieve its goals through support mechanisms, which, with respect to exporting companies, are as follows:

UK Export Finance (UKEF): Increased capacity, a new Small Export Builder for SMEs, and streamlined support for repeat overseas orders.
Tackling Barriers: Using the new Ricardo Fund to address complex regulations and global standards.
Services Superpower: Aiming for mutual recognition of qualifications to solidify the UK's leading role in services exports.
SME Focus: Recognising the vast untapped potential in SMEs, with efforts to make exporting easier for them.
Strategic Partnerships: Deepening collaboration with nations like Japan, Norway, South Korea, and exploring opportunities with Brazil, Mexico, and the Philippines.

Industry bodies have welcomed the strategy announcement and its focus on exporting and have also provided detailed responses. The Chartered Institute of Export said that among the key challenges to exporting companies with expansion potential were access to finance and availability of skilled workers.

Exporting companies that plan to grow should expect support through the mechanisms above.

UK–India Free Trade Agreement: HMRC Registration for Preferential Origin Declarations

Tue, 20 Jan 2026 12:45:07 GMT

HMRC has now published guidance on completing and authenticating preferential origin declarations for the UK-India Free Trade Agreement. You can register with HMRC ahead of the UK-India Trade Agreement coming into force if you intend to complete origin declarations under this Free Trade Agreement.

You need to register with HMRC if both of the following apply:

You’re a UK producer or exporter exporting goods originating in the UK to India
You plan to complete preferential origin declarations under the UK-India Free Trade Agreement

You must complete the procedure each time you send goods of preferential origin to India; in effect, there is no long-term supplier declaration.

The agreement allows you to self-certify preferential origin, but only if you can supply the following details:

The Economic Operators Registration and Identification (EORI) number that HMRC have on record for your business
Your business or trading name
A primary email address and up to 10 additional email addresses (you can use any of these to send origin declarations to the Customs authority of India)

You can only register these email addresses with one EORI number to complete origin declarations under the UK-India Free Trade Agreement.

HMRC will share your details with the Indian Customs authority to authenticate each consignment exported under the Free Trade Agreement.

It is essential that if you declare preferential origin, you must hold evidence to support the claim . You should not apply for preferential origin declarations unless you have thoroughly checked that the goods meet the rules of the trade agreement.

Please also note that it’s not mandatory to apply for preferential origin declarations. You can continue to export to India without origin declarations if your goods do not qualify for preferential tariffs or you choose not to use the UK-India Free Trade Agreement.

Register Online

You’ll need to sign in to register online. If you do not already have sign-in details, you can create them.

Register now

After you’ve registered

With every consignment of goods that you send, you must complete an ‘Annex 3B: Origin Declaration Template’ and send it to both of the following:

Customs Authority of India
importer in India

From July 2026, you can also use this service to:

Change your registration details
Cancel your registration

The UK-India trade deal is not yet in force and is currently undergoing ratification in both nations. The UK and India must complete this process for the agreement to come into effect. Once ratified by both countries, businesses will be able to trade under its terms.

2025 Export Control Highlights – Notice to Exporters

Tue, 13 Jan 2026 14:19:18 GMT

Notice to Exporters communications totalled 34 in 2025, covering a variety of topics. Popular subjects for last year’s announcements included changes to UK Open General Export Licences (OGELs). The AUKUS licence for Australia, the United Kingdom, and the United States was subject to specific notices. Also, the UK’s sanctions on Russia and updates on export control non-compliance, along with subsequent compound settlements, were regularly announced throughout the year.

As the year ended, we saw further updates to UK Export Control legislation, along with the creation of new classifications.

Below is a summary of the Notices to Exporters published in 2025, including the subjects covered. 

Notice to Exporters 2025/01: Countering Russian sanctions evasion

The first Notice to Exporters update of 2025 provided guidance to UK Exporters on countering Russian sanctions evasion, along with supplementary guidance to help businesses insert a “no re-export to Russia” clause into contracts.

Notice to Exporters 2025/02: Update to Open General Export Licence

Relating to the Open General Export Licence (exports in support of Joint Strike Fighter: F-35 Lighting II), this notice advised the addition of Greece as a permitted destination.

Notice to Exporters 2025/03: Countering Russian sanctions evasion and circumvention guidance.

Updating the guidance issued under NTE 2025/01, this notice introduced the Common High Priority List, detailed specific critical items to Russian weapons systems and Military development, identified by the Harmonised System code.

Notice to Exporters 2025/04: Changes to permitted destinations on 4 Open General Export Licences

The second Open Licence update of 2025 removed Rwanda as a permitted destination on four OGELs for Military Goods.

Notice to Exporters 2025/05: Compound settlement offers for Export Control breaches.

This notice confirmed a compound settlement issued in October 2024 to a UK business for unlicensed exports of dual-use goods and failure to declare a licence to HMRC. The communication also advised an increase in Voluntary Disclosures over the last year.

Notice to Exporters 2025/06: Updates to the UK Strategic Export Control list

Published on 11th March 2025, subscribers were advised of a forthcoming amendment to the “Consolidated list of strategic military and dual-use items that require export authorisation” to align with domestic and multilateral changes.

Notice to Exporters 2025/07: Update to Open General Export Licence

Advising an update to the Open General Licence (AUKUS Nations) to better align with the United States' excluded technologies list for the trilateral security partnership among Australia, the United Kingdom, and the United States.

Notice to Exporters 2025/08: Compound settlement offers for Export Control breaches.

HMRC agrees to three settlements with UK companies during January and February 2025—two settlements related to unlicensed exports of military goods, totalling more than £3.6 million.

Notice to Exporters 2025/09: Update to Open General Export Licence

This notice communicated a revision to the Open General Export Licence for oil and gas exploration to permit exports to the continental shelf off coastal destinations that are confirmed as permitted destinations on the licence.

Notice to Exporters 2025/10: Update to Open General Export Licence

Advising a revision to the Open General Export Licence oil and gas exploration: dual-use items to reinclude the UK Continental Shelf as a permitted destination.

Notice to Exporters 2025/11: Further sanctions against Russia introduced in April 2025

Confirming new Trade Sanctions on Russia, which entered into force on 24th April, 2025. The new measures added new sanctions items and the provision of related ancillary services.

Notice to Exporters 2025/12: Amendments to Syria sanctions and revocation of general trade licence

Further to the Foreign, Commonwealth & Development Office’s Syria amendments on 25th April 2025, this notice advised the removal of certain export restrictions on Syria and the revocation of the general trade licence for Syria sanctions – earthquake relief efforts in Syria.

Notice to Exporters 2025/13: the export control (amendment) regulations 2025

Further to Notice to Exporters 2025/06 on 2nd May 2025, we have a variety of updates to the Export Control Order 2008 and Assimilated Dual Use Regulation, resulting in a revised “consolidated list” to be issued.

Notice to Exporters 2025/14: changes to the scope on 13 Open General Export Licences

On May 9th 2025, notice communicated the revision of 13 Military Open General Export Licences to exclude nuclear power-generating equipment under ML17g and naval nuclear propulsion equipment under ML9.

Notice to Exporters 2025/15: F680

An update relating to LITE, Licensing for International Trade and Enterprise, the replacement for SPIRE. The notice advised that users should apply on LITE for an F680, the Ministry of Defence security approval form 680.

Notice to Exporters 2025/16: Updated use of characters on the Customs Declaration Service (CDS)

Published on 17th June 2025, this notice advised a change to CDS, the Customs Declaration Service, which would exclude case sensitivity and include the acceptance of special and diacritic characters applicable on licences used for the import and export of licensable goods.

Notice to Exporters 2025/17: Update to the Uk Arms Embargo on Armenia and Azerbaijan

Communicating updates to the UK arms embargo on Armenia and Azerbaijan, which does not apply to weapons, ammunition and munitions that might be used on the land border between the two countries by military, police, security forces, and related government entities of either destination.

Notice to Exporters 2025/18: Compound Settlement for Export Control Breach

Further communication on July 8th, 2025, regarding the largest compound settlement of a breach of the Russia (Sanctions) (EU Exit) Regulations 2019. Just over £1.1 million was paid by a UK Exporter in May 2025.

Notice to Exporters 2025/19: Foreign Influence Registration Scheme launch – guidance on registering foreign power arrangements.

The Home Office launched the Foreign Influence Registration Scheme (FIRS), which increased transparency into activities taking place in the UK at the instruction of a foreign state or a foreign state-controlled organisation. The note detailed two types of activity: the political influence tier and the enhanced tier, for which FIRS registration is required.

Notice to Exporters 2025/20: Updated End User Undertaking and Guidance

This announcement introduced a change to the process for exporters seeking to apply for a SIEL (Standard Individual Export Licence) or SITCL (Standard Individual Trade Control Licence). Previously, an End User Undertaking or Stockist Undertaking were the appropriate document depending on the scenario. The notice advised that a new single document, the “End-user and stockist undertaking EUSU)” form, would take effect from 1st September 2025 and provided a link to the newly created guidance document to assist with completing the new undertaking. The update also confirmed that digital signatures are acceptable, the removal of the Annexe A document and confirmation that it is no longer necessary to provide the document on a company letterhead.

Notice to Exporters 2025/21: F680 Approval for classified and unclassified ITAR material

The first of two communications was published on 21st July 2025. This notice confirmed details of the F680 requirements. Further to NTE 2025/15, this notice advised that a LITE application is required for approval to release UK Official Sensitive and above material, as well as ITAR Classified material. Subsequently a SPIRE application is needed for approval to release ITAR unclassified items.

Notice to Exporters 2025/22: General trade licence Russian sanctions – sectoral software and technology.

The second July 21st, 2025, communication announced the publication of the General Trade Licence (Russia Sanctions – Sectoral Software and Technology) on the same day. The licence permits the transfer of technology for business enterprise software and technology, subject to the Terms and Conditions. It related to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which came into force.

Notice to Exporters 2025/23: New Ultimate end-user screen

On August 15th, 2025, details of a possible New Ultimate End-User screen to be incorporated into LITE for SIEL applications were communicated.

Notice to Exporters 2025/24: Amendment to EU Regulation (EU) 2019/125 (torture and capital punishment goods) applying to Northern Ireland

Published on 27th August, NTE 2025/24 published an amendment to EU Regulation 2019/25 through Commission Delegated Regulation (EU) 2025/928, which applies directly to Northern Ireland under the Windsor Framework. The notice confirmed that implications for England, Scotland, and Wales were under consideration and would be published in due course.

Notice to Exporters 2025/25: Reversal of new ultimate end-user screen

Further to the announcement on 15th August 2025, this notice advised a reversal of the Ultimate End-User screen on LITE, confirming that an update would be made to the stockist application, with unknown ultimate end-users, once available.

Notice to Exporters 2025/26: Update to open general export licence

Further to the change communicated via NTE 2025/07, issued on 2nd October 2025, this notice advised of changes to the Open General Licence (AUKUS Nations), specifically regarding F680 requirements and membership of the Authorised user community. The notice also made changes to better align with the United States Excluded Technologies List.

Notice to Exporter 2025/27: General trade licence Russia sanctions – sectoral software and technology

This notice advised of an extension of the validity of the General trade licence for Russia sanctions sectoral software and technology to 17th April 2026. The initial licence was revoked, and an updated version was published.

Notice to Exporters 2025/28: Removal of UK arms embargo on Armenia and Azerbaijan

The UK Government announced the complete lifting of the UK Arms Embargo on Armenia and Azerbaijan on 13th October 2025. This was subsequently confirmed via Notice to Exporters on 29th October 2025.

Notice to Exporters 2025/29: the Export Control (Amendment) (No.2) Regulations 2025

NTE 2025/29, on November 7th provided advanced notice of the upcoming Statutory Instrument. (SI): The Export Control (Amendment) (No.2) regulations 2025. These changes amended and updated the controls to strengthen compliance on specific emerging technologies, amending and updating the Export Control Order 2008, Annexe I of the Council Regulation EC 428/2009, and the assimilated Torture Regulation. In addition, there was a further update regarding Armenia and Azerbaijan, reflecting the lifting of the Arms Embargo, whilst providing that certain goods remain subject to transit control.

Notice to Exporters 2025/30: Updates to the Export Control regulations

Further to NTE 2025/29, an update on 20th November provided details of updates to UK Export Control legislation. Amongst the changes, the UK National Dual Use classifications PL9013, PL9014, and PL9015 were transferred to the Assimilated Dual Use list. The new classifications were identified by a third digit of “5” and were described as “500 Series” controls. Subsequently, an updated version of the “consolidated list” was published on 16th December 2025.

Notice to Exporters 2025/31: UK Export pays compound settlement for breaches of export controls.

Published on 1st December 2025, this notice confirmed a compound settlement offer paid by a UK Exporter for unlicensed exports of Military Goods.

Notice to Exporters 2025/32: UK accedes to the Agreement on Defence Export Controls

Joining France, Germany, and Spain, the UK acceded to the agreement, which is, a defence exports treaty designed to reduce the administrative burden of granting export licences among signatory nations. The Export Control Joint Unit published this notice on 11th December 2025.

Notice to Exporters 2025/33: Open general export licences updated

This notice, issued on 16th December 2025, advised that eight OGELs had been updated to align with the commencement of the Export Control (Amendment) (No.2) Regulations 2025, which came into force on the same day.

Notice to Exporters 2025/34: Update to general trade licence Russia sanctions – fertilisers.

The final Notice to Exporters of 2025 advised of an update to the licence relating to financial services and funds related to fertilisers.

Open Licence Returns

Tue, 06 Jan 2026 14:55:33 GMT

The ECJU, (The Export Control Joint Unit) has requested a report listing the use of applicable licences since 2014. The transition to LITE (Licensing for International Trade and Enterprise) is an ongoing process. Submitting returns will be via SPIRE (Shared Primary Information Resource Environment) this year.

Open Licence Returns are an essential reminder that the exporter must adhere to the Terms and Conditions of the OGEL they have registered to use. In the first instance, the exporter must review the licence to ensure compliance with the requirements. Alternatively, the conditions can be checked using the OGEL Checker. The registration process for an OGEL provides the exporter with a unique licence number. Open Licences can be updated, so the exporter must be aware of any changes. Signing up for Notice to Exporters is highly recommended. The exporter will always use the latest version of the licence. Verifying the licence's validity and retaining a copy on file are imperative for audit preparation.

The SPIRE “workbasket” contains the link to submit Open Licence Returns. Clicking this option takes the user to a screen where they can either manually submit the information or download a spreadsheet to generate a bulk report.

The template has five columns: “Licence Number”, “Destination”, “End-User Type”, “Usage Count”, and “Period”. The Manual Return replicates the information and adds an additional section to confirm whether a Nil Return is being submitted to the ECJU.

The Manual Return section provides a drop-down list of licence numbers that require a return. The “Destination” drop-down will list the countries valid for the licence. The SPIRE hint for the destination confirms that the necessary information is the first destination country in which the goods are used, in the form in which they left the source country. The “End-User Type” provides four options: “Government,” “Commercial,” “Pvt Indiv.” (Private Individual), or “Other.” The hint indicates that “Other” applies to an Academic Institution. The hint defines the end-user as the first organisation or person that uses the goods in the form in which they left the source country.

The usage count is the number of times the exporter has used their OGEL for the selected end-user type in the chosen country. The ECJU is currently updating the Open Licence Return guidance . An interim communication published by the ECJU in December 2025 confirmed that tangible exports made should be submitted on a per shipment basis. This means that if a shipment included multiple licensable items, the exporter would need to declare the usage as a single item. Accurate record-keeping is imperative for Customs and Trade Compliance. In theory, the exporter could consolidate multiple orders into a single shipment, identified by the information declared to CDS, (The Customs Declaration Service). Each shipment will have a unique MRN (Movement Reference Number), with the requirement to declare the exporter’s licence number in Data Element 2/3.

Always double-check that the period is correct before submitting the return!

In January 2026, returns for calendar year 2025 must be submitted. Please do not assume the drop-down displays the correct year. Unfortunately, exporters have submitted returns for the wrong year.

Many Happy Returns!

Notice to Exporters 2025/34

Mon, 05 Jan 2026 16:05:28 GMT

The ECJU – Export Control Joint Unit, published communication 2025/34 relating to the General trade licence Russia sanctions – fertilisers.

The Notice confirms that the Licence has been updated to include anhydrous ammonia within its scope.

The licence was first published on 9 ^th November 2022; this is the first amendment since publication.

The notice confirms that this general licence permits the provision of financial services and making funds available to a person connected with Russia for the supply or delivery of specified fertiliser goods either from Russia to a third country, or from Russia to a person in a third country, where they are intended for agricultural use only.

CDS Update 5.0.0.2

Mon, 05 Jan 2026 15:07:50 GMT

The upcoming CDS update, version 5.0.0.2, is scheduled for release on the 15 ^th January 2026. There should be no scheduled downtime during this update.

Changes for both Imports and Exports

Supervising Customs Office ID

DE 5/27 Customs Supervising Office: A correct Supervising Office ID must be declared accordingly.

Should DE 5/27 be declared without an actual Supervising Office ID being declared, then the declaration will be rejected.

Document Code Requirement to be enforced

Document code requirements for the following codes

D025, D026, D027, D028, L128, L129, X828, Y257, Y258, Y688, Y689, Y690, Y768, Y769, Y886, Y887, 9EHC.

Document codes L128, L129, and X828 will become electronic licences effective as of release. The declarations will be rejected should an electronic document ID be declared with a non-electronic document status code.

Document code X001 will reject declarations if completed with an ID other than that of a CAP export licence.

For documents such as Export Health Certificates that are incorrectly declared against X001, they must be declared against document code 9EHC, as per the tariff, or omitted from the declaration.

Additional Information Code (AI)

SDSDE has been added to the CDS additional information code list

It should only be used when instructed by HMRC.

Freeport Location Codes

Some changes have been made to the validity of Goods Location Codes that can be declared in DE 5/23 when Authorisation Type Code ‘FP’ is declared in DE 3/39.

When Authorisation Type Code ‘FP’ is declared in DE 3/39 the following changes apply to the Goods Location Type (third character) of the Goods Location Code:

‘B’ is no longer mandated as the third character of a Goods Location Code declared in DE 5/23.

When Authorisation Type Code ‘FP’ is declared in DE 3/39 the following changes apply to the Goods Location Qualifier (fourth character) of the Goods Location Code:

‘U’ is no longer prohibited as the fourth character of a Goods Location Code declared in DE 5/23.

This means that Goods Location Codes where ‘B’ is the fourth character, such as Codes relating to a Customs Warehouse or inland location, will not cause declarations to be rejected when Authorisation Type Code ‘FP’ is declared in DE 3/39.

Goods location codes

New Goods Location Codes have been added to the CDS code list.

Appendix 16 will be updated accordingly.

IMPORT DECLARATION UPDATE

Country of Dispatch

Document codes N002, N851, 9115, C085, C640, N853, C678, C673, then DE 5/14. The country of dispatch/export must also be declared. If DE 5/14 is not completed, the declaration will be rejected.

This is to ensure the country of dispatch is declared on an I1 C&F to support BTMS/CERTEX validation.

The other datasets for import declarations either already mandate DE 5/14 or do not permit use with SPS goods.

Nationality of Means of Transport Crossing the Border

For Northern Ireland H1, H3, H4, H5 declarations, data element DE 7/15, Nationality of the means of transport crossing the border, is mandatory unless DE 7/4, Mode of transport at the border, is coded 2 (Rail), 5 (Mail), or 7 (Fixed Transport Installation).

If a Northern Ireland H1, H3, H4, or H5 declaration is submitted with DE 7/15 and DE 7/4 is not coded 2, 5, or 7, the declaration will be rejected.

DE 7/15 is no longer required on GB H1, H3, H4 or H5 declarations, regardless of the mode of transport at the border. These changes were delivered as part of the GB declaration simplifications in CDS Release 4.9.0.

The GB declaration simplifications require extensive amendments to the Declaration Completion Instructions, which are currently being compiled.

Identity of Means of Transport

For import H1, H3, H4, H5 declarations with Additional Declaration Type Codes A or D

If the border transport means mode code declared in DE 7/4 is not 5 (Mail) or 7 (Fixed Transport Installation), then DE 7/9 Identity of the means of transport on arrival is mandatory and must be completed.

If a declaration of type A or D (H1, H3, H4, H5) is submitted with a border transport means mode code other than 5 or 7, and DE 7/9 has not been declared, the declaration will be rejected.

EXPORT DECLARATION UPDATE

Statistical value update

Data Element (DE) 8/6 is mandatory on Export declarations unless Additional procedure Code 3NS is declared.

This applies to export declarations B1, B2, B4 & B1MOU with Additional Declaration Type Codes A, D, Y & Z

If DE 8/6 is not completed for these Export declarations, the declarations will be rejected.

Export document codes

Document Codes - C651 and C658

When either is declared in DE 2/3 for an item on a declaration, all goods on that declaration must also contain the document code C651 or C658.

The document Codes declared on each goods item do not have to match.

For example, Document Code C651 could be declared against items 1 and 2, and Document Code C658 against item 3 DE 2/3.

If one of the Document Codes C651, C658 is entered in DE 2/3 for a goods item, but any other goods item on the declaration does not contain one of these document codes, the declaration will be rejected.

If a consignment includes items covered by an Electronic Administrative Document/Fallback Document and other items that don’t have either, separate declarations will be required.

Document code 90W8

When Document Code 90W8 is entered in DE 2/3 for an item, it must be present on all items on the declaration.

Should 90W8 be declared on an item, but is not present on any other items on the declaration, the declaration will be rejected.

Separate declarations would be required if some items are covered under 90W8 and others are not. Those not covered would need their own customs declarations.

Preparing for the €3 Duty on Small Consignments

Tue, 23 Dec 2025 13:00:15 GMT

Christmas for EU customers could be costly for e-commerce parcel imports into the EU in 2026. This is due to the pending implementation of a fixed duty rate on parcels entering the EU from the 1st of July 2026.

This is being described as a temporary measure because of unfair competition for EU sellers, health and safety risks for consumers and high levels of fraud and environmental concerns as outlined here:

Customs: Council agrees to levy customs duty on small parcels as of 1 July 2026 - Consilium

The fixed rate from 1st July 2026 is 3 euros per consignment for consignments valued at 150 euros or less, and it will be a fixed rate of duty applied at the time of import.

That rate applies to all non-EU sellers selling via E-commerce into the EU when you are registered for the IOSS (Import One Stop Shop).

The EU Commission also confirmed in its statement that it will assess whether this should be extended to non-registered IOSS traders.

While €3 per commodity code may appear minimal, cumulative costs can be significant for high-volume importers.

That means if you are importing one commodity code, you would pay €3; if you are importing 99 individual commodity codes on the same declaration, you would pay €297 in duty for that consignment.

Multiply this by five shipments per week, and you could, for example, be looking at over 5k Euros per month in duty payments that were not required previously.

Some of you may be aware that a transitional measure will be in place. This was discussed and published in November; however, it was not confirmed until now:

Customs: Council takes action to tackle the influx of small parcels - Consilium

There is already a discussion within the European Union about implementing a handling fee for parcels imported into the EU. This €3 duty, due on 1st July 2026, is separate from the handling fee, which is still being finalised.

Who would this affect?

This will affect any e-commerce business that is a non-EU seller using IOSS. That could lead to an increase in operating costs, an increase in the potential cost of goods, and an increase in the actual cost of importing goods into the EU.

This will require a Customs declaration to facilitate item-level information. Would further information be needed beyond the reduced dataset? Would there be an additional charge from a third party, and how would this be actioned?

Ultimately, however, this could affect the final consumer in the EU, as a rise in costs for the UK E-commerce business could be passed on to the customer. Or could this be absorbed by the UK seller of the goods?

What about the supply chains that are already in place? How is the current documentation actioned? Would you need to speak with the distributor of your goods? Would a third party pay the duty first?

All questions that need to be answered between now and the 1st of July 2026: this is not just a Christmas Tax.

Notice to Exporters 2025/33 – updates to eight Open General Export Licences

Fri, 19 Dec 2025 11:56:10 GMT

On Tuesday, December 16 ^th , 2025, Notice to Exporters 2025/33 was communicated by the Export Control Joint Unit.

Firstly, the communication relates to six updated OGELs to align with changes in UK Export Control Legislation, which were communicated via Notice to Exporters 2025/30 on 20 ^th November 2025, which relates explicitly to The Export Control (Amendment) (No. 2) Regulations 2025

The amendment includes changes that remove existing classifications and create new ones . Three UK Dual Use Classifications PL9013, PL9014 and PL9015 have been removed from the UK Dual Use List and have subsequently been incorporated into the Council Regulation (EC) No 428/2009 as “500 Series” classifications. The list of new classifications was communicated in Notice to Exporters 2025/30 on 20 ^th November 2025.

Subsequently, a new Consolidated List was published on 16 ^th December 2025 .

The six updated OGELs, reflecting the amendments to the UK legislation by removing PL9013, PL9014 and PL9015 and replacing them with new classifications to Council Regulation (EC) No 428/2009, are as follows;

In addition, there are changes to two other OGELs.

First, the OGEL A400M collaborative programme has been updated to reflect a minor change to Annex A of the OGEL.

The OGEL PCBs and Components for Military Goods licence permits the export of specifically described products and ML classifications to approved destinations. This licence has been updated to include O-rings for gas systems in the scope of approved items.

These licences (except for the OGEL export after exhibition for dual-use items) have also been amended to reflect Export Customs Declaration requirements. The update confirms that “the licence reference in the form ‘GBOGE 20XX/XXXXX’ must be entered onto the UK’s Customs declarations system” This clause is referring to CDS, the Customs Declaration Service and the mandatory requirement for the exporter to declare their unique licence number to HMRC in Data Element 2/3 of the Customs Declaration.

The notice confirms that the eight OGELs came into force on 16 ^th December 2025, aligning with the commencement of the Export Control (Amendment) (No. 2) Regulations 2025

Existing OGEL registrations will still apply. When using OGELs, it is imperative that the updated version be reviewed to verify compliance and ensure adherence to the Terms and Conditions. If exporters have PL9013, PL9014, and PL9015 controlled items, these will require reclassification against the updated Consolidated List of Strategic Military and Dual-Use items that require export authorisation .

The Customs Spirit of Christmas

Wed, 17 Dec 2025 13:45:36 GMT

While we toast to Christmas with mince pies and mulled wine, few realise how much of the holiday season rests on the long, often hidden, history of Customs controls, import tariffs, and trade restrictions. Today’s Christmas cheer would have once been a Customs officer’s nightmare, or dream, depending on which side of the brandy they were on. The modern British Christmas, from its foods to its decorations, is the product of centuries of trade, tariffs, excise rules and regulatory oversight. And if Santa tried to cross a UK border today, laden with controlled toys, high-tech gifts, and a few bottles of brandy, he’d be flagged for inspection before he could even say "Ho, Ho, Ho.”

Let’s start with the old tradition of the Christmas orange. That bright citrus in the toe of a child’s stocking wasn’t just a treat; it was a signal that your family had money. Oranges were once a luxury, imported from southern Europe and the Levant, and subject to tariffs under the Customs codes of the 17th and 18th centuries. Alongside them came cinnamon, nutmeg, and cloves, essentials for everything from festive punch to Christmas pudding. All arrived via heavily taxed maritime routes and were subject to the Navigation Acts, which restricted imports to British ships and British ports.

The Christmas pudding itself is a Customs miracle: sultanas from Turkey, spices from the East Indies, rum from the Caribbean, sugar from cane fields — each a step in a carefully controlled chain of 18th and 19th-century global trade.

And historically, where there are tariffs, there are smugglers. The festive period was no exception. Brandy, silk ribbon, lace, and perfume often entered the UK under cover of darkness, hidden in false-bottomed crates, in fishing boats, or along quiet beaches from Kent to Cornwall. Customs officials (or excise men) stationed along the coast were known to step up inspections in the run-up to Christmas, aware that both merchants and smugglers wanted to capitalise on the seasonal demand for foreign luxuries. Had Santa existed in 1805, his sleigh would almost certainly have been seized for undeclared brandy and contraband ginger.

Many of our “traditional” Christmas ideas were invented or imported during the Victorian era, a period defined as much by imperial trade routes as by Dickens and the railways. Crackers? The idea came from France, but the snap was British. Glass baubles? First imported from Bohemia (modern Czechia) and later mass-produced in Germany. German wooden toys were among the first regulated seasonal imports as the toy industry boomed. Even Christmas cards, first printed in London in 1843, were made with paper often sourced from abroad and ink dyes imported via Europe’s regulated chemical trade.

All of this was subject to tariff books, Board of Trade oversight, and increasingly centralised Customs records — the ancestors of today’s CDS and commodity code databases.

It wouldn’t be Christmas without a bottle (or three). But alcohol, from Prosecco to Scotch, has long been one of the UK’s most tightly regulated commodities. Excise duty on spirits is one of the oldest forms of taxation in Britain, dating back to the 1600s. By the 1800s, Customs officers were stationed along rivers, ports, and city centres to intercept illicit barrels. Christmas brandy was often smuggled into coastal villages, hidden in hay carts, or disguised as vinegar.

Today, while the trade may be more transparent, the obligations are no lighter. Alcohol shipments still require additional declarations, duty stamps, and licensing/authorisations, as well as accurate classification under the excise Tariff chapters. And it’s not just the booze. Christmas hampers filled with meat, cheese, or composite foods may require full Export Health Certificates (EHCs) signed by an official veterinarian before leaving the UK — particularly for export to the EU or Northern Ireland. If your pigs in blankets are heading abroad, the paperwork might outweigh the sausages.

The first British Customs House opened in London in 1275. By the Victorian era, the UK Tariff Book was hundreds of pages thick. Goods being imported into the UK had to be declared with precision: a bauble wasn’t just a bauble; it might be taxed differently based on the material (glass vs. metal), country of origin, or whether it came pre-packed with other decorations. Today, we use the UK Trade Tariff online tool, but the principle remains the same: mis-declaring goods risks penalties, delays, or overpaying duties. Recent Customs data shows that around 2 in 5 businesses use the wrong commodity code…. a mistake that would make a Victorian officer shake his powdered wig.

So, this Christmas, as you raise a glass of brandy, nibble a mince pie, or ship out a Bluetooth-enabled toy, remember: Christmas has always been a celebration shaped by international trade and the controls that regulate it. Whether it’s 19th-century smugglers dodging excise, or 21st-century exporters juggling CDS declarations, commodity codes, and health certificates, the Customs spirit of Christmas is alive and well.

And if Santa really did try to run this show without an EORI number, origin documentation, and a vet-signed certificate for reindeer jerky, he’d be spending Boxing Day in detention at the Border Control Post.

Goods Location Codes Under CDS 5.0.0 Update

Tue, 16 Dec 2025 12:52:05 GMT

We have been made aware that some traders are experiencing technical issues with goods location codes that were deleted following the CDS 5.0.0 update.

For any rejected declarations, you should submit a replacement declaration.

For pre-lodged declarations, amend them using the correct Goods Location Codes.

The complete list of all of the goods, location codes, and the subsequent changes below can be found within the following link: Goods location codes for Data Element 5/23 of the Customs Declaration Service - GOV.UK

The following goods location codes have been updated in the latest CDS 5.0.0 release.

CDS – System Issues (15 December 2025)

Mon, 15 Dec 2025 14:30:14 GMT

HM Revenue & Customs (HMRC) is currently experiencing technical difficulties with the Customs Declaration Service (CDS). To minimise disruption, HMRC has implemented contingency processes to allow businesses to continue moving goods and freight while full service is restored.

Contingency Measures in Place

Hauliers using the Goods Vehicle Movement Service should create a Goods Movement Reference (GMR) and select ‘Declaration by Conduct’
At maritime Temporary Storage locations, carriers and shipping agents are authorised to use contingency manifest codes (such as ‘C’ or ‘T2’ status, depending on the inventory system in use).

Traders should use these options wherever possible. If they are unable to do so, they should contact the CDS helpdesk and provide their unique consignment number (UCN) and, if available, the Movement Reference Number (MRN).

The C130 form will not be required when goods are held at an inventory-linked Temporary Storage location.

HMRC has acknowledged customer concerns and reiterated its commitment to system resilience. The organisation continues to work closely with stakeholders to minimise disruption and apologises for any inconvenience caused.

For the latest updates on CDS service availability, businesses are encouraged to consult the official page: Customs Declaration Service: service availability and issues – GOV.UK before commencing any journey.

I went to the shops…. An International Trade Advisor's Festive Shopping Spree

Fri, 12 Dec 2025 16:58:05 GMT

As a Customs and International Trade advisor, I need to know a lot about the importation process and understand how goods make their way onto supermarket shelves. This includes all the regulatory requirements they must meet to achieve this. Importantly, I need to understand Tariff Classification, how to determine which certificates are required for importing goods, which legislation applies, and whether the product is a food product or a composite good.

If all that wasn’t enough, I also need to understand the Rules of Origin and the distinction between where a product is made and where it meets the Origin rules in trade agreements.

While walking around the supermarket, I considered the above information regarding specific products. I first looked at a fresh pasta salad containing prawns, cooked pasta, and vegetables, dressed with a mayonnaise-style sauce. What Commodity Code did this come under? Would the prawns, the pasta, or the vegetables determine the code?

I wondered if this product would be imported from the EU and which risk category it would come under, as outlined in the Border Target Operating Model (BTOM). Would this pasta salad require a Health Certificate, and would it be classified as a composite product? If the prawns were wild caught, a ‘Catch Certificate’ would be necessary to import them. If the same type of product were imported, but instead of being chilled, it was shelf-stable and ambient, would different regulations apply? Would a shelf-stable pasta salad be exempt from the requirement for a health certificate, given its ingredients and processing, and would a Catch Certificate still be required?

I wandered into the clothing section, where a lovely Christmas outfit for a baby caught my eye. It consisted of a Babygro, a bib, mittens, a hat, and a little tutu. Would that be classified as a set, or would each garment have to be classified individually? I’d have to check the legislation, section, and chapter notes, and consult official guidance here to determine the correct code to proceed.

So, on to the bakery aisle. The meat and vegan sausage rolls and pasties caught my eye here... What did I need to think about to classify these? With meat products, is the meat the essential characteristic that determines the code? It would be vital to know the type of meat (e.g., a mix of different meats) and the percentage of meat in the product. In vegan products, will it be the pastry or the filling that determines their essential characteristics? What health certification will apply when importing these from a third country outside the EU? Is there a trade agreement between the UK and the supplying country, and could I claim a preferential duty rate?

I then reached the cleaning products aisle . This was interesting - how would I classify 3-in-1 dishwasher tablets that contain dishwasher salt, detergent, and a rinse aid? Does one element give an essential characteristic, or will each element be equally important? As I progressed, I wondered which General Rule of Interpretation (GRI) I would need to apply to classify the dishwasher tablets.

Finally, I arrived at the Christmas aisle, where an array of gift sets awaited me. In one gift set, there was a combination of a razor and shaving foam. I considered how best to classify two distinct products bundled together. Did one item possess the essential characteristics of the gift set, or would they be classified separately under different Tariff codes, even though they shared the same retail pack? Then I’d have to establish the Origin for the goods - again, one Origin, or two? That would depend on whether I could use one Commodity Code. Next, what about the Product Specific Rules (PSR) of any Trade Agreement that may be in place between the supply country and the UK?

A further look around brought a pretty gift set of mixed peppers in olive oil in a fancy bottle to my attention . Would the peppers meet the ‘wholly obtained’ Origin rule, or would there be an ingredient from another country, which might disqualify the product from meeting the Product Specific Rules of a Trade Agreement, that needs to be considered? The fruit in brandy brought the rules relating to Alcoholic Ingredients Relief to mind, and at that point, I decided to go home!

I was exhausted after my shopping trip, so I settled down in front of the 8525600000 for the evening, with a meal of a product classified under Commodity Code 1902201099, washed down with a glass of 2204218290. Cheers!

Notice to Exporters 2025/32 – UK Accedes to the Agreement on Defence Export Controls

Fri, 12 Dec 2025 15:42:31 GMT

On December 11th 2025, Notice to Exporters 2025/32 was issued, advising on the UK’s formal Agreement on Defence Export Controls, a defence exports treaty with France, Germany, and Spain, designed to establish a framework to facilitate licensing by promoting closer integration across the contracting parties in the signatory countries.

A policy paper with supporting information was issued on December 10th 2025, detailing the agreement.

The notice advises that the Agreement will reduce the administrative burden of approving licences between the signatory nations, whilst confirming that the Agreement doesn’t affect the UK’s export control regime or the assessment of applications against the Strategic Export Licensing Criteria, which were revised in December 2021.

The notice also confirms “that the agreement is designed to promote closer integration of defence industries across the contracting parties and streamline export controls for defence-related products, through six articles which are detailed in the policy paper. A summary of the articles is detailed below.

Article 1 – “Facilitating intergovernmental partnerships, by ensuring no party blocks exports of jointly produced equipment on purely political grounds, where it cannot cite an impact on direct interests or national security.”

Article 2 relates to streamlining and simplifying licensing processes for joint industrial programmes, thereby reducing the risk for exporters in joint defence programmes by enhancing co-operation and consultation in certain circumstances. Further details are provided in Annex 1, Article 2 of the Agreement.

Article 3 references a “de minimis” principle. This term is relevant to the United States Export Administration Regulations when assessing the value of a U.S.-controlled component to determine whether re-export controls apply. Under the Defence Export Controls agreement, a simplified licensing process applies if the value of defence-related components from one or more contracting parties in a final system exported by another party is below 20%. An OGEL will be published in due course to facilitate exports under Article 3 of the agreement. Annex 2, Article 3, provides further details on the “de-minimis principle,” and Annex 3, Article 3, details the goods to which the principle shall not apply.

Article 4 details that the contract parties will create a permanent body to consult on all general issues covered by the agreement in order to resolve differences relating to operational implementation.

Article 5 highlights controls on classified and protected information

Article 6 details the final provisions of the agreement.

A statement was made in Parliament on December 9th 2025 detailing the Agreement on Defence Export Controls, which the Ministry of Defence leads. The Ministry also issued a press statement on the same day.

Notice to Exporters provides regular updates on Export Control Joint Unit communications, including legislation and licensing changes, as well as compound settlements for non-compliance. The list of communications also provides a link to subscribe to future emails.

Panic at the Pole – Unarrived Customs Entries

Mon, 08 Dec 2025 13:58:08 GMT

The magic of Christmas, due to an elf's oversight, is dangerously up in the air. Father Christmas, with his sleigh full of presents, sends a ‘code red gift emergency’ message to the head of elf logistics at the pole.

The code red message states:

The Customs declarations have not been arrived, and Border Force is holding me on instruction from HMRC – Help!!!

As the night hangs in the balance, the elf logistics team is now in full high-priority response mode, collating the Christmas carriage mode by reindeer (CMR) document and the DDP incoterm invoices for all the presents Father Christmas is delivering to the children on the nice list. The most important thing is to check that the Customs declarations have been arrived and cleared correctly.

A frantic message was sent back to Father Christmas:

The Customs declarations have been arrived and are Customs cleared; we can provide evidence. We will be sending these through to you now, the message said.

Thinking that this was simply a clerical error on HMRC’s behalf, and that Father Christmas would be released and on his way, the elves and the elf logistics team carried on their Christmas Eve tradition of carolling and drinking mulled wine, toasting another successful year of bringing cheer to others. After all, this has never happened before, so what could possibly go wrong?

Little did they know that Father Christmas would not be released; after all, HMRC had been waiting a full 12 months to speak to him over non-compliance.

"Non-compliance?” ask s Father Christmas. “ The Customs declarations are arrived and cleared and I have provided you with the evidence that the elves have given me.”

“That is right,” HMRC explained. “ The presents have cleared for 2025, but we are not looking at this year’s declarations; it is last year’s, 2024, that have never been arrived and then cleared.”

Father Christmas gasps - “ Oh dear, I'd best ask my elves!”

So, Father Christmas sends another message back to the North Pole, “ It is the Customs declarations from 2024 they are telling me, please help!”

As you can imagine, this caused the team back at the North Pole to panic again. "How can this have happened?" shouted the chief of elf logistics, Barnaby Twinkletoes, interrupting his tasty stollen and mulled wine. “Where are the cleared Customs declarations on the Christmas Declaration Service (CDS)?”

Guess what? They are not there.

The presents had all been delivered in 2024, but the entries are no longer in the system. “ They were!!!” shouts Barnaby, now rather frustrated. They may have been at the time of submission, but because they had not been arrived within the 30-day period, they had timed out and disappeared from the system.

Due to a clerical error, the Customs declarations were not linked to GVMS (Goods Vehicle Movement Service), so that when Father Christmas and his sleigh arrived in the UK, the Customs declarations were not automatically arrived.

The Christmas Declaration Service Customs declarations are always pre-lodged declarations with all the relevant information included within the declaration. This is because they are being imported from outside the UK, so duties and VAT will always apply.

This was a simple oversight, indeed one in which they have been navigating since 2021. Now, HMRC is going to issue a demand notice for duties and VAT, plus a civil penalty, to Father Christmas.

Mrs Claus, at this point, is urgently coordinating with the elf logistics team. She sends another message back to Father Christmas.

“What do we need to do?” Thinking that they could re-issue the Customs declarations for 2024.

The answer from HMRC is simple: no, you cannot issue new Customs declarations. HMRC will be issuing a ‘right to be heard’ letter immediately before issuing the C18 demand notice.

There and then, unfortunately, it appears that Father Christmas accepts the fact that this is a costly error, and one that cannot be delayed any further.

Mrs Claus pays the outstanding duties to HMRC, along with the civil penalty for non-compliance.

Although feeling downbeat, the Christmas spirit will live on. Presents will still be delivered, and those on the nice list will still wake up to surprise gifts under the tree. The elves will get a long rest before getting back to spending 2026 working away in the toy shop, to do it all again for next year.

This will, however, be a reminder, and a big one at that, for Barnaby and the rest of the logistics team, to make sure that everything is in order before Father Christmas arrives with his presents.

Mrs Claus has now given herself a new title – Head of Compliance, after all, the sleigh may defy gravity, but it cannot defy HMRC!

Merry Christmas, all.

CDS 5.0.0

Fri, 28 Nov 2025 16:49:58 GMT

The Customs Declaration Service update, version 5.0.0, is scheduled for release on Saturday, 13th December 2025, between 9:30 pm and 6 am Sunday, 14 December 2025. During this period, CDS will be unavailable. Please note that any pre-lodged declarations that will be affected by the changes should be changed/amended prior to the goods arriving.

Changes for both Imports and Exports

Document Code Amendments

Document code - U119 status code of XA has been added
Document code -C100 status code is no longer required

Document Codes

Further validation of document codes has strengthened the document codes, which are as follows:

C105, Y128, Y134, Y135, Y136, Y137, Y172, Y173, Y174, Y239, Y240, Y241, Y242, Y243, Y244, Y245, Y246, Y248, Y249, Y250, Y251, Y252, Y253, Y254, Y255, Y256

Note that failure to follow Appendix 5A as instructed will result in the declaration being rejected.

Document Status Code Amendments

Document status code of XB can no longer be used with the following document codes:

C057, C079, C082

Document status code XF can no longer be used for the following document code :

E013

Note that failure to follow the Appendix 5A status codes will result in the declaration being rejected.

Electronic Licences

When you are declaring an electronic licence within DE 2/3, you must ensure that the Net Mass is completed within DE 6/1

Failure to do so will result in the declaration being rejected.

Container Identification

When a shipment is within a container and ‘1’ is completed in DE 7/2, you must ensure that DE 7/10 is completed either at the header or item level with a container ID.

Failure to do so will result in the declaration being rejected.

Northern Ireland location of goods

Should a declaration or a CCR be made for goods that are moving through a port that is flagged within Appendix 16 as a Northern Ireland Port, you must ensure that a Northern Ireland AI code is also declared in DE 2/2 as follows.

For Imports : NIDOM or NIIMP

For Exports: NIEXP

Failure to do so will result in the declaration being rejected.

Fixes to issues

There are two issues causing CDS not to be operating correctly that will be resolved.

Declarations will accept country code TZ and will not be rejected for Imports.

CHED – Common health document on an invalidated declaration can not be reused on a replacement declaration.

Goods location codes

Goods location codes (GLC) are to be updated to the new codes in Appendix 16 after the CDS 5.0.0 release.

IMPORT DECLARATION UPDATE

Additional Information Code

AI code COMNE is declared in DE 2/2. The following national additional codes have been updated

X520, X521, X522, X541, X542, X551, X556 , X561, X570, X571, X572 ,X589

The following list of commodity codes has been added for use with AI code COMNE :

3901908099
3902909099
3911100090
3911909990

Should the goods be declared using one of the above commodity codes and COMNE is declared within DE 2/2, then no excise duty should be charged.

COMNE must not be used when excise duty is to be accounted for.

Removal of document codes

The following document codes will be removed from Appendix 5A.

U003, U031, U052, U058, U072, U073, U077, U095, U096, U097, U100, U500

The Declaration will be rejected if these codes are declared in DE 2/3.

Procedure code 6122

Procedure code 6122, which is declared within DE 1/10, must be completed on a declaration under an H5 declaration category.

SPIMM supplementary declarations

Supplementary declarations using SPIMM, the correct previous document identifier must be used in DE 2/1. This is when using the following additional procedure codes :

1AG- must include the Previous Document Identifier- AGG

1RD -must include the Previous Document Identifier- RSD

Should the appropriate Previous Document Identifier not be declared within Data element 2/1, then the declaration will be rejected.

Declaration Invalidation

If a request to invalidate a declaration has been made, it will be automatically rejected if the goods have been released and the following DMS message has been sent.

DMSROG or DMSCLE

01 Series procedure code

01 Series procedure code will no longer grant VAT relief. When using this procedure code, VAT must be accounted for on the declaration. Should the goods be eligible for VAT relief, then you would need to ensure that the correct additional procedure or additional code is declared.

INVENTORY IMPORTS UPDATE

Types of packages and shipping marks

When declaring a C21 under additional procedure code in DE 1/10 of 0009 or under SPIMM additional procedure codes, the following DE are not mandatory to be completed :

DE 6/9 - Type of Packages
DE 6/11 - Shipping Marks

The following additional procedure codes under SPIMM that this will apply to are :

24G, 61G, 62G, 63G,71G

Should these additional procedure codes or procedure code 0009 not be completed correctly, the declaration will be rejected.

EXPORT DECLARATION UPDATE

Northern Ireland Exports

When exporting goods from Northern Ireland under onward supply relief, the AI code of NIEXP must be declared within DE 2/2.

When the previous procedure code 42 is declared within DE 1/10, and NIEXP is not declared, the declaration will be rejected.

The procedure code 42 and the AI code NIEXP are not to be used on GB declarations. These are only applicable to Northern Ireland.

INVENTORY EXPORTS UPDATE

Country of destination

Customs clearance request using either C21E or C21 EIDR NOP, the country of destination can be completed at the header or item level.

INVENTORY EXPORTS AND IMPORTS UPDATE

Additional procedure code 63T

Additional procedure code 63T if declared within DE 1/11 for a C21I or C21E CCR, the supervising office must be declared within DE 5/27

Failure to do so will result in the declaration being rejected .

NTE 2025/30 Export Controls – Classification Updates

Tue, 25 Nov 2025 13:26:17 GMT

The UK Government published Notice to Exporters 2025/30 on 20th November 2025, which details amendments to three elements of UK Export Controls regulations, as set out in The Export Control (Amendment) (No.2) Regulations, which will come into force on 16 ^th December 2025.

Export Control Order 2008 (“the 2008 Order”)

Schedule 2 of the Export Control Order 2008, which lists Military Goods, Software, and Technology, will add the definition of a suborbital craft and update the technical note in ML7h relating to Biopolymers.

Notice to Exporters 2025/28 29 ^th October 2025, detailed the removal of the UK Arms Embargo on Armenia and Azerbaijan, subsequently the Export Control (Amendment) No.2 regulations will move the two countries from Export Control Order 2008 Part 2 (Embargoed and Subject to Transit Control for Military Goods) to Part 4 (Subject to Transit Control for Category B goods).

Assimilated Council Regulation 428/2009 of 5 ^th May 2009

The Dual Use controls amendments have been made to align with Regulation EU 2021/821, reflecting changes made by the Wassenaar Arrangement, Missile Technology Control Regime, Australia Group, and the Nuclear Supplier Group. There are also several editorial amendments to the regulations . The changes also introduce new entries. We are used to seeing the third digit of a Dual Use classification as “0”, “1”, “2”, “3”, or “4”, but there are now new “5” classifications to check. For example, 3B504 “New Entry for Cryogenic wafer probing equipment”

The EU has published Commission Delegated Regulation 2025/2003, which amends EU 2021/821. The changes, applicable to the EU and Northern Ireland, came into force on 15 ^th November 2025 .

The UK Dual List identifies specific items with a “PL” Prefix. Notice to Exporters 2024/04 Dated 12 ^th March 2024, detailed three new classifications PL9013, PL9014 and PL015 under the heading of “Electronics and Related equipment, materials, software and technology”. The classifications relate to quantum technologies, cryogenic technologies, semiconductor technologies, additive manufacturing equipment, and advanced materials.

The Export Control (Amendment) No.2 Regulations will remove PL9013, PL9014 and PL9015 from Schedule 3, the UK Dual-Use List of Goods, Technology and Software to Assimilated Council Regulation 428/2009. New classifications will be identifiable by the third digit being a “5”. Notice to Exporters 2025/30 describes these classifications as “500 Series” and provides a table of the new classification, control entry description, and PL control entry for reference. For example: 3B503 Scanning electron microscope (PL9013a3).

Regulation (EU) 2019/125 of 16 ^th January 2019

Certain goods which could be used for capital punishment, torture, or other inhumane treatment or punishment (“the assimilated Torture Regulation” are detailed in the “List of Capital Punishment and Torture Goods” detailed in the UK Consolidated List of Strategic Items .

Annex II and Annex III have been updated to add items to the list.

It is expected that an updated UK Consolidated List will be communicated via Notice to Exporters to reflect the updates.

The amendments will align the UK’s Export Controls framework with international commitments, the Dual Use and Torture regulations with corresponding EU Controls and ensure that Great Britain and Northern Ireland regulations correspond.

Revamped MSS reports are now available from CDS as the Get Customs Data for Import and Export Declarations Service - launched 13th November.

Tue, 18 Nov 2025 13:32:31 GMT

HMRC has announced that the new Get Customs Data for Import and Export Declarations Service is now available from Thursday, 13th November 2025.

This reporting service is free to use and is based on the user’s import and export data from the Customs Declaration Service. They are set out in a similar way to Management Support System (MSS) reports.

These reports can help the user to:

check that Customs declarations are accurate
support audits or investigations
review declarations that have been made on behalf of the user
monitor import and export activity over time

The reports themselves are not yet perfect. User testing has determined some service restrictions:

The key findings are:

• Missing XI EORI data

• Inability to Search Multiple EORIs

• Data Formatting issues (to reflect existing report formatting)

HMRC have advised that fixes and solutions have been identified for these findings and are scheduled for implementation in due course.

Until these fixes are implemented, the above information will not be available.

Guidelines on how to access the reports and what to expect on the downloads can be found at the link below:

Get customs data for import and export declarations - GOV.UK

Reports can be requested on a per-month basis, and it is anticipated that service speeds will be affected at peak times.

🎄Professional Development this Winter🎄

Fri, 14 Nov 2025 10:36:55 GMT

Discover the ABC of Customs and International Trade. From AEO to Border Controls and Compliance, our training courses cover the basics of importing and exporting through to more advanced Customs regulations training.

Register online to strengthen your knowledge and improve Customs compliance.

See below for further details of courses running this Winter.

November & December Training Courses

Indirect Exports changes for Northern Ireland

Thu, 13 Nov 2025 16:54:53 GMT

From 15th December 2025, there will be a change to the current process for declaring indirect exports from Northern Ireland through CDS.

CDS can still be used for goods that are exiting via the Republic of Ireland.

The Alternative processes

You can still move your goods through the alternative process outlined below, but you must ensure you choose the correct method.

Submit your Export Declaration in CDS if you’re moving goods through a port of exit in the Republic of Ireland.

If you use this process, you must ensure that:

AI Additional information code AG999 is declared in DE 2/2
AI Additional information code AG999 also has the Office of Exit code included in DE 2/2
The Office of Exit code within DE 5/12 must match the Office of Export
The Agent/ Broker/ Haulier must carry a copy of the Export Declaration in paper or electronic format.
The MRN, that is the Movement Reference Number of the Declaration, is included within the PBN, that is the Pre-Boarding Notification
Should the movement be travelling by AIR, then the MRN should be provided to the airline or handling agent

Failure to follow these procedures and to enter the Office of Exit as an EU location within DE 5/12 will prevent the Declaration from being closed. Note that this does not apply to exits via any other EU member states.

Other processes available

If the value of the goods is under €3,000, they are not subject to any licensing restrictions or controls, and a direct export with the Customs authority from where the goods depart can be declared accordingly.

Using the Common Transit procedure—if the destination is within a CTC country that is a signatory to the CTC, Great Britain is a signatory to the CTC. Guidance on the CTC .

Changing the routing - By moving the goods directly from Northern Ireland, if the goods are qualifying goods and do not require an Export Declaration when moving from Northern Ireland to Great Britain. This can only be used for qualifying goods.

Single Transport contract or STC – That is moving goods with an airline or via a shipping company from Northern Ireland, which is responsible for the carriage of the goods. This type of movement cannot be used for Road movements or goods that are subject to any excise duties, such as beer, wine, or spirits.

Unfettered Access.

These changes to CDS and the processes listed above do not in any way change the rules and regulations, or any changes to unfettered access for movements from Northern Ireland to Great Britain.

HMRC has advised that if you have any further questions regarding these changes, contact the following: AESteam@hmrc.gov.uk .

Changes to Statistical Value

Thu, 13 Nov 2025 14:19:47 GMT

Following our previously published CDS updates as well as HMRC updates in MAY 2025. HMRC has now confirmed that the statistical value will be enforced in CDS export declarations.

Export declarations

From the 8th January 2026, declarations under the following declaration categories:

B1
B1MOU
B2
B4

Must have the statistical value included within DE 8/6; failure to do so from this date will result in the declarations being rejected.

This does not affect traders who will be applying the non-stat export additional procedure code 3NS.

Import declarations

We have been advised that this is currently being reassessed and that an update on the statistical value will be issued in the future. Imports are NOT included in the export changes for January, as listed above.

We will issue an update regarding the statistical value at import once received.

Notice to Exporters 2025/29 – The Export Control (Amendment) (No.2) Regulations 2025

Tue, 11 Nov 2025 12:27:23 GMT

Notice to Exporters 2025/29, published on November 7 ^th , 2025, communicates advance notice of the Export Control (Amendment) (No.2) Regulations 2025, which will encompass the following updates.

Dual-Use updates to Council Regulation (EC) No 428/2009, following the European Union's adoption of a Delegated Regulation that updated Annexe I of Regulation 2021/821 on September 8 ^th , 2025.

Relevant to the controls of specific emerging technologies, the amendment will strengthen export controls for national security purposes. To ensure alignment with EU regulations, avoiding duplication of control in Northern Ireland, where corresponding EU regulations apply directly, the amendment will move controls from Schedule 3 of The Export Control 2008 (S.I. 2008/3231(the ‘2008 Order’) to Annexe I of Council Regulation (EC) No 428/2009 .

There will be an update to Schedule 4 of the Export Control Order 2008 to reflect the removal of the UK Arms Embargo on Armenia and Azerbaijan, which was confirmed on October 29 ^th via Notice to Exporters 2025/08 .

Finally, an amendment to Annexes II and III of the assimilated Torture Goods Regulation, to bring controlled items in alignment with the corresponding EU Regulation 2019/125 of the European Parliament and the Council of January 16 ^th , 2019. Annexes II and III already feature within the Human Rights List, located here in “The consolidated list of strategic military and dual-use items that require export authorisation from the United Kingdom”

The notice states that the intention is to lay out the regulations in November, with them coming into force in December. Regulation will be published on legislation.gov.uk in due course .

Remember, remember the 5th of November! - Gunpowder, Guy Fawkes, and Government Controls.

Wed, 05 Nov 2025 16:03:07 GMT

While November 5th is known for fireworks and the foiling of the Gunpowder Plot, it's a story that goes beyond mere historical events. It's a tale of smuggling, licensing violations, and the evasion of government controls. Guy Fawkes and his co-conspirators, often portrayed as terrorists, were more than that. They were black-market operators who bypassed what we would now recognise as Customs and Export Laws. The plot, had it succeeded, would have turned a regulatory failure into a national catastrophe, a fact that still resonates with us today.

The year was 1605, and tensions between Protestants and Catholics simmered across England. King James I, who was at the time a Protestant monarch, had enforced strict laws against the Catholic population, including restrictions on worship, property rights, and civil participation. Amid this climate, a group of English Catholics decided to strike back. But what was their goal? Well, if we recount the tale, it was to blow up the House of Lords during the State Opening of Parliament, killing the King and much of the Protestant leadership in one massive detonation. It would come to be known as the Gunpowder Plot.

But an overlooked part of this story is the supply chain behind the sabotage. For this plot to succeed, the conspirators required at least 36 barrels of gunpowder, which, even in 1605, was a dangerous and highly regulated substance. Gunpowder was not freely traded. It was a controlled, military-grade material, and anyone acquiring or transporting it was subject to Crown licensing restrictions. Buying, storing, or moving gunpowder without authorisation was illegal and potentially treasonous. Guy Fawkes and his colleagues weren’t just stockpiling explosives; they were violating the 17th-century equivalent of export control laws, smuggling strategic materials, and operating outside regulatory controls designed to protect national security

At the time, England had already begun to regulate trade in sensitive goods. At that time, gunpowder was being used in both warfare and mining. It was tightly controlled to prevent any uprisings and to protect the state’s military advantage. While not formally called “dual-use goods” as we would call them today, the concept did exist. The Crown reserved the right to grant or deny permission to possess or trade such materials. The timing of the Gunpowder Plot is also interesting. Just a year earlier, in 1604, the Crown had issued the first official Book of Rates, a standardised Tariff list that laid out Customs duties on imported and exported goods. This Elizabethan innovation, carried forward into James I’s reign, marked a significant tightening of trade controls, and reflected rising concerns over smuggling, revenue loss, and the national security risks posed by unregulated imports.

Customs enforcement in the early 1600s would be considered limited by today’s standards. Still, it was far from non-existent, as Fawkes and his associates were circumventing a recently reformed Customs system designed to bring transparency and control to England’s growing trade network. Ports like London and Dover had Customs officials who collected duties and inspected cargo. Revenue from Customs formed a significant part of the Crown’s income, especially after the decline of feudal taxation. Any scheme to import or move goods, especially volatile substances like gunpowder, outside these structures was a direct challenge to the state. By the time of the Gunpowder Plot, England had been enforcing Customs duties for over 300 years, ever since Edward I established the first Custom House in 1275 to regulate the wool trade. But the early 17th century was a time when smuggling was a political and religious tool. English Catholics often trafficked in forbidden literature, relics, and even people, particularly priests. In this context, the movement of gunpowder wasn’t just illegal; it was part of a wider network of resistance that relied on evading Customs enforcement and operating in the shadows of trade regulation.

Guy Fawkes himself was a seasoned soldier. He had fought for Catholic Spain in the Netherlands and was an expert in munitions. In today’s terms, he would fall under export control watchlists for providing defence services to foreign powers. This raises another modern parallel: the transfer not just of goods, but of technical knowledge. Today, governments tightly regulate the export of military expertise, blueprints, and training. If a British explosives expert went abroad today to join a foreign military or paramilitary group, it would trigger serious legal and diplomatic consequences.

Fawkes wasn’t just a bomb carrier, he was a trained operative with foreign connections, using specialist knowledge gained abroad for subversive purposes, precisely the kind of risk modern export control regimes are designed to catch and contain.

The real lesson from the Gunpowder Plot isn’t just about failed terrorism, it’s about what happens when regulatory controls are bypassed. If Customs officers, licensing agents, or port inspectors had intercepted the acquisition or movement of the gunpowder, the plot might never have reached Westminster. Today, that lesson is more relevant than ever. Global trade has exploded in scale and complexity, and with it, the risks of misuse have grown. From semiconductors and drone parts to chemicals and encryption software, dual-use goods are everywhere. Governments maintain strict Customs and export frameworks not just for taxation, but to protect national and international security. The Gunpowder Plot, a historical event, is a stark reminder of the power and necessity of strong, modern regulation. This lesson is just as explosive today as it was in 1605.

So, this week, when you're at a fireworks display or lighting sparklers in the garden, spare a thought for the real logistics behind Bonfire Night then and now. The very fireworks we use to commemorate the failure of the Gunpowder Plot are themselves subject to tight import controls, explosive licensing laws, Customs declarations, and safety certifications. It’s a stark reminder that what began with barrels of smuggled gunpowder in a cellar under Parliament is now a lesson in the power and necessity of strong, modern regulation. Compliance, it turns out, is just as explosive a topic today as it was in 1605.

Release of CDS 4.9.1 – Update to Import Declarations

Wed, 05 Nov 2025 13:09:57 GMT

CDS Update 4.9.1 will be released on the 5th November 2025. This will deliver live fixes for error messages received in the Customs Declaration Service.

The following update will apply to UK Import Declarations.

Country codes – ALL movements

Upon changes in the CDS release 4.9.0 that required the country code EU to be declared, it was identified that this caused an error message not to be generated when EU was declared within DE 5/15.

This will be rectified, and an error message will be generated if EU is declared within DE 5/15

EU as a country code is only permitted to be used to declare the country of preferential origin within DE 5/16; it is not to be declared within DE 5/15

When the code EU is declared in DE 5/16, within DE 5/15, enter the country code of the EU member state of origin for the goods.

If Country Code ‘EU’ is entered in DE 5/15, the declaration will be rejected.

The Haunted HS Code

Wed, 29 Oct 2025 13:50:49 GMT

Halloween wasn’t just a marketing opportunity for this company, for Jasper & Veil Ltd.; it was peak season. Their custom ghoulish gift boxes were packed with ghost-shaped biscuits, spooky mugs, novelty sweets, and glow-in-the-dark clothing, and flew off the shelves faster than you could say “trick or treat.”

But to keep things simple at the border, they assigned everything a single tariff code: 9505 – Festive Articles. At just 2% duty, it felt like they’d hacked the system. Mugs with pumpkins? Festive. Chocolate skulls? Festive. Witch socks? Definitely festive!

It was all going perfectly until, out of the blue, HMRC came knocking.

As if it were planned in conjunction with their gift boxes on 31st October, the inevitable HMRC audit came. Right after their biggest shipment to date, the auditor enters. Wrapped in a black coat, wielding a clipboard that resembled a guillotine, he was eerily calm…. Polite but silent.

As he slowly thumbed through the requested import documents, he could be heard muttering under his breath like a witch reciting a spell:

“Biscuits… chocolate… candles… clothing…”

Tom, the operations manager, offered a proud smile. “They’re all Halloween themed. Festive, right?”

The auditor looked up, face expressionless. “Do you realise most of these don’t belong under the commodity code 9505?”

Everyone felt a chill flood the room.

“9505 excludes candles—they fall under heading 3406. Biscuits and chocolate are classified under food chapters and are often subject to quotas, seasonal restrictions, or additional duties. And clothing? Even if it’s got a skeleton on it, it still falls under Chapters 61 or 62.”

Tom’s smile faded faster than a supermarket pumpkin on 1st November.

The auditor didn’t raise his voice. He didn’t need to. He just opened a folder marked “Reclassification” and began writing.

Duty differentials were calculated, interest applied. VAT adjustments followed. By the time the dust settled, Jasper & Veil owed over £60,000, and the horror of a voluntary disclosure suddenly looked like the better outcome. This hefty bill was a stark reminder of the importance of correct classification and the potential financial consequences of misclassification.

Before he left, the auditor turned back at the door and said, almost kindly:

“Let this be a lesson: classification is based on what something is, not how spooky it looks.”

Since that day, Jasper & Veil have treated chapter notes like sacred scrolls. Every HS code is checked, cross-referenced, and questioned. Still on stormy nights, especially in the approach to All Hallows Eve, the warehouse lights begin to flicker and the printer bursts into life for no reason. Some in the warehouse swear they hear a whisper echoing through the loading bay:

“Chapter notes… always read the chapter notes…”

NTE 2025/28: Removal of the UK Arms Embargo on Armenia and Azerbaijan

Wed, 29 Oct 2025 11:58:13 GMT

The ECJU have published Notice to Exporters 2025/28 detailing the removal of the UK arms embargo on Armenia and Azerbaijan.

The Notice, dated 29th October, advises that the UK Arms Embargo, which restricted the supply of weapons, ammunition and munitions that might be used on the land border between Armenia and Azerbaijan by military, police, security forces and related government entities of either state on both countries, ceased to be in force as of 13 October 2025.

Details were presented in the written ministerial statement, as detailed at the link below:

Written statements - Written questions, answers and statements - UK Parliament

All export and trade licence applications for Armenia and Azerbaijan will continue to be assessed on a case-by-case basis against the  Strategic Export Licensing Criteria (SELC) .

Schedule 4 of the Export Control Order 2008 is expected to be amended in due course to reflect this change.

Contact Details for the ECJU

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 on legislation.gov.uk

Telephone 020 7215 4594

Don’t Let Compliance Become Your Horror Story

Tue, 28 Oct 2025 16:45:28 GMT

Export and import controls aren't just red tape…. They are serious! The penalties are real, and the ghosts of mistakes past are hard to banish. So this Halloween, double-check your HS codes, origin declarations, OGEL conditions, and valuation methods. Because nothing's scarier than the words: "You are under investigation."

The Origin Mistake: A Tale of Tariff Terror

When Trump returned to the White House in 2025, one of his first moves was to reinstate and expand tariffs on Chinese-origin goods, citing "economic resilience" and "national security." For UK exporters with links to US supply chains, it marked the start of a new nightmare. At Braxwell Components Ltd, Nigel—the ever-efficient sales director—was proud of his ability to turn orders around quickly. He wasn't one for fine print or footnotes, especially when it came to customs paperwork. So when it came time to fill in the Certificate of Origin for a shipment of control units headed to a key US client, he didn't hesitate: "UK origin," he declared, as the company always had. After all, the units were checked and packed in Leeds, and some of the Chinese parts did fit together.

Surely that made them British enough, didn't it? Weeks passed without incident. But then came a cryptic email from the customer's US customs broker: "Urgent: Query on declared origin under 2025 Section 301 tariffs. Please confirm the Chinese content." Nigel dismissed it. "All UK assembled," he replied. But questions kept coming back, and details of the "assembly" were requested, and all the time the goods were delayed in customs, and the customer was getting very jittery. Then a 2nd, a 3rd and a 4th import from Braxwell were detained. The Halloween decorations in the office seemed to grin menacingly at Nigel, especially that stupid spider!!!

Then came the final email. This time it included flagged entry reports, documentation reviews, and a worrying phrase from the US Customs and Border Protection (CBP): "Substantial transformation not met." US Customs had classified the items as Chinese-origin, regardless of where they were "assembled". That meant Braxwell's clients owed the full additional tariff rate on the imports – an eye-watering potential of up to 84% or more, once you stacked Section 301 duties, IEEPA surcharges, and Trump's new "reciprocal" tariffs. Retrospective duty charges were being assessed on imports that had been allowed in as UK origin. Head in hands, Nigel sadly acknowledged the message from one client cancelling all future orders; another threatened litigation.

Nigel tried to argue the logic of UK labour and assembly, but logic doesn't override regulation – even his Halloween spider seems to shake its head. Braxwell had also been warned that they could now face investigation under US and UK compliance frameworks.

The lesson was clear: origin isn't about where a box is closed—it's about where its value is created. For Nigel, Halloween came early—and it brought spreadsheets, angry customers, extra duties, and a potential loss of market access, not to mention a laughing spider.

NTE 2025/27: Notice to Extend the General Trade Licence Russia Sanctions – Sectoral Software and Technology from 20th October 2025 to 17th April 2026

Fri, 17 Oct 2025 14:32:56 GMT

The ECJU have advised that the General Trade Licence Russia Sanctions – Sectoral Software and Technology, due to expire on 20th October this year, is to be extended until 17th April 2026

The licence, which came into force on 21 July 2025 and was due to expire on 20 October 2025, has been extended to provide additional time for licensing processes to be completed. This is intended to ensure that legitimate use of sanctioned software and technology can continue without disruption.

If a business has questions about the impact of Russian sanctions on its UK operations in any sector, or on business operations in Ukraine or Russia, it is advised to contact the export support team at the link below.

Contact the export support team.  

The export support team are providing a front-line Russia Sanctions Support Service to all businesses.

The regulations to which this notice relates are available at the link below:

Contact details for the ECJU are below:

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Moving to a single list for UK sanctions designations, 28 January 2026 – Guidance to help business and industry prepare to use the UK Sanctions List as the only source for UK sanctions designations after the closure of the OFSI Consolidated List of Asset Freeze Targets.

Telephone 020 7215 4594

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Moving to a Single List for UK Sanctions Designations, 28 January 2026

Mon, 13 Oct 2025 15:16:32 GMT

The UK Government have announced that the OFSI Consolidated List of Asset Freeze Targets is closing. From Wednesday, 28 ^th January 2026, the UK Sanctions List will be the only source for all UK sanctions designations.

Currently, there are two sources for UK Sanctions Designations:

The UK Sanctions List (UKSL)
The Consolidated List of Asset Freeze Targets (OFSI Consolidated List)

From 28 ^th January 2026, this is changing, and a business that regularly uses both the UKSL and the OFSI Consolidated List will need to prepare for this change. In particular, this is imperative for businesses whose systems source data from the OFSI Consolidated list or rely on the “OFSI Group ID,” as these systems will need to be updated.

What is the UK Sanctions List?

The UK Sanctions List is the primary list of sanctions designations – it provides comprehensive information on those persons placed under sanctions made under the Sanctions and Money Laundering Act 2018 (SAMLA).

Why the move to a single list?

In response to industry feedback, which indicated that duplication of effort was happening when checking both lists, and the merger of one list would simplify checks and aid the industry.

From 28th January 2026, the UK Sanctions List will be the only source of information detailing sanctions designations published by the UK Government. From this date on, the OFSI Consolidated list will no longer be updated.

How to prepare?

Understanding the impact of the closure of this list on your business will be crucial to preparing for this change. Switching to the UK Sanctions list as the primary source of data well in advance. The UK Sanctions List is now live, enabling screening and comparison of differences between the two lists.

The ‘OFSI Group ID’ identifier is being retired

There will be a change to how newly designated persons (DPs) subject to financial sanctions are identified.

Any external systems that use ‘OFSI Group ID’ to identify DPs subject to financial sanctions will need to be updated to use the UK Sanctions List ‘Unique ID’ and ‘Sanction Type’ fields instead.

Currently, all DPs and specified ships are given a ‘Unique ID.’ Those DPs subject to financial sanctions are also given an ‘OFSI Group ID.’

From 28 ^th January 2026, newly designated DPs subject to financial sanctions will not be assigned an ‘OFSI Group ID’ and will only have a ‘Unique ID’ as an identifier.

Further information

For specific queries about the content of this notice, please email:  ofsi@hmtreasury.gov.uk

Notice to Exporters Update 2025/26 Dated 2nd October 2025

Mon, 06 Oct 2025 14:04:49 GMT

Today, the Export Control Joint Unit have issued NTE 2025/26 in relation to an update on the Open General Export Licence (AUKUS Nations). AUKUS is a trilateral defence partnership between Australia, the United Kingdom and the United States, announced in September 2021.

This latest update refers to NTE2024/18 , dated August 16, 2024, which provided details on the publication of the OGEL for AUKUS Nations, along with guidance notes and an update on the agreement.

When using OGELs, it’s important to review the Terms and Conditions to check compliance responsibilities and review any updates made to the licence. NTE2025/26 confirms that the existing AUKUS Nations OGEL has been revoked, and an updated version has been uploaded, which is included here for reference.

https://assets.publishing.service.gov.uk/media/68dbd2ab49e17d00a56ffc1b/open-general-licence-aukus-nations.pdf

The latest version of the OGEL updates text on the Authorised User Community, Clarification on the F680 Requirements and a revision on items not permitted by the licence.

An Exporter must be on the Authorised User Community list to use the OGEL. Additionally, the export, transfer, supply or delivery of controlled goods under the OGEL can only be made to entities within the Authorised User Community. The OGEL confirms that “A person within 'Authorised User Community' means an eligible member who has undergone an authorised user enrolment process, in coordination with the Department’s Directorate of Defence Trade Controls (DDTC), and who is listed as a person in the Authorised User Community”.

The OGEL states that “US and Australian persons within the AUC operating in the UK but who are ordinarily domiciled outside the UK are permitted to register for and use this licence, but only for intangible technology transfers”

In relation to the F680 Procedure, the updated OGEL states, “For any Australian or US persons operating in the UK but who are ordinarily domiciled outside the UK using this OGL for intangible technology transfers, there is no requirement for them to obtain further F680 approvals. Note: The UK contractor should have already obtained any necessary F680 approval to release this technology to the Australian or US recipients in the UK. Note: The UK contractor should have already obtained any necessary F680 approval to release this technology to the Australian or US recipients in the UK.”

Further details can be found in the updated AUKUS National OGEL Guidance Notes

https://www.gov.uk/government/publications/open-general-licence-aukus-nations/open-general-licence-aukus-nations-guidance-note

In relation to the revision on Items not permitted by the AUKUS Nations OGEL, the updated licence provides three criteria in the “Goods, technology and software that can be exported or transferred under this licence” section on Page 2, which must be reviewed in conjunction with Schedule 1 and Schedule 2, which begins on Page 7.

HMRC: Update on Proposed Changes to Document Status Codes for CHED Document Codes on a Declaration

Fri, 03 Oct 2025 11:41:37 GMT

HMRC have announced their long-term intention to remove the XX document status code on a CDS declaration, leaving XW as the only available document status code.  

In due course, document status code XW will be intended for use where a CHED is required for the consignment and where documents C085, C640, C678, N002, N851 & N853 are presented on the declaration to confirm that a waiver applies.

XW is anticipated to be restricted to NIRMS declarations, when being used with CHED document codes.

Use of waiver document codes and waiver document status codes

Declarants are advised to double-check whether a consignment requires a CHED before using any of the document waiver codes, or when using a CHED document code with a waiver status of XX or XW.

Where a waiver is claimed, declarants are reminded to ensure that they can meet the terms of that waiver before using the related code.

Document Status code XX

Appendix 5A of the Tariff has already been amended to remove the option of using document status code XX with document codes C085, C640, C678, N002, N851 & N853.

However, this change in Appendix 5A will not be live in CDS until 23rd October 2025.

HMRC is encouraging declarants to start using the appropriate waiver document codes now, instead of declaring the CHED document code with a status code of XX.

Document code C085 and N85: CDS Update 23rd October

CDS will be updated on October 23, 2025, and will be set to reject a declaration where the XX status code is declared with document code C085 or N851.

If declaring goods where codes C085 or N851 would have been used with document status code XX, declarants should:

Confirm that a CHED is not needed for the consignment
If the tariff measures for the commodity code include a related waiver document code, the referenced waiver document code should be declared instead of C085 or N851

Note : If using a code to support the use of a waiver, ensure that the conditions associated with that waiver are met

If the commodity code does not have a relating waiver document code, then codes C085 or N851 should be used with document status code XW, until appropriate document codes are added to the commodity in the future.

DEFRA is reviewing the tariff measures to ensure that waiver document codes are in place in due course.

Document Status Code XW

Plans to restrict the use of CHED document codes with a document status code XW to NIRMS only consignments are on hold until DEFRA review the waiver document codes available against the CHED document code tariff measures.

EU CHED-PP measure

HMRC expects the EU to add its CHED-PP measure to the Northern Ireland Tariff on 20th October 2025, with an entry into force date of 29th October 2025.

What this will do

This will add the requirement to declare the CHED-PP against document code C085 or for one of the waiver document codes to be used, if the consignment qualifies.

If the consignment qualifies, waiver codes Y122, Y146 or Y979 will be available.

Document code Y146. Presentation of a licence

Use of document waiver code Y146 is subject to the importer holding a licence to import goods for scientific purposes.

Changes will be made to the CDS declaration completion requirements to include the licence identification in the document field.

The incremental changes in CDS will mean that initially, CDS will require both the document ID and document reason to be completed with the licence ID when using document code Y146.

UK Trade Tariff Measures Using Document Code C085

Document C085 testing is planned for later in 2025 to ensure that document code C085 operates effectively in conjunction with BTMS.

The UK tariff measures will be updated to mandate the declaration of the CHED-PP against C085, in due course.

Export Control Joint Unit

Thu, 02 Oct 2025 10:57:50 GMT

As a result of the UK Government's 2015 Strategic Defence and Security Review, the ECJU, Export Control Joint Unit, began operating on Monday, 18th July 2016, to bring together policy and operational skills from government departments, including the Export Control Organisation and the Ministry of Defence. The ECJU’s role is to promote global security through strategic export controls.

For many exporters, the interface with the ECJU is through the licensing portals SPIRE and its replacement, LITE, which stands for Licensing for International Trade and Enterprise. Goods can be controlled at export for a variety of reasons. Still, the ECJU considers strategic controls relating to products, as well as technology and technical information related to the goods, such as drawings or blueprints. Software can also be controlled as a Strategic item.

The ECJU publish the “Consolidated list of Strategic Military and Dual-Use Items that require export authorisation” Although the title suggests two classification types, the list contains seven sections; the UK Military List, Dual Use List Annex I and IV, UK Dual Use List, Non-Military Firearms List, Human Rights List, UK Security and Human Rights List and the UK Radioactive Source List.

For Military and dual-use controlled goods, it may be possible to use an “open approval” in the form of an OGEL, Open General Export Licence or a GEA, Assimilated General Export Authorisation. These approval types require the licensee to know the classification of the Goods, Technology, or Software and ensure they can adhere to the Terms and Conditions. A single licence registration on SPIRE allows for multiple uses, while also acknowledging the responsibilities of compliance, which will be assessed during an ECJU audit.

LITE’s implementation began with private beta access, where selected exporters were able to use the new system before it went live as a public beta in September 2024. Currently, LITE is only for SIEL (Standard Individual Export Licence) applications, with certain exceptions still requiring an application on SPIRE. F680 applications are also made on LITE. Gov.uk confirms that “F680 approval is required before the transfer of any classified material graded OFFICIAL-SENSITIVE or above (including international classified equivalents) or any ITAR material to any foreign entity, including where these transfers occur within the UK borders”

ITAR refers to the United States International Traffic in Arms Regulations, which is an additional compliance responsibility for exporters to consider when items are controlled under the United States Munitions List.

What is GVMS?

Mon, 29 Sep 2025 13:28:59 GMT

GVMS, or the Goods Vehicle Movement Service, was introduced following the UK’s exit from the EU, to allow both EU imports and exports to flow more efficiently through UK RORO ports. You should bear in mind that these EU facing RORO ports, unlike the deep-sea container port and major international airports, lacked the infrastructure (no electronic inventory control system – also known as the pre-lodgement model) to handle exports and imports.

Full implementation of GVMS occurred on January 1, 2022, for Imports and exports, with partial integration in effect from January 1, 2021.

GVMS works by allowing the risking of declarations (i.e., cleared, or uncleared) in HMRC systems and automatically arriving the declaration on HMRC’s Customs Declaration Service (CDS) when the goods physically arrive the port.

The GMR (Goods Movement Reference) is created within GVMS by linking the vehicle registration and Customs declaration together. The automatic number plate recognition (ANPR) cameras read the vehicle registration at the RORO location and allows the port to subsequently arrive the Customs declaration on the CDS system.

By doing so at this point, the haulier will know if the goods are Customs cleared or if there is a requirement for the goods to be held or inspected following documentary or physical inspection.

Who can apply to use it?

GVMS is an online service available through Gov.uk, enabling traders, hauliers, and agents to register and link Customs declarations to vehicle registrations. It is not dependent on a specific party, although in most cases, it is the haulier who is responsible.

This is because the Haulier is usually the party that knows all the transport details, such as the vehicle registration and Customs declaration.

You only need to register once to use the service, which can be activated here - https://www.gov.uk/guidance/register-for-the-goods-vehicle-movement-service

Do you need to submit more than one GMR?

A GMR (Goods Movement Reference) is the reference number generated once the details have been submitted through the GVMS service. It allows the declaration references to be linked together so that the person moving the goods only has to present one GMR reference at the port.

Did you know? For exports from the UK, goods cannot board the ferry or Eurotunnel until a GMR has been created, and for imports into the UK, goods cannot board the ferry or Eurotunnel until there is a GMR in place.

The haulier cannot board the ferry without the GMR.

Are all ports GVMS ports?

Not all ports are GVMS ports, and specific export ports require an Arrived Export Declaration to be submitted. This is port-dependent, and further guidance on this can be found here: https://www.gov.uk/guidance/check-which-locations-need-an-arrived-export-declaration-from-1-january-2022

Some ports have both an inventory control side and a GVMS side, so you would need to check with the Carrier/Ferry company accordingly before import or export. Your haulier may also be able to handle this, so you can always double-check.

https://www.gov.uk/guidance/list-of-ports-using-the-goods-vehicle-movement-service

What about transit movements?

Transit movements are also managed through GVMS, which allows for the automatic operation of transit functions.

You will need the MRN of the Transit Accompanying Document for imports under transit, or the DUCR (Declaration Unique Consignment Reference) for exports under transit.

Are all imports and exports through GVMS subject to inspection?

The answer to this is no; not all shipments are inspected by Border Force or for a documentary inspection by the national clearance hub.

Just as not all shipments through a container port or airport are inspected.

You can check if you need an inspection for your shipment that is imported or exported by using the following link:

Check if you need to report for an inspection - Check if you need to report for an inspection - GOV.UK.

To use the service, you will need to know the GMR reference of the goods being imported or exported.

If you need to attend an inland border facility, you would be directed as such, and there is further guidance which can be found here: https://www.gov.uk/government/publications/attending-an-inland-border-facility/attending-an-inland-border-facility

Note that you may be liable for a penalty of up to £2500 if you do not follow HMRC guidance.

The Full GVMS collection of HMRC guidance can be found here: https://www.gov.uk/government/collections/goods-vehicle-movement-service.

Simplification of GB Export Declarations CDS Update 4.9.0

Thu, 25 Sep 2025 12:04:47 GMT

HMRC has, under the CDS update 4.9.0, started to simplify Export Customs Declarations. This update is scheduled to be implemented as of September 27, 2025.

Will Exporters be affected by the changes?

It is both the Exporter and the declarant.

The declarant is the party who submits the Export declaration, which could be the Exporter if they submit their own Customs Declarations.

This can also be a third party, such as a Customs agent, Customs broker, Haulier, or fast parcel operator, for example.

The simplification of the Customs Declaration means that some optional data elements will need to be completed.

Optional, meaning they may not be mandatory for your export declaration, as they may be before the 27th of September 2025.

This is also optional, meaning that it may or may not be included on your Export Customs Declaration, and we will discuss this further.

What about Export Compliance?

Any simplifications do not remove the compliance requirement as an exporter, which remains the same after this update. It is always the exporter's responsibility to ensure that the declaration is completed correctly.

It is the exporter's responsibility to ensure that the correct details are submitted within the export entry. That includes any document codes, licences, measures, or waivers.

As an exporter, you must still ensure that you receive a DMS EOG, which is an ‘exit of goods’ message for your export, to claim VAT zero rating, or hold alternative evidence; none of the optional data elements we will discuss will change this requirement.

Further guidance on VAT zero rating evidence can be found within VAT notice 703

https://www.gov.uk/guidance/vat-on-goods-exported-from-the-uk-notice-703

What are the Export Simplifications?

The simplifications below are only applicable to GB Exports and not in relation to NI shipments.

Full Export Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the B1, B2, and B4 Declaration Categories.

The Data Elements are as follows:

DE 3/19: Representative Name and Address

DE 4/15: Exchange Rate

DE 5/14: Country of Dispatch/Export

DE 5/26: Customs Office of Presentation

DE 6/13: CUS Code

DE 7/5: Inland Mode of Transport (This may cause a temporary conflict with CSE requirements for this DE. This will be rectified in a future update.)

DE 7/14: Identity of Active Means of Transport Crossing the Border

DE 7/15: Nationality of Active Means of Transport

Export Simplified Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the C1 B&E or C1 C&F Declaration Categories.

The data elements are as follows:

DE 3/19: Representative Name and Address

DE 5/26: Customs Office of Presentation

DE 5/27: Supervising Customs Office

Please note that other areas may still require some of these data elements from the Declaration Completion Instructions.

Export Supplementary Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the B1 or B4 Declaration Categories.

The optional Data Elements are:

DE 3/19: Representative Name & Address

DE 4/15: Exchange Rate

DE 5/14: Country of Dispatch/Export

DE 5/26: Customs Office of Presentation

DE 5/27: Supervising Customs Office

DE 6/9: Type of Packages

DE 6/11: Shipping Marks

DE 6/13: CUS Code

DE 7/2: Container

DE 7/10: Container ID NO

DE 7/14: Identity of Active Means of Transport Crossing the Border

DE 7/15: Nationality of Active Means of Transport

Where could we find Further Information?

HMRC also states that other areas may still require some of these data elements from the Declaration Completion Instructions. Because of this, it is crucial to review the completion rules outlined in Tariff Volume 3 for CDS.

https://www.gov.uk/government/collections/uk-trade-tariff-volume-3-for-cds--2

What about Due Diligence Checks on our Export Entries?

If you are issuing instructions to a third party, it would be recommended to check against the above data elements and also against the full CDS 4.9.0 update that has been published: https://www.strongandherd.co.uk/cds-version-4-9-0

As discussed, there are no changes to an exporter's responsibility. We have the potential for optional data elements to be optional; these may or may not be completed within an export declaration, but that does not remove any other compliance requirements.

These changes do not in any way reflect data element DE 2/3, where export licences such as SIEL or OGEL are declared. Nor does this change any exemptions to these licences, which would also need to be declared in DE 2/3.

Upon reviewing your clearance instructions, it is essential to ensure that the Tariff Volume 3 is cross-referenced as of 27th September 2025.

Additionally, these changes do not alter the requirements and responsibilities under direct or indirect representation, should you be using any third parties to submit your Customs Declarations.

If you would like to learn more about the CDS 4.9.0 update or gain a clearer understanding of the optional data elements, please contact us.

A Spotlight On: What is Transit?

Wed, 24 Sep 2025 13:24:02 GMT

Transit, or Common Transit as it is often referred to, is a Customs procedure to move goods between two points of a Customs territory or between two or more Customs territories.

By using Transit, you enable the temporary suspension of duty and taxes at the point of arrival into a Customs territory.

Using Transit allows Customs formalities to be completed at a designated office of destination, rather than at the first point of arrival into the Customs territory.

You do not need to produce multiple Customs Declarations for goods moving through different territories under Transit.

If you are not using Transit, you may need to produce multiple Customs Declarations for each movement.

An example of this is a movement from the UK through France, Switzerland, and into Italy, for instance.

What would be required from a Customs Declaration perspective?

An Export declaration from the UK, followed by

An Import declaration into France, followed by

An Export declaration from France followed by

An Import declaration into Switzerland followed by

An Export declaration from Switzerland, finally followed by an Import declaration into Italy.

That could be very costly (with six potential Customs Declarations) and very time-consuming, as Transit could be a benefit. An export entry from the UK and an import entry into Italy would be required, along with the TAD.

The TAD (Transit Accompanying Document) travels with the consignment and is scanned at each point throughout the journey at each Customs checkpoint.

Simply meaning that the Transit movement can be discharged, and then the shipment is Customs cleared, not at the port of arrival, but inland, for example. Only countries within the CTC use Transit.

What is the CTC?

The CTC is the Common Transit Convention; it consists of all the countries which are within the CTC that allow the use of Transit.

The countries are as follows:

United Kingdom of Great Britain and Northern Ireland
The European Union – 27 member states
EFTA countries - Switzerland, Iceland, Norway, Liechtenstein
Türkiye
The Republic of North Macedonia
Serbia
Ukraine.

The CTC countries all permit the use of Transit, which is used to streamline movements. The agreement allows for the movement of goods through the group of countries without requiring Customs formalities and taxes until the goods reach their destination.

How does transit work?

Transit works by creating the TAD, which is the Transit Accompanying Document. The TAD document is used to verify the movement in transit from the office of departure through the office(s) of Transit until the office of destination.

When the goods arrive at the destination office, the TAD is now discharged, which closes the TAD movement.

Closing the Transit movement also removes the guarantee that is placed upon the movement, which we will also discuss.

What is important to remember is that the TAD is just one half of the requirement; the goods still need to be Customs cleared, and a Customs Declaration would still need to be made at import.

Just because the goods are released from Transit does not mean that they are released from Customs control; they are not.

Can anyone use Transit?

Yes, anyone can use Transit, although there are stipulations in place. One of the requirements is that the exporter or holder of the transit procedure must hold a financial guarantee against the Transit movements.

The Guarantee is in place to ensure that it covers any potential debt from duties or taxes that would be due if the goods never arrive at the destination office.

You must be established in the UK to have the guarantee in place, have no serious or repeated infringements of Customs or tax rules within the last 3 years, and have no record of any serious criminal activities in the previous 3 years.

In most cases, it is the carrier, haulier, agent, or broker that holds the Transit procedure, and they use it for the movement of goods.

Although, as stated, anyone can use Transit, so as an exporter, you can use the facilitation if you wish.

Are there any simplifications?

There are two Transit simplifications in place. They are:

Authorised consignor
Authorised consignee

Starting at the authorised consignor, this allows us, as an authorised consignor, to initiate movement from the authorised consignor's premises at the time of export.

The authorised consignee works in the reverse; it allows for the movement to end at the authorised consignee premises, whereas we have seen that the TAD is discharged and Customs clearance takes place.

As I said, in most cases, a third party is used as the holder of the Transit procedure, and in most cases, the authorised consignor and consignee are also the carrier, haulier, agent, or broker.

Are there any compliance requirements?

There are indeed Customs formalities or procedures using Transit, which are a very stringent regime.

There are time limits for using Transit, meaning you must ensure that the goods are delivered within the specified time period outlined in the TAD document.

You can be fined; the holder of the Transit procedure could be liable for civil penalties for serious or repeated infringements.

All parties, from the office of exit to the office of destination, will have access to the Transit details. Therefore, it is not just UK Customs that will be checking; it could also be overseas Customs, verifying that the goods have arrived, been discharged, and cleared within the correct time period.

Authorisations can be removed; for example, a visiting officer could revoke or remove an authorisation for non-compliance.

With thanks to Andy Baker for this month's Spotlight On.

Simplification of GB Import Declarations CDS UPDATE 4.9.0

Tue, 23 Sep 2025 13:55:18 GMT

HMRC, under the CDS update 4.9.0, has started to simplify import Customs declarations. This update is scheduled to be implemented from the 27th of September 2025.

What does this mean for traders?

Who will be affected by these potential changes, you may ask? Well, it is both the Importer and the declarant.

The declarant is the party that submits the import declaration, which could be the importer if they submit their own Customs declarations. This could also be a third party, such as a Customs agent, Customs broker, Haulier, fast parcel operator, for example.

The simplification of the Customs declaration means that some optional data elements will need to be completed. Optional, meaning they may not be mandatory for your import declaration, as they may have been if submitted before 27th September 2025.

Optional also means that they may or may not be completed on your import Customs declaration, and we will discuss this further.

Does this change any compliance requirements?

Even though we have this simplification, this does not remove the compliance requirement. The requirement is that it is the importer's responsibility to ensure that the declaration is completed correctly.

It is the importer's responsibility to ensure that the correct duty and VAT have been paid at the time of import, and that all relevant documents and licenses have been declared.

Often, that can lead to misinterpretation or incorrect information being completed on the Customs declaration. We have discussed the complexity and requirements under Customs regulations regarding compliance many times, and it is essential to understand these requirements, especially with the new simplifications.

So, what are the simplifications?

Below, it is broken down into each Import declaration section; these simplifications are only for GB imports. These do not apply to NI declarations:

Full Import Declarations

The data elements below have been amended to be optional for specific Declaration Categories under the H1, H2, H3, H4, and H5 Declaration Categories.

The optional Data Elements are:

DE 3/19: Representative Name & Address

DE 4/11: Total Amount Invoiced

DE 5/26: Customs Office of Presentation

DE 5/27: Supervising Customs Office

DE 6/13: CUS Code

DE 7/5: Inland Mode of Transport

DE 7/15: Nationality of Active Means of Transport

Import Simplified Declarations

The data elements below have been amended to be optional for specific Declaration Categories under the I1 B&E and I1 C&E Declaration Categories.

The optional Data Elements are:

DE 3/17: Declarant Name & Address

DE 3/19: Representative Name & Address

DE 4/11: Total Amount Invoiced

DE 5/36: Customs of the Office of Presentation

DE 5/27: Supervising Customs Office

DE 6/13: CUS Code

Import Supplementary Declarations

The data elements below have been amended to be optional for specific Declaration Categories under the H1, H3, H4, or H5 Declaration Categories.

The optional Data Elements are:

DE 3/19: Representative Name & Address

DE 4/11: Total Amount Invoiced

DE 4/15: Exchange Rate

DE 5/26: Customs Office of Presentation

DE 5/27: Supervising Customs Office

DE 6/9: Type of Packages

DE 6/11: Shipping Marks

DE 6/13: CUS Code

DE 7/2: Container

DE 7/5: Inland Mode of Transport

DE 7/9: Identity of Means of Transport on arrival

DE 7/10: Container ID no.

DE 7/15: Nationality of Active Means of Transport

Where could we find further information?

HMRC also state that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

Because of this, it is crucial to review the completion rules within Tariff Volume 3 for CDS.

https://www.gov.uk/government/collections/uk-trade-tariff-volume-3-for-cds--2

What about due diligence checks on our import entries?

It is also important to note that within the simplification, you will notice that DE 4/11, which is the total invoice value, will become optional. There is potential for under- or overpayment of duties and VAT if this is optional within your Customs declaration, and it is not completed.

Why is that the case? Because DE 4/11 forms a verification, the declaration cannot move forward. It will be rejected if the item values (if we are declaring more than one item) do not match the total value at the header level in DE 4/11.

What happens if this is to become optional on your declaration and it is not completed? You cannot check the total value declared in DE 4/11 on the CDS declaration against the commercial invoice value because DE 4/11 would be blank.

You would need to verify that the values of all items add up to the total value declared on the commercial invoice. CDS allows up to 99 line items.

As part of due diligence, the declaration that you hold as evidence would still need to be a cleared Customs declaration, and any other mandatory data elements would remain to be completed accordingly.

If you are issuing instructions to a third party, it would be recommended to check against the above data elements and also against the full CDS 4.9.0 update that has been published:

https://www.strongandherd.co.uk/cds-version-4-9-0.

Also, ensuring that the Tariff Volume 3 is cross-referenced from the 27th of September 2025.

These changes do not alter the requirements and responsibilities under direct or indirect representation, should you be using any third parties to submit your Customs declarations.

If you’d like to learn more about the CDS 4.9.0 update or gain clearer insight into the optional data elements, please contact us here.

Free Trade Agreements – Back to Basics

Thu, 18 Sep 2025 12:34:40 GMT

If you’re venturing into the world of international trade or already trade internationally, you’ll inevitably encounter the phrase ‘Free Trade Agreement’ (FTA). Sounds fancy, right? In plain English, it’s just a deal between countries to make buying and selling goods across borders cheaper and easier. Think of it as the “mates’ rates” of international trade — fewer barriers, fewer tariffs, and fewer Customs headaches.

For UK importers and exporters, understanding how FTAs work isn’t just practical; it can give you a real commercial advantage (and save you from paying more duty than you need to).

What is a Free Trade Agreement?

An FTA can be referred to by different names, but the theme remains the same: two or more countries agree to lower trade barriers. This usually means cutting or removing Customs duties (those pesky taxes on imports), agreeing on clear product standards, and smoothing out Customs procedures so you’re not bogged down in red tape. In short, FTAs are trade’s way of saying: “let’s make life a bit easier” and bring down the costs.

If you’re buying from a country the UK has an FTA with, chances are you’ll pay lower import duties, sometimes zero. That means more money stays in your business (or your pocket). FTAs also widen your supplier options. You’re not just stuck shopping from the same old markets; you get a bigger catalogue of potential suppliers, often with better prices.

And let’s not forget the Developing Countries Trading Scheme (DCTS), which is akin to the UK providing a helping hand to suppliers in less-developed countries. It’s not just good for your margins; it’s also good for global development. Win-win.

If you’re selling UK goods abroad, an FTA can significantly enhance the appeal of your product. Why? Because your overseas customers don’t have to pay hefty tariffs to import them. That could be the edge that gets you into new markets. Some FTAs also streamline the paperwork. Fewer forms, fewer arguments at the border, and fewer grey hairs for you (too late for me!)

Of course, nothing’s ever entirely free – what’s the catch? Specific Product Rules of Origin apply. To claim the benefits of an FTA, you need to prove your goods meet the Rules of Origin in that agreement. This doesn’t mean you don’t just have to know where you shipped from — it means where the product was made. And this might not be as easy as it sounds.

You need to understand other areas of Customs regulations to assess whether goods qualify under the terms of an FTA, that is, whether they qualify for lower duty rates or simplified procedures. You’ll need to check your product’s commodity code (also known as the Harmonised System code, HS Code, or Tariff number) and understand the specific Origin rule applicable to those under that code. And then you will need to keep records (because HMRC loves records). The records need to include the correct Proof of Origin—but under UK FTAs, that is often just a simple declaration on your invoice.

It is worth learning about FTAs because they can save you money, boost your competitiveness, and give you access to markets you might not have considered. But it’s a big but, only if you understand and use them correctly.

FTAs might sound like something only trade lawyers or policy experts care about, but for small businesses, they can be the difference between “just surviving” and “seriously thriving.” Think of them like a gym membership: having one doesn’t magically get you fit — you have got to know how to use it. But once you do, the benefits can be huge. And if the jargon still makes your head spin, you don’t have to figure it out alone.

Strong & Herd’s training is like a friendly personal trainer for your Customs paperwork — breaking it down into steps, showing you the correct technique, and keeping you from injuring yourself (financially, in this case). So don’t leave money on the table. Learn how to flex those FTAs and turn “trade barriers” into “trade opportunities.”

CDS Version 4.9.0

Wed, 17 Sep 2025 12:21:10 GMT

The upcoming CDS update, version 4.9.0, is scheduled for release on 27 ^th September 2025. During this period, please note that any pre-lodged declarations that will be affected by the changes should be changed/amended prior to the goods arriving.

If customs declarations are not corrected prior to arrival, they will be rejected.

We have been advised that CDS will be unavailable from 9.30 pm (27 ^th September 2025 until 5 am (28 ^th September 2025)

IMPORT AND EXPORT UPDATE

Authorisation by Customs Declaration (ABD) EORI

Procedure Code 44 or 51, a valid Importer EORI must be declared in DE 3/16 at the header level.

Procedure Code 21 or 22, a valid Exporter EORI must be declared in DE 3/2 at the header level.

If the correct EORI is not present for Authorisation by Declaration for those Requested Procedure Codes, the Declaration will be rejected.

Authorisation by Declaration declarations should also declare AI Code 00100 within DE 2/2.

Authorisation by Customs Declaration Methods of Payment

Authorised-Use (End-Use)

Temporary Admission (TA)

Inward Processing (IP)

Using Authorisation by Customs Declaration, then the Method of Payment Code must be one of the following: M, N, R, S, T, U, V, Z.

Failure to declare one of the above will result in the declaration being rejected.

Amendments to Currency Codes

Currency Codes for Sierra Leone and Venezuela have been updated as follows:

SLE has been introduced for Sierra Leone.

VED has been introduced for Venezuela.

The old codes should no longer be used; otherwise, declarations will be rejected.

If the invoice is declared in the old currencies, the value must be converted to GBP. That is using the appropriate HMRC exchange rate and ensuring that when declared in GBP, the Document Code 9WKS is declared in DE 2/2 for the worksheet showing the calculations.

Duty Relief

Duty Relief Additional Procedure Codes that are declared using Simplified Procedures must be declared with indirect representation.

Additional procedure codes are 0GD, C04, C08, C19, C22, C24, C27, C28, C29, C40, C51, C52, C53, C54, C55.

Should any of these additional procedure codes be declared in DE 1/11 and Representative Status Code ‘3’ is not within DE 3/21, then the Declaration will be rejected.

Simplifying Customs Declarations – Total number of Items

DE 1/9 Total Number of Items is now optional on all Declaration types.

It will be automatically calculated by CDS based on the number of Goods items declared.

Invalid Procedure Code/Additional Procedure Code Combinations

The following procedure code and additional procedure codes are now not allowed within CDS:

B53 is not permitted with Procedure codes - 2100 or 2144
93M is not allowed with Procedure code - 0019
2CL is not permitted with Procedure codes - 0100 or 4200
1PB is not permitted with Procedure code - 4000
1PL is not permitted with Procedure code - 4000

If any of the additional procedure codes above are declared in DE 1/11 with a declaration, and the procedure code is declared in DE 1/10 for the same item, then the entry will be rejected.

The following procedure codes have been removed from CDS 03C, 1AT, 1SE, 50U, 74O, 91L, 91O, 96F

Document Code DE 2/3 - C505

When declaring C505, you must make sure that :

The guarantee Identification that is declared in the Document ID field is a valid electronic guarantee ID, and the EORI of the guarantee owner must match within either the import or export declaration :

Import Declarations: the EORI must be either the:

Importer DE 3/16
Declarant DE 3/18
Representative DE 3/20

Export Declarations: the EORI must be either the :

Exporter DE 3/1
Declarant DE 3/18
Representative DE 3/20

The declaration will be rejected if these do not match.

This change does not affect declarations where document code C505 has been declared to claim a guarantee waiver in DE 2/3.

Office of Presentation DE 5/27

If you declare either one of the following AI Codes, that is

MORC1

NCSMA

SHNMO

Within DE 2/2 at the item level, then DE 5/27 can now be left blank as no Office of Presentation is required under these AI Codes.

When moving goods into a Customs Warehouse, completing DE 5/27 may still be required.]

Previous Document Type ‘CLE’

When declaring declaration type Z within DE 1/2 for a supplementary declaration following EIDR, then CLE must be entered within the previous document type.

If CLE is not entered when declaring a type Z declaration, then the declaration will be rejected.

Alternatively, if CLE is declared but Z is not declared within DE 1/2, it will also reject

Country Codes

Country code of the EU is only permitted to be used when you are declaring the country of preferential origin with DE 5/16

It cannot be used with DE 5/15

When the EU is declared within DE 5/16, you must complete DE 5/15 within the country code of the EU member state from which the goods originated.

Country Code PR has been added for Puerto Rico, where a licence has been issued against Country Code PR.

The Country Code' US 'should be used for goods that originated in Puerto Rico; in all other cases, the Country Code' PR' is not allowed on NI Declarations.

Purging of unused AI Codes

The following AI codes have been removed from CDS, they are as follows: CXR01, CXR02, CXR03, CXR06, CXR07, CXR08, CXR09, CXR10, CXR11, CXR12, EXGTE, GBILB, GEN17, GEN38, GEN41, GEN42, NIUNC, PFCLM, and VRN01.

Changes to existing Document Codes

When declaring a Document Code that covers an electronic licence, if you declare a non-electronic Status Code, the Declaration will be rejected.

The affected Document Codes are:

9015, 9023, 9031, L100, L139, L142, L143, L144, L146, L148, L838, X802, X805, X806, X807, X808, X817, X819, X823, X824, X830, X831, X832, X834, X835, X836, X837, X838, X838, X839,X840, X841, X841, X842, X990, X992, X993, Y123, Y915, and Y919

Please refer to Appendix 5A for complete instructions on completing these codes.

Goods Location Code amendments

New Goods Location Codes have been added, and some codes have been removed.

4 GVMS Location Codes that have been removed as follows:

Aberdeen: GBAUABDABDABDGVM
Cairnryan: GBAUCYNAYRCYNGVM
Loch Ryan Port: GBAULRPAYRLRPGVM
Ramsgate: GBAURMGRMGRMGGVM

Only the GVMS Location Codes at these locations are affected as per above. All other Goods Location Codes (GLC) at these locations are still in use.

IMPORT AND EXPORT – INVENTORY UPDATE

Additional Procedure Code - 19Z

When declaring a C21I CCR to move goods into, or using a C21E CCR to remove goods from:

Free Zone or Freeport, when an additional procedure code 19Z is declared in DE 1/11, you must also declare Document Code C600 in DE 2/3.

Failure to do so will result in the declaration being rejected.

Additional Procedure Codes - 14C, 40D, 40P, 50D

When using one of the following additional procedure codes - 14C, 40D, 40P, 50D in DE 1/11

Entered within a C21I or a C21E Customs Clearance Request (CCR), the goods must not be subject to any prohibitions or restrictions.

If prohibited or restricted goods are moved under an additional procedure code of either 14C, 40D, 40P, 50D on a CCR, it will be rejected if any of these Document Codes is also declared in DE 2/3:

9104,9105, 9106, 9107, 9005, 9100, 9101, 9102, 9103, 9111, 9112, 9113, 9114, 9115, 9116, 9118, 9119, 9120, C001, C034, C056, C085, C635, C638, C639, C640, C641, C656, C670, C673, C678, C690, I004, L001, L116, N002, N851, N853, X001, X002, Y915

The prohibitions or restrictions can be found in the Integrated Online Tariff under the corresponding commodity code.

Additional Procedure Codes -11A,12A

When goods are being moved under an ATA Carnet using a C21I or C21E CCR and an additional procedure code of either 11A or 12A is declared within DE 1/11, then the previous Document Code 955 must also be entered in DE 2/1.

Failure to do so will result in the rejection of the goods. Also, when using 12A as an additional procedure code, you must ensure that the commodity code is completed within DE 6/14; otherwise, the declaration will also be rejected.

EXPORT DECLARATION UPDATE

Entry in Declarants Records

When Authorisation Type Code ‘EIR’ is entered in DE 3/39,

DE 1/11 must not contain any of these additional procedure codes:

B51,B52, B53, B54, 0MG, 1CD, 1CG, 1DP, 1MP, 1NO, 1NP, 2CD, 2CG, 2DP, 2ES, 2IE, 46P, 48P

Should any of these additional procedure codes be declared with EIR, then the Declaration will be rejected.

Shipping marks

For MOU traders, when making a declaration under B1 MOU, there is a limit of 99 shipping marks or references that can be entered within DE 6/11. If more than 99 are declared, then the declaration will be rejected.

Authorisation by Customs Declaration for Outward Processing Procedures

When you are declaring under Procedure Code 22, one of the following must be present:

Additional Information code (AI) ‘ABDIN’ in DE 2/2 (OP using Authorisation by Declaration),

(AI) ‘OPVAT’ in DE 2/2 (VAT-only Outward Processing, which doesn’t require an OP Authorisation)

C019in DE 2/3 Outward Processing covered by an OP Authorisation

Should none of the above ABDIN, OPVAT, or C019 be present, the Declaration will be rejected.

You must also ensure that the AI code of 100 is entered within DE 2/2 for any Authorisation by declaration declarations.

Simplifying Customs Declarations – for Full Export Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the B1, B2, and B4 Declaration Categories.

Note that these amendments do not apply to NI Declarations.

The Data Elements are as follows :

DE 3/19: Representative Name and Address
DE 4/15: Exchange Rate
DE 5/14: Country of Dispatch/Export
DE 5/26: Customs office of presentation
DE 6/13: CUS Code
DE 7/5: Inland Mode of Transport (This may cause a temporary conflict with CSE requirements for this DE. This will be rectified in a future update.)
DE 7/14: Identity of Active Means of Transport Crossing the Border
DE 7/15: Nationality of Active Means of Transport

Please note that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

Simplifying Customs Declarations – Export Simplified Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the C1 B&E or C1 C&F Declaration Categories.

Note that these amendments do not apply to NI Declarations.

The data elements are as follows :

DE 3/19: Representative Name and Address
DE 5/26: Customs Office of Presentation
DE 5/27: Supervising Customs Office

Please note that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

Simplifying Customs Declarations – Export Supplementary Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the B1 or B4 Declaration Categories.

Note that these amendments do not apply to NI Declarations.

The optional Data Elements are:

DE 3/19: Representative Name & Address
DE 4/15: Exchange Rate
DE 5/14: Country of Dispatch/Export
DE 5/26: Customs Office of presentation
DE 5/27: Supervising Customs Office
DE 6/9: Type of Packages
DE 6/11: Shipping Marks
DE 6/13: CUS Code
DE 7/2: Container
DE 7/10: Container ID NO
DE 7/14: Identity of Active Means of Transport Crossing the Border
DE 7/15: Nationality of active means of transport

Please note that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

Additional Procedure Code - 3RI

When you are declaring the additional procedure code 3RI on an export declaration, you must also declare the document code.

C507 within DE 2/3

If this is not declared, the declaration will be rejected.

Outward Processing: Additional procedure codes

For exports under declaration Category B2

Additional procedure codes 46P and 48P cannot be used in combination with either of the following additional procedure codes.

B53 or B54

Should they be declared together, then the Declaration will be rejected.

Additional procedure code 3PM

3PM cannot be used in conjunction with a CPD Carnet.

Should 3PM be declared within DE 1/11, and either :

CPD- is declared in DE 2/1

9CPD- is declared in DE 2/3

CPD- is declared in DE 3/39

The Declaration will be rejected.

Customs Supervised Exports (CSE)

When a CSE authorisation holder is declared in Data Element (DE) 3/39, then a valid Inland Mode of Transport Code must also be declared in DE 7/5.

Should CSE be completed and no valid inland mode of transport be completed, then the Declaration will be rejected.

EXPORT DECLARATION INVENTORY UPDATE

Guarantees on Export Customs Clearance Requests

Customs Comprehensive Guarantees have been expanded to be allowed on C21E CCRs.

Document Code C505 is to be entered in DE 2/3 at the item level on a C21E CCR. Authorisation Type Code CGU must also be entered in DE 3/39 at the header level.

The Declaration will be rejected if C505 and CGU are not completed as above.

When guarantee details are entered at the header level in DE 8/2 on a C21E, the Guarantee Type Code must also be entered in that DE; otherwise, the CCR will be rejected.

Please note that this would trigger a rejection in cases where the XML message contains an XML tag for the guarantee, but the tag is empty.

The only Guarantee Type Codes that can be completed within DE 8/2 on a C21E CCR are as follows: 0, 1, 5, 8, C, D, E, F, G.

Should any other Guarantee Type Codes be completed, the declaration will be rejected.

Previously, one of the Guarantee Type Codes, which is either 0 or 1, was always mandated when CGU was declared in DE 3/39. This caused potential situations where more than one Guarantee type Code was required.

There will be only one Guarantee Type Code from the above list that is needed.

IMPORT DECLARATION UPDATE

Invalidation of Declarations

When submitting a request to invalidate an entry if DMSROG or DMSCLE has been received, then the request to invalidate will be rejected.

Authorisation by Customs Declaration for Outward Processing and End Use/Authorised Use Procedures

Re-import of goods previously exported for Outward Processing (OP)

When declaring under procedure code 22, one of the following must be present:

Additional Information code ABDOU in DE 2/2 (OP using Authorisation by Declaration)

Document code C019 in DE 2/3 (Outward Processing covered by an OP Authorisation) or

Additional procedure code B06 in DE 1/11 (VAT only Outward Processing, which doesn't require an OP Authorisation).

End Use/Authorised Use

When declaring under procedure code 44 with Additional Information code (AI) in ABDIN in DE 2/2, the Document Code N990 must also be declared.

Ship-Work Authorised-Use (End-Use) is not permitted by Authorisation by declaration, so Document Code ‘C990’ is not allowed on these Declarations.

The declaration will be rejected if ABDIN and N990 are omitted.

Any Declarations involving authorisation by declaration should also declare an AI Code 00100 in DE 2/2.

Document code 9023

Document code 9023 has now been added to the CDS code list; this is due to future tariff measures for firearms import licences.

At present, this code should not be used; however, further information will be provided in advance of the tariff measures from the Department for Business and Trade.

FLEGT licences

For document Code C690 to indicate a FLEGT licence applies to the shipment, Document Status Code XW is no longer valid.

The waiver Document Code listed against the commodity code within the online tariff should be used instead of XW.

Additional Procedure Code - D07

When using additional procedure code D07 in DE 1/11

DE 2/2 must also contain a GEN30 AI Code.

Additional Procedure Code - C48

When using additional procedure code C48 in DE 1/11

Additional procedure code F45 must also be declared

Failure to declare both will result in the declaration being rejected.

Simplified Declaration on an Occasional Basis - I1 B&E

When declaring a simplified declaration under I1 B&E declaration category, the preference code of 118 will no longer be allowed in DE 4/17

The following preference Codes

115119 and 140 are now permitted with I1 B&E Declarations.

Should any preference code other than 100, 115, 119, or 140 be declared under an I1 B&E declaration, then the declaration will be rejected.

Note that if the Preference Code on an I1 B&E Declaration is either ‘115’ or ‘140’, then APC 2MO must also be declared in DE 1/11.

Additional Procedure Codes -1GP and 1PN

The following additional procedure codes, 1GP and 1PN, can only be used under indirect representation, and ‘3’ must be entered in DE 3/21.

If this is not completed with a '3' in DE 3/21 to indicate indirect representation, then the Declaration will be rejected.

UKIMS-EIDR using SPIMM

When a Declaration or C21I EIDR NOP is made to import goods into Northern Ireland (NI) using UKIMS-EIDR under SPIMM, only the following additional procedure codes may be entered within DE 1/11:

1SG or 1EN must be declared

Only the following additional procedure codes may also be declared :

1CO, 1EN, 1GO, 1GP, 1NR, 1RD, 1RM, 1SC, 1SG, 1SP, 1SR, 1TB, 1VW, 1XW, A04, A10, F44, F46, or F47.

The declaration will be rejected if the above additional procedure codes are not completed.

UKIMS-EIDR (non-SPIMM

When UKIMS-EIDR is used to import goods into Northern Ireland (NI) on a non-SPIMM Declaration or C21I EIDR NOP, then only the following additional procedure codes are allowed within DE 1/11

000, 1CL, 1DP, 1EB, 1ES, 1MO, 1NC, A04, A10, 1NO, 1PP, 1SC, 1RD, 1RM, 1VW, 1XW, C06, C09, C10, C11, C12, C13, C14, C16, C17, C20, C21, C23, C25, C26, C30, C31, C32, C34, C35, C36, C37, C38, C45, C46, C47, C49, C50, C56, C57, C58, C59, F44, F45, F46, F47, 1NR

The declaration will be rejected if the above additional procedure codes are not completed.

Currency Limits

Some additional procedure codes are subject to currency limits. When using the following APCs in DE 1/11, you must ensure the values meet the following rules :

F48 is declared, the item price in DE 4/14 must not exceed £135
C07 is declared, the item price in DE 4/14 must not exceed £135
C08 is declared, the item price in DE 4/14 must not exceed £39

Should these be declared and the item price in DE 4/14 is entered in a currency other than GBP, CDS will convert the value into GBP.

If the declared value exceeds the limits, the declaration will be rejected accordingly.

Licence Document Codes on SPIMM Declarations

When importing licensable goods into NI using SPIMM APCs, 1EN or 1SG must not be used.

Should 1EN or 1SG be entered on a SPIMM Declaration, then the Declaration will be rejected if one of the following Document Codes is entered in DE 2/3 on the same goods item:

I001, I004, X843, X844, X845, X847, X848, X849, X850, X851, X852, X853, X854, X855, X856, X857, X858, Y100

Simplifying Customs Declarations – Full Import Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the H1, H2, H3, H4, and H5 Declaration Categories.

Note that these amendments do not apply to NI Declarations.

The optional Data Elements are:

DE 3/19: Representative Name & Address
DE 4/11: Total Amount Invoiced
DE 5/26: Customs Office of Presentation
DE 5/27: Supervising Customs Office
DE 6/13: CUS Code
DE 7/5: Inland Mode of Transport
DE 7/15: Nationality of Active Means of Transport

Please note that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

Simplifying Customs Declarations – Import Simplified Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the I1 B&E and I1 C&E Declaration Categories.

Note that these amendments do not apply to NI Declarations.

The optional Data Elements are:

DE 3/17: Declarant Name & Address
DE 3/19: Representative Name & Address
DE 4/11: Total Amount Invoiced
DE 5/36: Customs of the Office of Presentation
DE 5/27: Supervising Customs Office
DE 6/13: CUS Code

Please note that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

Simplifying Customs Declarations – Import Supplementary Declarations

The data elements below have been amended to be optional for certain Declaration Categories under the H1, H3, H4, or H5 Declaration Categories.

Note that these amendments do not apply to NI Declarations.

The optional Data Elements are:

DE 3/19: Representative Name & Address
DE 4/11: Total Amount Invoiced
DE 4/15: Exchange Rate
DE 5/26: Customs Office of Presentation
DE 5/27: Supervising Customs Office
DE 6/9: Type of Packages
DE 6/11: Shipping Marks
DE 6/13: CUS Code
DE 7/2: Container
DE 7/5: Inland Mode of Transport
DE 7/9: Identity of Means of Transport on arrival
DE 7/10: Container ID no
DE 7/15: Nationality of active means of transport

Please note that other areas may still require some of these Data Elements of the Declaration Completion Instructions.

IMPORT INVENTORY DECLARATION UPDATE

Additional Procedure Code 74A

Additional procedure code 74A has been withdrawn and should not be used.

Any CCRs where 74A has been declared within DE 1/11, the declaration will be rejected.

Upcoming Events & Training Courses this October

Tue, 16 Sep 2025 16:26:42 GMT

Join us in October for comprehensive training courses on Customs compliance and international trade.

Our October sessions are tailored to suit your schedule, offering full-day courses and focused, shorter clinics. Whether you're looking to master the basics of import/export or delve into more advanced Customs regulations, we have a wide range of courses to suit your needs.

See below for further details of October courses.

Last Minute Availability

Our Accredited Learning Pathways are Ideal for professionals who:

✔ Have foundational knowledge but want to apply it confidently in practice
✔ Want to equip themselves with the skills and recognition to lead confidently in international trade
✔ Are stepping into new roles in Customs, International Trade, or Compliance
✔ Are responsible for developing or managing internal Customs policies or procedures
✔ Want to enhance their value to their organisation through accredited, practical skills

Courses

5 Common Customs Mistakes and How to Avoid Them

Mon, 15 Sep 2025 14:26:16 GMT

For SMEs and newcomers, Customs mistakes are more than just annoying; they can result in financial losses, cause delays, and even block shipments entirely. Let’s break down five mistakes beginners often make and how to tackle them early, so your first steps in trade are confident, not chaotic.

Mistake 1: Wrong Tariff Classification

What happens: Assigning the wrong HS code leads to incorrect duties, and HMRC won’t hesitate to correct you, which could lead to unexpected additional costs.

Fix it: Use a Tariff tool and double-check HS chapters, section notes, and if needed, seek help—HMRC has a classification enquiries team. For hands-on practice, look into technical workshops like Strong & Herd’s Tariff Classification Explained.

Mistake 2: Misusing Incoterms® Rules

What happens: Misapplying terms like EXW or DDP can leave your business with unanticipated shipping costs, Customs liabilities, or expose you to non-compliant declarations made by agents selected by your customers/suppliers.

Fix it:

Choose terms that fit your logistics reality. Don’t agree to EXW if you’re arranging collection, or DDP if you can’t handle Customs clearance in the buyer’s country.
Check who controls the paperwork. Ensure that the party responsible under the chosen Incoterm has the necessary resources and authority to handle export/import declarations correctly.
Align with your freight partners. Speak to your forwarder or Customs broker before confirming terms, so they can flag any risks or costs you might not be aware of.
Document responsibilities. Specify in contracts or purchase orders who is responsible for covering transport, insurance, and duties — don’t rely on assumptions.
Train your team. Ensure that sales, logistics, and finance staff are all familiar with how Incoterms work, so that no one commits the business to obligations it can’t meet.

Mistake 3: Ignoring CDS Requirements

What happens: Are you one of the companies that still refer to the old CHIEF box numbers instead of the data elements (DEs) required on the Customs Declaration Service (CDS)? Others apply outdated CHIEF codes that are no longer in use. This leads to rejected declarations, delays in clearance, or costly amendments from your broker.

Fix it: Familiarise yourself with the CDS declaration data you need. Courses such as our Advanced CDS Technical Workshop or Introduction to Customs Procedures provide you with real-life tools, including duty reliefs and CDS elements. Ensure that your references, procedures, and document codes have been updated for CDS. Create an internal reference guide. Translate your most common shipments from “old CHIEF box numbers” into the equivalent CDS DEs, so staff can adapt quickly. Train your team.

Mistake 4: Getting Origin Wrong

What happens: Businesses claim preferential duty rates under trade agreements without holding the correct evidence of origin. Using an invalid statement on origin, or assuming supplier declarations are enough, can trigger HMRC audits, duty reclaims, and penalties. Errors often occur when confusing the country of dispatch with the country of origin, relying on suppliers who can’t prove origin, or failing to maintain the required declarations and supporting records for the proper length of time.

Fix it: Understand the rules of origin. Each trade agreement has specific product rules (e.g., percentage of local content, changes in Tariff headings). Check the exact rule for your goods. Audit your supply chain. Don’t assume — verify that your suppliers can substantiate origin claims if challenged. If necessary, get valid supplier declarations. If you’re using suppliers’ statements, ensure they are correctly worded, signed, and renewed annually if required.

Mistake 5: Incomplete Record-Keeping

What happens: Failing to keep complete Customs records means you can’t prove compliance during an HMRC audit. Missing evidence of export, duty relief claims, or licence usage can result in demands for back duty, fines, or suspension of reliefs. Many businesses fail because they only keep shipping documents, but not the full trail linking export/import declarations to licences and commercial paperwork.

Fix it: Build a complete audit trail. Keep everything connected to each movement: Customs declarations, invoices, packing lists, licences, end-use statements, correspondence, and proof of export/import. Go digital where possible. Use document management systems or shared drives to link records by shipment or declaration reference number. Test yourself. Conduct an internal “mock audit” annually. Can you pull together a complete set of records for a random shipment within 30 minutes? If not, you’re at risk.

So, there you have it, five of the most common (and costly) Customs slip-ups. The truth is, nobody sets out to misclassify goods, pick the wrong Incoterm®, or lose a stack of export evidence in the office recycling bin. However, without the right know-how, these mistakes can creep in quickly, and HMRC doesn’t hand out sympathy cards. The good news? Customs isn’t black magic.

With the proper training, a bit of structure, and maybe one less spreadsheet that only Bob from Accounts can understand, you can keep your shipments smooth and your compliance tight.

Think of training as the sat-nav for your trade journey: sure, you might find your way without it, but why risk detours, fines, and dead ends? Courses like Strong & Herd’s are designed to give you the shortcuts, the “watch out for this” warnings, and the confidence to ship without stress. So don’t just avoid mistakes, get ahead of them. Your future self (and your Customs broker) will thank you.

Why Export? A Beginner’s Guide to Exporting from the UK

Tue, 09 Sep 2025 13:24:51 GMT

For many UK businesses, the idea of exporting can feel like a big leap. Selling your products or services overseas is not only about finding new customers, but also about opening your business up to fresh opportunities, new challenges, and long-term growth.

At Strong & Herd, we often remind businesses: before you begin exporting, make sure you can answer a simple question: why do you want to export?

The benefits of exporting:

Access to new markets

Exporting enables businesses to reach customers they could not otherwise access by trading internationally, rather than solely within the UK. Entering new markets not only increases sales potential but also helps spread risk . Exporting can provide balance by diversifying revenue sources more effectively. A broader market means greater demand, and this demand can sometimes be especially lucrative, for example, in rapidly developing economies where consumers are eager for high-quality goods and services.

Growth and profitability

Many businesses discover that overseas markets bring more substantial profit margins. In some countries, demand for UK goods and services is high, primarily due to their quality, reputation, or innovative products. Increased production to meet international demand can also deliver economies of scale, reducing costs per unit and strengthening competitiveness both abroad and at home.

Innovation and competitiveness

Exporting often pushes companies to think outside the box. By adapting products and services to meet third-country regulations or consumer needs, innovation is often increased, as a product is improved, and efficiency can be enhanced. Competing internationally also drives businesses to raise their standards in areas such as customer service, product design, and supply chain resilience.

Building brand recognition

Trading internationally can strengthen your brand. Over time, a brand that is visible and respected worldwide develops a sense of prestige that can have positive effects even in the domestic market . Operating across borders demonstrates ambition and capability, which builds credibility with both overseas and UK customers. Often, a strong export profile can make it easier to:

secure large contracts
attract investment
recruit talent

Resilience

Businesses with international sales are often better equipped to handle uncertainty. Global events, ranging from economic shifts to political changes, can impact individual markets. However, companies that export can pivot more easily, offsetting challenges in one region with opportunities in another.

Strategic exporting

Success with the exporting market can’t be achieved without a clear sense of purpose and a carefully researched strategy, with much hinging on planning and preparation. A well-researched export strategy can enable businesses to:

set realistic goals
understand the third-country regulatory environment
avoid costly mistakes

Whether your business is new to exporting or seeking to refresh or revisit your approach, issues such as Customs compliance, export controls, logistics, and cultural differences can all pose challenges if not properly managed.

That’s where Strong & Herd can help. Through our public training courses , we provide businesses with the knowledge and confidence they need to navigate international trade effectively. And with our OneCall™ Service , expert advice is just an email away, whether you’re planning your first shipment or tackling a complex Customs issue.

Taking the first step

Diving into exporting can be daunting, but for many businesses, it becomes one of the most rewarding aspects of their operations. Approaching it strategically and methodically, understanding why you want to export, where you want to go, and how to do it compliantly, puts your business on the strongest possible footing for success.

What is an Import Entry?

Mon, 08 Sep 2025 17:52:28 GMT

If you are looking to start importing goods into the UK, it is essential to have a thorough understanding of the requirements and responsibilities associated with the process. One of the key elements is correctly declaring the goods coming into the UK, which is done by completing an Import entry .

An import entry is a legal declaration to HMRC, informing them of goods which have arrived in the UK. The entry can be raised by the importer or a Customs Agent (sometimes referred to as a Customs Broker) acting on behalf of the importer . The import entry is required to ensure that any goods arriving in the UK comply with UK laws, are not subject to any restrictions, and to recover any applicable Customs Duty and VAT.

To complete the declaration, the importer must have, or be able to provide, essential data, including the reason for import, EORI number, VAT number, classification of the goods, valuation, and origin. While some of this information can be found in the commercial paperwork, the importer must conduct their own due diligence to ensure it is correct for the Customs entry. Supporting documents, such as the commercial invoice, packing list, transport documents, and certificates/licenses, must be held by the importer. If the importer wishes to use a third party to carry out their Customs entry, they will need to provide the supporting documents and clearance instructions so the entry can be completed.

Import entries are declared electronically through HMRC’s Customs Declaration Service (CDS), which can be done directly through approved Customs software. When an entry is accepted, checks are completed by HMRC, which determines if further information is required; this could be additional documentary checks or a physical examination of the goods. Once all checks have been made, HMRC will request payment of any Duty and/or VAT. There are different methods of payment, but the goods will only be cleared by Customs once the funds have been recovered.

Finally, accurate information must be used on import entries; any discrepancies can lead to additional funds being required or, in severe cases, fines being imposed by HMRC .

UK Customs Jargon Explained: 15 Terms You Need to Know

Thu, 04 Sep 2025 14:04:47 GMT

Getting into import and export can feel like plunging into a foreign country—full of unexplained shorthand and puzzling abbreviations. No one wants to look lost in conversation or feel overwhelmed when filling out a Customs form. That’s precisely why mastering Customs jargon is a smart starting point—so you can work, communicate, and trade with confidence.

1. HS Code (Harmonised System Code) – A universal numbering system for classifying traded goods. It determines duties, restrictions, and eligibility for trade deals.

2. Incoterms ® Rules – Standard shipping terms (like FCA, DAP) or International Commercial Terms that define shipping responsibilities, insurance, and costs.

3. CDS (Customs Declaration Service) – The UK’s updated system for Customs declarations, replacing the old CHIEF platform.

4. Tariff – The duty or tax imposed on imported goods, determined by the HS Code.

5. Commodity Classification – The process of assigning the correct HS code to your product is critical for accurate duties and compliance.

6. Origin vs. Preference – 'Origin' is where a good is made; 'Preferential Origin' allows reduced duty if specific trade deal criteria are met.

7. Customs Procedure – Four-digit codes that define how Customs processes apply to your shipment (e.g., temporary import, inward processing). Formerly known as CPC (Customs Procedure Code). Completed by a 3-digit Additional Procedure Code to make it more specific to a particular Customs scenario.

8. Transit – Moving goods through a country to another destination, often using a guarantee system like NCTS, for example, goods moving from the UK, across the EU to Switzerland.

9. Temporary Admission (TA) – Allows goods into the UK temporarily (e.g., for exhibition) with reduced or no duty.

10. Inward Processing Relief (IP) – A common Customs procedure that allows goods to be imported for processing or repair and then re-exported without paying duty or VAT. Correct use of IP can save businesses significant costs, but it requires strict record-keeping and compliance with HMRC’s conditions.

11. Import VAT – VAT on goods entering the UK; can be postponed via Postponed VAT Accounting (PVA).

12. Export Licensing – The system ensures controlled goods (e.g., dual-use or sensitive items) have official export authorisation.

13. Audit Trail – All documents and records kept to prove you're trading compliantly—essential if HMRC requests them.

14 . Bonds & Guarantees – Collateral systems used with special procedures like transit or warehousing.

15. Customs Guarantee Waiver – HM Revenue & Customs (HMRC) allows certain traders to apply for a guarantee waiver when using special procedures. If approved, this reduces the need to provide a financial guarantee for potential Customs debts, thereby improving cash flow while still ensuring HMRC's assurance of compliance.

I know, that’s only 15 terms!!! Customs jargon can feel like another language — and honestly, sometimes it is. But once you crack the code, you start spotting things that save you money (like duty reliefs), keep you out of trouble (like using the correct procedure codes), and help you talk the talk with freight forwarders and HMRC without breaking a sweat. Think of it this way: these terms are your starter pack for trading. Get them wrong, and you’re fumbling around at the border, trying to explain yourself. Get them right, and you glide through with confidence (and maybe even impress your colleagues by knowing what “Inward Processing” actually means).

And if you’d rather not spend weeks untangling jargon on your own, there are beginner-friendly courses that show you how all this works in practice — with real examples, not just dictionary definitions. Strong & Herd’s guides are a bit like having Google Translate for Customs, only they come with people who know what they’re talking about.

So, yes, Customs jargon can look intimidating at first glance. But once you’ve got the basics under your belt, it’s less like learning Latin and more like picking up the lingo for your next holiday — useful, empowering, and guaranteed to save you from some awkward situations at the border.

NTE 2025/25: Reversal of the New Ultimate End-User Screen

Mon, 01 Sep 2025 12:43:45 GMT

The ECJU has released Notice to Exporters 2025/25, which updates information on NTE2025 24, released on August 15th, regarding an additional ‘possible ultimate end user’ input screen on the licence application database, LITE.

The ECJU has released Notice to Exporters 2025/25, which updates information on NTE2025 24, released on August 15th, regarding an additional ‘possible ultimate end user’ input screen on the licence application database, LITE.

NTE2025/24 , released on the 15th of August, detailed that the LITE (Licence for International Trade and Enterprise) application system would be updated to allow for the input of possible ultimate end use details when applying for a Stockist Standard Individual Export Licence (Stockist SIEL).

Traders exporting controlled goods to stockists are often unable to provide ultimate end-user details at the licence application stage, particularly when exporting to a distributor for stock against future orders.

NTE2025/25 updates traders to the effect that the additional application screens to detail possible ultimate end users have been removed until further notice.

Further updates regarding stockist applications with unknown ultimate end-users will be shared as soon as they become available.

The ECJU requests that, where the exporter is aware of a possible ultimate end-user in the supply of controlled goods, details of that possible ultimate end-user be added to the application.

Where the recipient stockist does not know the ultimate end-user of the product imported to stock, ‘Unknown’ should be recorded in the ultimate end-user details box.

The ECJU further advise that any relevant destination should be added to the address field/country.

Where there is information as to possible ultimate end-user destinations, each destination should be recorded as a separate ultimate end-user entry.

Further information will be provided in due course .

A link to the NTE is below.

NTE 2025/25: reversal of new ultimate end-user screen - GOV.UK

 Contact ECJU

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Should any of the details in the Notice to Exporters be unclear, traders are advised to contact the export control helpdesk at the address below:

Telephone 020 7215 4594

NTE 2025/24: amendment to EU regulation (EU) 2019/125 (torture and capital punishment goods) applying to Northern Ireland

Fri, 29 Aug 2025 14:11:46 GMT

The ECJU have published Notice to Exporters 2025/24 that details a change in EU regulation that applies to Northern Ireland

The notice, published 27th August 2025 details that EU  Regulation (EU) 2019/125  which relates to the trade in certain goods that could be used for capital punishment, torture, or other cruel, inhuman, or degrading treatment or punishment, has been amended through  Commission Delegated Regulation (EU) 2025/928 .

The amendments have the effect of expanding the scope of controlled items in Annexes II and III of the Regulation

Amending regulation

The amending regulation came into force on the 20th of August 2025 in the EU and applies directly to Northern Ireland under the Windsor Framework.

The amending regulation can be accessed at  Commission Delegated Regulation (EU) 2025/928 .

The implications of these amendments for Great Britain are presently under consideration, and a further update is expected in due course

Contact ECJU

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Convention on a common transit procedure | EUR-Lex

Telephone 020 7215 4594

Subscribe to notices to exporters

Important Notice: DEFRA Border System Issue

Wed, 27 Aug 2025 14:44:45 GMT

DEFRA (Department for Environment, Food & Rural Affairs) have released the following message regarding a current issue affecting their digital border services.

IMPORTANT – DIGITAL BORDER SERVICES ISSUE 27th AUGUST 2025

Dear traders,

We are aware of an issue impacting some digital border services and affecting some traders. We are investigating the scope and cause of the issue and will look to identify and implement a fix as soon as possible. 

We expect minimal disruption, however, if you do encounter any problems, please contact the STORM Incident Hub - manned 24/7, who will liaise with NCH and competent authorities as required. 

Email Stormincidentresponse@apha.gov.uk

Before contacting Storm, please ensure:

The CHED is fully submitted and visible in IPAFFS.
SPS checks (as applicable) are complete.
A customs hold is visible in CDS that requires action.
You include the MRN, and all relevant CHED references

Please note the Storm inbox is not able to assist with:

CHEDs still in draft or amendment status
General or policy-related questions

Messages that do not meet these criteria may need to be redirected, which can lead to delays.

We will be in contact with further communication very soon and we appreciate your patience and cooperation whilst we work through this issue. 

CDS Scheduled Downtime Wednesday 27th August

Thu, 21 Aug 2025 11:52:21 GMT

HMRC has issued a notification to advise that the Customs Declaration Service, or CDS, will be taken out of service for a short period on the evening of Wednesday, 27th August.

CDS will be unavailable as follows: Wednesday 27 ^th August from 19.00 -19.45

This scheduled maintenance is designed to implement multiple performance improvements.

Users are advised that declarations submitted during this time will experience delays.

HMRC also advise that a Goods Movement Reference (GMR) may also be impacted at this time. This includes creating, updating, or embarking on a GMR.

Understanding XI REX Numbers and Their Role in EU-NI-GB Trade Flows

Thu, 21 Aug 2025 11:29:59 GMT

Since Brexit, the movement of goods between the EU, Northern Ireland (NI), and Great Britain (GB) has become significantly more complex. One Customs identifier you might start seeing on invoices is the XI REX number. If you’re wondering what it is, why it’s showing up, and whether it’s valid — you’re not alone.

Let’s break down what’s happening, and why GB traders may start seeing XI REX numbers on invoices — even when they’re not used to seeing them at all. A REX (Registered Exporter System) number is an EU-issued identifier that allows exporters to self-certify the origin of goods under various preferential trade agreements (e.g., EU-UK TCA, EU-GSP) . It replaces traditional EU preference certificates like EUR.1. It is especially relevant when the goods being supplied from the EU are above EUR 6,000 in value, and the exporter wants to declare preferential tariff treatment under a Free Trade Agreement (FTA) for a UK/GB-based business to claim the preferential rate of import duty.

Following the UK’s exit from the EU and the implementation of the Northern Ireland Protocol, the Windsor Framework has now been established. Under these arrangements, Northern Ireland remains aligned with specific EU Customs rules, allowing for frictionless trade with the Republic of Ireland (IE) and the broader EU, despite the UK's departure from the EU. The “XI” country code was created to indicate authorisation in place in Northern Ireland under the EU’s Customs framework. So, businesses established in Northern Ireland can

Apply for an XI EORI (Economic Operators Registration and Identification) number
Obtain an XI VAT number for intra-EU trade, and
Apply for an XI REX number, which is recognised in the EU’s Registered Exporter System.

So, when would an XI REX be applicable ? The NI company is the exporter of record for goods being sent from NI to a third country under the Generalised System of Preferences (GSP) Scheme that operates in the EU, but also, in certain circumstances, when moving EU originating goods across to GB (England, Scotland and Wales) when

The goods are of EU preferential origin,
No work has been undertaken in Northern Ireland on the goods and
The NI supplier to GB has obtained a Long-Term Supplier Declaration (LTSD) from the original EU supplier (e.g., from ROI).

So, this can be used in two different scenarios:

a) When an NI company purchases goods from an IE (Republic of Ireland) company. The supply from IE to NI is made under an intra-EU movement, meaning the goods are in free circulation within the EU . The NI company receives the goods into NI, takes ownership, and subsequently sells or moves the goods to GB . The arrival into GB cannot be under UK free circulation rules (i.e., a domestic movement) but the arrival must be declared as an import entry. If EU preference applied to the goods when supplied from IE, and the XI company has a LTSD to confirm this, then the EU-UK TCA preference statement can be made by the NI supplier so the preferential rate of import duty will apply into GB.

b) When an NI company purchases goods from an IE (Republic of Ireland) company and though the NI company does not move them out of IE, they take ownership of the goods prior to them being exported from IE to the UK . As the legal exporter of record (using the XI established EORI), the NI company can, if supported by an LTSD from the IE supplier, declare the goods as EU Preferential origin. This means that at import into GB, the import preference duty rate can apply.

It is crucial to understand that, though these goods may physically be in NI, if they do not undergo processing in NI, they are not considered “NI Qualifying” under the UK’s definition for domestic sales . That means:

They do not automatically benefit from UK internal free circulation, and
A UK import declaration is required when moving them from NI to GB.
If they are moved to GB without a Customs entry, that’s a risk of non-compliance.

Is this scenario unusual? No, but it seems odd because we are moving goods between two nations of the United Kingdom . If we swap out Northern Ireland and replace it with a full member country of the EU, then it makes more sense . Let’s replay the two scenarios:

a) When a company purchases goods in one EU country from another company based in a different member state of the EU, we’ll say goods purchased by a Belgian company from Germany. The supply from DE is made to BE under an intra-EU movement, meaning the goods are in free circulation within the EU . The BE company receives the goods in Belgium, takes ownership, and subsequently sells or moves them to GB/UK . The arrival in the UK will be an import. If the EU preference applied to the goods when supplied from Germany to Belgium, and the BE company has an LTSD to confirm this, then the EU-UK TCA preference statement can be made by the BE supplier, so the preferential rate of import duty will apply in GB/UK.

b) When a Belgian company purchases goods from a German company and though the Belgian company does not move them out of Germany, they take ownership of the goods prior to them being exported from the EU to the UK . As the legal exporter of record, the Belgian company (using its EU EORI) can, if supported by an LTSD from the DE supplier, declare the goods as having EU Preferential origin. This allows the import preference duty rate to apply at import into GB/UK.

As a GB importer, you might see a REX number with the XI prefix on the invoice or origin statement. Here's what to verify:

Is the XI REX valid?
Use the EU REX validation system (your check confirms it is).
Was there a UK import declaration?
Required if goods are not a UK-NI qualifying movement.
Was an LTSD used?
The NI exporter must hold this from the EU supplier.

Was the movement into NI declared under transit?
Do the FTA rules support the preferential claim?
Must match rules of origin and documentary requirements.

Northern Ireland’s unique position creates a hybrid set of rules, part of the EU and part of the UK. The XI REX is legitimate — but only in the right context, with all the necessary documentation to support it.

CDS Document Code Update

Wed, 20 Aug 2025 10:55:33 GMT

HMRC have released several amendments that will affect CDS documents.

The codes which are found within Appendix 5A

For further details on these changes, please refer to the information below.

Document codes C019, C601 & N990

Definition and references to these particular document codes have now been updated. This is to ensure that the difference between GB and Northern Ireland is clearer, and the terminology used, from End Use to Authorised Use.

Document codes C057, C079 & C082

XB status code is no longer permitted with these document codes . Due to this, the document ID is mandatory, and the document reason is no longer in use.

The only waiver codes that will be available are those permitted in the Tariff measures for the particular commodity code.

The Declaration of Conformity details for these particular document codes on Northern Ireland declarations will be sent to the EU CERTEX system in the latter part of 2025.

The document ID supplied for these document codes for NI declarations must match the EU format. CDS will accept the EU ID numbers, which are currently in use.

Document code L100

L100 document code for ozone-depleting substances has now been updated to show the difference in use between GB and NI.

Imports into NI for goods that are subject to licence controls will require L100 to be declared, irrespective of whether the goods are being entered into Customs warehousing.

Upon importing goods into a Customs Warehouse in GB, an import licence will also be required unless they are to be exported from the Customs Warehouse within a 45-day period.

XX status code must not be used with L100 for any NI declarations. It can be used on GB declarations for CW removals to declare on entry to or to claim an exemption from licence controls for goods that will be re-exported from the CW.

The latter part of 2025 will see the details for L100 on NI declarations sent to the EU CERTEX system. The document ID supplied for these document codes for NI declarations must match the EU format. CDS will accept the EU ID numbers, which are currently in use.

Both import and export licences use L100 within the UK Tariff; however, NI uses L100 for import licences only and E013 for export licences. NI imports will require a single declaration of L100, along with the EU licence ID, unless multiple licences are to be declared. NI Exports: The EU licence ID must be declared against E013 and L100.

Document Code E013

E013 export licence for ozone-depleting substances has been updated to remove both status codes XB & XF.

The document ID is now mandatory, and the document reason is no longer applicable.

The only waiver codes that will be available are those permitted in the Tariff measures for the particular commodity code.

The latter part of 2025 will see the details for E013 on NI declarations sent to the EU CERTEX system. The document ID supplied for these document codes for NI declarations must match the EU format. CDS will accept the EU ID numbers, which are currently in use.

NI Exports will only need to declare the EU licence ID against E013 and document code L100.

U110, U111 & U112

This has been updated to reflect the new document codes U116, U117, and U118 for claiming EU preference.

When claiming preference under the document codes U110, U111, and U112, it was introduced only on an interim basis as a workaround until CDS accepted the new document codes.

CDS now accepts U116, U117 and U118 for claiming preference from the EU, and users should be using them. See our article here.

U110, U111, and U112 will be switched off by HMRC, although there is no target date for this to be advised as of yet .

Status codes of AE, AP and JE have been added to U112 (Importers' knowledge). HMRC are investigating issues with the use of JP when claiming a quota under U112. When claiming a quota under U112, use the status code AE or AP accordingly.

HMRC Prepare for NCTS6 Phase One Implementation, 1st September 2025: Current Information and Details of NCTS Downtime

Wed, 20 Aug 2025 10:40:33 GMT

HMRC is unable to release the NCTS6 update by the deadline of 1st September 2025, as published at the implementation of the NCTS Final State Rules in January this year. Instead, HMRC are preparing to implement an update to NCTS5 on 1 ^st September . This will be released as NCTS6 Phase 1 and serves primarily as a migration pathway to prepare for NCTS6 Phase 2, or the deployment of NCTS6 proper at a later date.

The purpose of NCTS6 Phase 1 is to prepare the UK Transit system for the implementation of NCTS6 on the continent (for other contracted parties to the Union Common Transit Convention) while also releasing system bug fixes that should improve the NCTS experience in the UK.

NCTS6 Phase 1 release in the UK includes the following fixes for several known issues in NCTS5:

Unloading Remarks Timestamp Issue : Currently, unloading remarks submitted between 00:00 and 01:00 BST are incorrectly treated as future dated.

This will be resolved, eliminating the need for the workaround of using the previous day’s date.

National Transit Write-Off Issue : When the same trader handles both arrival and departure, the CC045 message is incorrectly linked to the arrival identifier.

This will be corrected.

Reusable Local Reference Numbers (LRNs): NCTS currently rejects LRNs that have been cancelled and reused.

This restriction will be lifted.

Unloading Remarks Rejections for Multiple House Consignments : When adding goods items sequentially within consignments, the system currently expects the sequence to follow the total number of goods items.

This will be fixed, and the current workaround will no longer be necessary.

Successful message regeneration : Users will be able to ask the NCTS Helpdesk to resend a transit message that has already been successfully sent.

Important Note : Some third-party software providers may have implemented temporary workarounds for some or all of these issues. It is advisable to check with your third-party software provider to ensure that your systems will operate smoothly with these changes from September 1st.

The UK has also opted out of safety and security connectivity between NCTS6 and the ICS2 (Import Control System) for the time being . There is an option to opt in to this connectivity at a future date.

NCTS Planned downtime – 1 ^st September 2025

To support the deployment of NCTS6 Phase 1 (the NCTS5 update), there will be a short period of downtime affecting both the Great Britain (GB) and Northern Ireland (XI) NCTS services:

Both Great Britain (GB) and Northern Ireland (XI) services will be unavailable as follows:

1 ^st September : From 21:00 BST to 23.00 BST .

Both services are expected to be fully restored later that evening by 23:00 BST.

Messages related to submitted declarations during this time will be queued and issued once the services have been restored.

Important information during downtime

HMRC has reminded users to ensure that usual procedures for exports and imports are followed, such as obtaining a Goods Movement Reference when moving via a GVMS location .

Departures while NCTS is unavailable:

It is recommended to avoid movements under the normal procedure that would require attendance at Inland Border Facilities (IBFs) or ports, and to avoid travelling to an IBF to commence a Transit movement until the system is restored to normal operability.

If it is essential that goods must be moved during downtime and it is not possible to submit declarations before the downtime begins, the manual fallback procedure is available as published in the Transit Manual Supplement.

A link to the Transit Manual Supplement can be found here: Transit Manual Supplement.

For arrivals into GB or XI .

Movements should continue as per normal practice.

Some transit processes, such as the office of destination, may need to be completed when NCTS is next available.

Contact details for urgent support are given as follows:

NCTS Helpdesk - ncts.helpdesk@hmrc.gov.uk or 0300 322 7095
NCTS Supervising Office - isbc.nctssupervisingoffice@hmrc.gov.uk or 0300 322 9452.

New Computerised Transit System – NCTS6 Delivery update

Mon, 18 Aug 2025 15:34:35 GMT

HMRC has issued further information regarding the implementation of NCTS6 following the implementation of the NCTS5 Final State Rules in January 2025.

What is NCTS6, and why is it being introduced?

NCTS6 is the latest version of the European digital system that enables the movement of goods using Union Transit across all contracting parties (i.e., countries) to the Common Transit Convention .

The convention covers the 27 EU member states (as one contracting party) and eight common transit countries, namely, Iceland, North Macedonia, Norway, Serbia, Switzerland, Türkiye, Ukraine, and the United Kingdom as separate contracting parties.

The convention itself provides the legal framework that sets out the obligations on traders and Customs authorities for goods in Customs transit from one contracting party to another and is overseen by the EU Commission (TAXUD) .

The EU Commission has directed that all contracting parties implement the upgrade to NCTS6 by 1st September, in accordance with the Design Document for the National Transit Application (the DDNTA), which outlines how NCTS is implemented within each contracting party state . HMRC is not yet able to implement NCTS6 and is therefore implementing a two-phase approach. Fixes to NCTS5 will be released on 1 ^st September, with NCTS6 implementation at a later date.

What will happen

The NCTS6 implementation phase one, the release of NCTS5 with fixes, will commence on September 1 ^st , 2025, with the second phase to follow in due course.

Phase 1: Interim release 1 ^st September 2025

Update to NCTS5: This release is a Migration Pathway to support the NCTS6 release . Updating NCTS5 should include any bug fixes to address system issues encountered with the NCTS5 release.

Phase 2: NCTS6 release – date to be confirmed.

This release will include the final coding for NCTS6, which will be delivered sometime after September 1 ^st , 2025.

HMRC has confirmed its intention to provide fair notice to software developers and businesses regarding the NCTS6 release timings and has written to some to advise on possible updates that may be required for third-party software.

There are risks associated with making a staged release of NCTS6 behind the target Go-Live date. Disjoint with other country systems and inconsistent national approaches to implementation are possibilities. The main hiccups may likely occur at official Transit Offices, where Transit compliance may become an issue for those trying to use it, and those working to ensure that the transit paperwork is fit for purpose and compliant with the CTC regulations for that country.

Opting out of using Transit Security Accompanying Documents

The deployment of NCTS-P6

One of the main functions of NCTS6 is the introduction of TSADs, which are designed to incorporate safety and security information into the Transit declaration, aligning with the introduction of ICS2.

CTC signatories were given the opportunity to opt out of introducing TSADs at the first stage of NTC6 implementation. The UK chose to opt out. The option to opt in can be taken at a later date.

Opting In or Opting Out of the TSAD: What it means

NCTS6 is divided into two approaches: ‘opt-in’ and ‘opt-out’ of the Transit Security Accompanying Documents.

By opting in, a country chooses to connect to Import Control System 2 via the Transit Entry Summary Declaration (ENS) Data (TED) Processing Bridge. This converter facilitates the communication of ENS data to ICS2.

This link with ICS2 means that economic operators (EOs) will be able to submit one declaration, instead of two separate declarations to NCTS and ICS2.

By opting out, the UK has chosen not to connect to ICS2, meaning that NCTS cannot use ENS data.

Countries opting out are obliged to update their systems to NCTS6 specifications.

Opting out of the use of the TSAD will also mean that the TSAD transit messaging, introduced with NCTS6, will need to be provisioned.

Technical information for TSAD messaging

NCTS6 introduces three new transit messages to support TSADs . Any countries opting in for the use of TSADs will need to use these messages to meet the S&S obligations.

These are:

1. IE117 Notification of the Presentation of Goods at the Office of Transit

2. IE058 Rejection of IE117

3. IE119 Rejection of Goods Crossing the Frontier

Notes on TSAD messaging for the UK having opted out of TSAD:

IE117 and IE058 messaging will not be used by the UK for transit movements into or out of GB and NI

IE119 will not be used as GB, and NI will use the Goods Vehicle Movement Service (GVMS) for this purpose.

HMRC have advised that there will be capacity for NCTS to accept any IE119 Rejection of Goods Crossing the Border received from another National Administration.

Will NCTS5 still be compatible when other countries transition to NCTS6 before the UK, from 1 ^st September 2025?

The present UK NCTS system will remain largely unchanged and will continue to accept messages to and from countries that have transitioned to NCTS6:

For Web Portal Users: The current NCTS5 system will remain unchanged and continue to send/accept messages as it does now.

Third-party software Providers may need to make modifications to enable compatibility with NCTS6 . HMRC have written to some software providers about this possibility. However, users are urged to check NCTS6 compatibility with their third-party providers in advance of September 1 ^st .

A summary of the convention with contracting parties can be found at this link:

The latest version of the CTC Design Document for National Transit

Application (DDNTA) can be found here:

NCTS-P6 - Design Document for National Transit Application (DDNTA)

Link to the EU Guidance on the ENS and Transit declarations for NCTS6 and ICS2 can be found below:

5b67b4ab-ece6-4dc6-a3be-8b938d603abc_en

Further details on NCTS can be found on the European Commission Website:

New Computerised Transit System (NCTS)  - European Commission

NCTS Downtime Scheduled for 1 September 2025

Fri, 15 Aug 2025 09:33:40 GMT

HMRC has advised of scheduled downtime for the New Computerised Transit System (NCTS) while system maintenance activities are completed.

Downtime is scheduled as follows:

Monday, 1st September 2025, from 21:00 to 23:00 .

Impact:

NCTS GB and NCTS XI data submitted during this downtime period will be held and processed once the maintenance activity has concluded and the service returns to normal

NCTS service availability and status are published at the following link: NCTS service availability page

Temporary Admission: Customs Technical Handbook Published

Thu, 14 Aug 2025 09:36:42 GMT

HMRC have published a further Technical Handbook for Temporary Admission Procedures.

The aim of this publication is to provide a single, centralised location for all associated government guidance on temporary admissions, facilitating ease of reference.

Definition of Temporary Admission

Temporary Admission (TA) is a Customs Special Procedure that allows for the temporary import of goods into the territory for a specific use, with duty and VAT relief applied upon import.

Specific conditions must be met for each procedure. Traders are expected to adhere to the obligations of the procedure before implementing Temporary Admission at import, and their consequent obligation to discharge the goods upon re-export.

Temporary import measures can be used for a variety of temporary imports where goods are not intended to remain in the territory. For example, this includes personal or professional equipment, such as for sporting events, as well as commercial purposes, including goods for import, exhibition, or commercial loans.

Stipulations for using a Temporary Admission procedure include that the goods must be put to a use specified in the given procedure, they must be returned in an unaltered state (allowance is made for maintenance to keep the goods in their original imported state) and be re-exported within a set time period.

A link to the handbook can be found below:

Temporary Admission Customs Technical Handbook - Guidance - GOV.UK

Upcoming Events & Training Courses this September

Wed, 13 Aug 2025 14:24:03 GMT

Join us in September for comprehensive training courses on Customs compliance and international trade.

Our September sessions are tailored to suit your schedule, offering full-day courses and focused, shorter clinics. Whether you're looking to master the basics of import/export or delve into more advanced Customs regulations, we have a wide range of courses to suit your needs.

See below for further details of September courses.

Last Minute Availability

Clinics

HMRC have recently published several updates to Customs Special Procedures

Tue, 12 Aug 2025 12:28:42 GMT

HMRC have recently published several updates to Customs Special Procedures and other import and export guidance pages. A summary of the changes and links to the updated pages are given below.

Outward Processing

What it is:

Outward Processing is a method of duty and VAT management that allows for the provision of goods exported for repair or processing to be reimported, with duty and VAT payable only on the costs of the repair or processing. For example, without employing an OP authorisation for an export for repair or processing, and with no compliance evidence to support the subsequent re-import, HMRC would consider that the goods on re-import are home-use imports, subject to duty and VAT on the full value of the goods.

Outward Processing Authorisation falls into four types:

Full authorisation: The importer applies to HMRC for an OP authorisation. This authorisation number must be quoted on all declarations where goods for return are to be re-imported, with duty and VAT payable only on the processing or repair costs.

Retrospective Authorisation: In exceptional circumstances, retrospective authorisation can be applied for after goods have been exported. This authorisation can only be used if it has not been used in the previous 3 years. HMRC would expect that a full OP Authorisation should cover frequent use.

Authorisation by Declaration: To be used for export for repair only, the declaration serves as the authorisation, identified by the procedure coding on the declaration. AbD may only be used under specific circumstances, for example, when the goods value is less than £500,000, or if importing using a simplified declaration.

An Authorisation that covers Northern Ireland and the EU:

If an authorisation is required for both GB and NI, two applications will be necessary to enable adequate provision.

What’s the change?

The number of times a business can apply for Authorisation by Declaration has been increased from 3 times in a rolling 12-month period to 10 times in a rolling 12-month period.

Full details can be found here: Apply to pay less duty on goods you export to process or repair  - GOV.UK.

Inward Processing

What it is : Inward Processing allows importers to suspend Customs duty and import VAT on goods they import for processing or repair from outside the UK.

This is particularly important for traders who have no intention of owning the imported goods. For example, when goods are imported for repair and return, or the importing business specialises in the repair of imported goods for reexport.

Postponed or Deferred VAT Accounting cannot be used as a mechanism for managing import VAT where there is no intention for the importing business to own the goods. Therefore, without using IP, goods imported for repair or processing and re-export would be subject to non-recoverable import VAT and duty on the full value of the goods at the time of import.

Inward Processing authorisations fall into the same four categories as Outward Processing, namely: Full Authorisation, Retrospective Authorisation, Authorisation by Declaration, and an Authorisation that covers Northern Ireland and the EU.

What’s the change?

The number of times you can apply for IP authorisation by declaration in your import declaration has been changed from 3 times to 10 times in a rolling 12-month period.

A link to the updated page can be found here: Apply to delay or pay less duty on goods you import to process or repair - GOV.UK.

Importing for Specific Uses

What it is: Some goods can be authorised to be imported to a specific authorised use, if the goods are captured in the Tariff as qualifying. Specific uses include importing for end-use in the aerospace industry, ship works, or fisheries.

How to apply:

There are four types of authorisation available for authorised use:

Full Authorisation
Authorisation by Declaration
Retrospective Authorisation — this is Full Authorisation where you request the start date to be before the date of application
Authorisation covering Northern Ireland and the EU

Full Authorisation

Full Authorisation allows you to use:

authorised use regularly
authorised use if you import non-commercial goods and you’re not established in the UK
a simplified declaration to import or export your goods

A list of goods that could fall under Importing to Specific Use can be found here: Authorised_Use_Eligible_Goods_and_Authorised_Uses_-_v2.18.docx.

Change made: The number of times an authorisation by declaration can be used has been increased from 3 times in a 12-month rolling period to 10 times in a rolling 12-month period.

A link to the guidance page can be found here: Apply to pay less duty on goods you import for specific uses - GOV.UK

Notices made under The Customs (Import Duty) (EU Exit) Regulations 2018

2 new notices have been added to ‘Notices made under The Customs (Import Duty) (EU Exit) Regulations 2018’, setting out the process of applying to HMRC for approval to declare certain goods to a temporary admission procedure, without an electronic declaration.

The new notices are to be found at 13 and 14 on the update issued below:

Notices made under The Customs (Import Duty) (EU Exit) Regulations 2018 - GOV.UK

Temporary Admission

What it is: Temporary Admission Authorisations are employed when goods for import are intended to be imported on a temporary basis to be re-exported unchanged, in due course. Therefore, a Temporary Admission procedure is applied at import and duty and VAT are duly suspended.

There may, however, be a guarantee or deposit payable, refundable on goods' exit from the UK territory.

There are six types of authorisations for the use of Temporary Admission:

Full Authorisation
Authorisation by Declaration
an Authorisation that covers Northern Ireland and the EU
Retrospective Authorisation — this is a Full Authorisation where you request the start date to be before the date of application
Oral Declaration
crossing the border ‘by any other act’

A Temporary Admission Authorisation is needed to suspend the import duty and VAT until the goods are confirmed as re-exported.

Goods for Temporary Admission should not be altered in any way before re-export.

Time limits vary for different types of goods, and some can be extended by submitting a request to HMRC.

Change Made : The time limits for which certain goods can remain before they must be re-exported have been updated.

Apply to import goods temporarily to the UK - GOV.UK

Authorisation by Declaration

What it is: Authorisation by Declaration is a method to suspend import duties and VAT on an import while goods are processed or used, then re-exported. It can be used for many purposes, including importing to IP or OP, with specific conditions.

The Customs Declaration will be a one-time only authorisation to use the special procedure for the goods on that specific declaration.

Goods must be under £500,000 in value.

Change made:
You can use Authorisation by Declaration 10 times within a rolling 12-month period.

Using a special procedure without a prior authorisation - GOV.UK

The Implementation of the French Smart Border Obligatory Logistics Envelope has been Delayed Until Later in the Year

Thu, 07 Aug 2025 14:14:20 GMT

The French customs authorities have announced that the Obligatory Logistics Envelope (ELO), a mandatory documentary control for the French border, will be delayed until later in the autumn of 2025.

The ELO is a method of collating all customs paperwork under one barcoded reference number, allocated to the driver before the crossing into France with goods for import. One truck or lorry, one ELO barcode.

The ELO has been live since April of this year (2025), allowing for trial running before its full go-live implementation at the end of August 2025.

The ELO, or mandatory compliance envelope, must be created by a pre-designated party or ELO creator, who will serve as the single point of contact for collating all customs regulatory paperwork before the goods begin crossing into France.

Goods are then risk-assessed during the crossing and directed to either the Green or Amber lane upon reaching France.

Implementation is now expected later in the Autumn of 2025 and will represent a substantial compliance change for those involved in exporting goods through the French short straits.

A link to the French Douanes (Customs) is below. The site is constructed with translation and instructions in English. Frequently Asked Questions:

FAQ - Obligatory Logistics Envelope (ELO) | Portail de la Direction Générale des Douanes et Droits Indirects

The French Customs Authorities can be contacted at the email address below:

dg-comint1-fil@douane.finances.gouv.fr

Historical Articles on the ELO are available on the S&H website:

French Customs releases an English User Guide for the French Smart Border Obligatory Logistics Envelope (ELO)

Notice to Exporters 2025/21: The Inclusion of US ITAR provision in the F680 Process. The ECJU issues clarification.

Mon, 04 Aug 2025 11:20:35 GMT

The Export Control Joint Unit has issued clarification on the inclusion of a provision for US International Trade in Arms Regulations when applying for an F680.

The F680 application process is primarily a security procedure to enable the UK Government to control when, how, and if Defence Related Classified Material is for release by UK defence contractors, sub-contractors, suppliers or businesses to foreign entities, generally for the purposes of export promotion or sales of equipment or services.

In August 2024, the F680 application process was amended to include controls under the US International Trade in Arms Regulation. This represents part of a collaborative agreement reached between the US and the UK authorities in return for a negotiated US exemption from the ITAR, provided certain conditions are met.

The agreement was originally reached to optimise US export licence provision through an ITAR exemption, supporting the AUKUS tri-national trade project and thereby reducing barriers to trade collaboration between Australia, the UK, and the US.

Notice to Exporters NTE2025/21 has been issued to remind exporters that ITAR provision is included in the F680 application process for all applications where US ITAR controls apply to goods or technology, not only those relating to the AUKUS project.

The F680 process will also include provision for the movement of ITAR-controlled goods or technical data to foreign persons within the UK. This provision allows for comparable control to the US Deemed Exports regulation.

The F680 application has now been moved to the new LITE system from SPIRE.

Note . The ITAR provision in the F680 process does not apply retrospectively. Inclusion commences from August 2024, when amendments to the F680 application process were published.

A link to NTE2025/21 can be found below:

NTE 2025/21: F680 approval for classified and unclassified ITAR material - GOV.UK

Full F680 policy and guidance, including details on ITAR inclusion and impact, can be found here:

Form 680 policy and guidance - GOV.UK

US ITAR: Definition of Deemed Export can be found here: eCFR:: 22 CFR 120.50 -- Export.

The latest government press release on the AUKUS international trade project can be found here:

AUKUS treaty deepens UK-Australia defence partnership to generate £20 billion in trade and create 7,000 new jobs - GOV.UK

HMRC Launches the Authorised Economic Operator (AEO) Customs Technical Handbook

Thu, 24 Jul 2025 16:05:48 GMT

HMRC has published the latest addition to its suite of Customs Technical Handbooks, the Authorised Economic Operator (AEO) Customs Technical Handbook, on 23 July 2025.

The Authorised Economic Operator Customs Technical Handbook is now available on the Customs Technical Handbooks landing pages.

The handbook is designed to support AEO applicants in understanding their responsibilities as AEOs and to clarify the obligations of an economic operator to the UK AEO Programme.

The AEO Customs Technical Handbook can be found at the link below:
Customs Technical Handbook - Authorised Economic Operator (AEO) - Guidance - GOV.UK

The technical handbook landing page, giving access to other published technical handbooks, is at the link below:

Customs Technical Handbooks - GOV.UK

HMRC Transformation Road Map

Thu, 24 Jul 2025 13:00:49 GMT

The UK Government has recently released the Transformation Roadmap, a comprehensive document that outlines HMRC's strategic reform. This roadmap, published on 21st July, details the government’s ambitious plans to modernise the HMRC tax and Customs system over the spending review period, with a clear vision for 2030.

The Transformation Roadmap outlines HM Government’s vision for a more efficient, modernised, and automated tax and Customs system, with a substantial shift towards the use of Artificial Intelligence and the gathering of data from cross-government departments, and where applicable, between 3 ^rd party actors.

For those involved in the international cross-border movement of goods, interest will focus on how HMRC will transform their interaction with traders, agents, and intermediaries in the use of more effective and efficient cross-border IT systems .

The article also confirms funding for the recruitment of 2400 Tax Debt Officers and 5500 Compliance Employees . We can therefore conclude that there is a movement towards tightening controls on compliance and tax enforcement across HMRC. This was previously announced within the Spring budget, although this confirms HMRC's commitment to scale compliance efforts to close the tax gap.

Government Prepares to Scale Compliance Audit Efforts

There was considerable disappointment at the cancellation of the Single Trade Window (STW) project in autumn 2024 . This policy communication appears to suggest that this transformation and modernisation strategy will move towards digitalisation and interdepartmental communication, making the STW a possibility in the future.

For the HMRC's modernisation efforts to be successful, the organisation must collaborate closely with its customers, partners, and stakeholders. Their active involvement in implementing these changes will be crucial to ensuring their effectiveness and efficiency.

A smooth transition towards any changes in IT systems and the supporting software, for example, will be essential . The EU Exit saw the implementation of numerous new IT systems to ensure that the cross-border movement of goods continued smoothly. Many would challenge that this was successful.

Improvements in published guidance, with a clear notice period for impact and change, will be vital if traders are to see the improvements that the Transformation Road Map aims for.

A link to the Transformation Road Map is below:

HMRC's Transformation Roadmap - GOV.UK

UK and Indian Prime Ministers Meet to Sign Trade Deal

niamho@strongandherd.co.uk (Niamh O'Connor) — Thu, 24 Jul 2025 12:45:28 GMT

Prime Minister Kier Starmer is set to meet with Prime Minister Narendra Modi of India today, 24th July 2025, for the signing of the UK-India Trade Agreement. The agreement will then move to be ratified in parliament before coming into force, enabling both countries to trade under its terms.

The new trade agreements are set to create thousands of British jobs through new Indian investment and export markets worth almost £6 billion. Nearly £6 billion in new investment and export wins, which will create over 2,200 British jobs across the country as Indian firms expand their operations in the UK and British companies secure new business opportunities in India. These deals will drive jobs in high-growth sectors, such as aerospace, technology, and advanced manufacturing, supporting engineers, technicians, and supply chain workers across the UK.

The UK already imports £11 billion in goods from India, but liberalised tariffs on Indian goods will make it easier and cheaper to buy their best products. For businesses, this could mean potential savings when importing components and materials used in areas such as advanced manufacturing or luxury and consumer goods.

India’s average tariff on UK products will drop from 15% to 3%, which means British companies selling products to India, ranging from soft drinks and cosmetics to cars and medical devices, will find it easier to sell to the Indian market.

Whisky producers will benefit from tariffs being slashed in half, reduced immediately from 150% to 75%. This immediate reduction, once the FTA is ratified, will give the UK a competitive advantage over international competitors in accessing the Indian market, sparking excitement and anticipation among whisky producers.

The full text of the agreement has now been published and can be accessed at the following link, along with the Chapter on Rules of Origin, which is also available for viewing.

Important: The agreement has not yet come into force; once ratified by both countries, businesses will be able to trade under its terms.

Comprehensive Economic and Trade Agreement between the United Kingdom of Great Britain and Northern Ireland and India

UK-India CETA Chapter 3: Rules of Origin

The two Prime Ministers have also signed a renewed Comprehensive and Strategic Partnership. This partnership is expected to see closer collaboration on defence, education, climate, technology, and innovation, in addition to efforts to tackle organised crime and illegal migration.

UK-India Free Trade Agreement Business Mobility.

As part of the UK-India Trade Agreement, the two countries have agreed on a chapter on business mobility, which will secure access for short-term business travel to and from India and the UK. This will give UK businesses and professionals a guarantee that existing access to the Indian market will continue.

Business Mobility Explainer

Full Press Release

Northern Ireland Press Release

UK-India Free Trade Agreement and Impact on Industrial Strategy Sectors

Prime Minister Keir Starmer said:

“Our landmark trade deal with India is a significant win for Britain. It will create thousands of British jobs across the UK, unlock new opportunities for businesses and drive growth in every corner of the country, delivering on our Plan for Change.

We’re putting more money in the pockets of hardworking Brits and helping families with the cost of living, and we’re determined to go further and faster to grow the economy and raise living standards across the UK.”

Secretary of State for Northern Ireland, Hilary Benn, said:

“This is a landmark deal that will bring real benefits for businesses and workers in Northern Ireland.

Northern Ireland’s advanced manufacturing, engineering, and medical technology sectors will see tariffs eliminated or significantly reduced, while Irish whiskey producers will benefit from substantial cuts in duties, allowing for increased trade with India.

This agreement will help further unlock the huge potential for growth across Northern Ireland, including its thriving services and technology sectors.”

The Export Control Joint Unit (ECJU) Released Notice to Exporters 2025/22: General Trade Licence Russia Sanctions – Sectoral Software and Technology

Thu, 24 Jul 2025 10:11:30 GMT

NTE 2025/22 advises traders of the release of the General Trade Licence Russia Sanctions – Sectoral Software and Technology. Both the NTE and the licence were published on 21 ^st July 2025.

The licence relates to specific prohibitions named in Chapter 4N of the Russia (Sanctions) (EU Exit) Regulations and is available for registration through the SPIRE export licencing system.

Note: The licence, valid for registration from July 21 ^st 2025, has a restricted usage time and will expire on October 20 ^th , 2025 .

A link to Chapter 4N can be found here: The Russia (Sanctions) (EU Exit) Regulations 2019

A link to the published Notice to Exporters 2025/22 is below:

NTE 2025/22: general trade licence Russia sanctions – sectoral software and technology - GOV.UK

Guidance for complying with the sectoral software sanctions and for making export licence applications can be found here

Complying with sectoral software sanctions - GOV.UK

A link to the Russia Sanctions regulation can be found at the link below:

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025

The licence can be found here: General Trade Licence (Russia Sanctions – Sectoral Software and Technology) .

Contacts

For any questions about the impact of these sanctions on UK businesses operating in any sector, or business operations in Ukraine or Russia, help can be found at the following link: contact the export support team.

Queries specifically relating to exports to Russia, Ukraine, and Belarus can be submitted using the online form found at the following link: https://submit.forms.service.gov.uk/form/3211/get-help-trading-with-ukraine-russia-and-belarus.

General queries about strategic export licensing should be addressed to the Export Control Joint Unit.

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

https://www.europarl.europa.eu/RegData/etudes/BRIE/2025/775873/EPRS_BRI(2025)775873_EN.pdf

Telephone 020 7215 4594

UK-EU Summit: Where Are We Now with Regards to SPS Agreements and ETS Linkage Agreement

Wed, 23 Jul 2025 12:14:02 GMT

On 19 ^th May 2025, leaders from both the UK and the EU reached a common understanding to strengthen bilateral cooperation between the two neighbours. This was the first EU-UK Summit since the UK's exit from the EU. On 16 ^th July 2025, the EU published its recommendation for a Council decision, which seeks authorisation to open negotiations.

An agreement in principle was reached to explore the potential for linking the two Emission Trading Systems, and an informal agreement was made on a common area for sanitary and phytosanitary cooperation, which holds the promise of easing trade frictions and strengthening the partnership.

UK-EU Common Sanitary and Phytosanitary Area

At the UK-EU Summit, it was agreed in principle that a common area for SPS goods would alleviate some of the issues facing traders on both sides when moving agricultural and food goods. This common area would enable products covered by the regulation to move freely from the United Kingdom to the European Union and vice versa, as if they were moving within the Union. There would need to be an identical set of rules regarding this with simultaneous supplication for it to be successful.

HMRC has indicated it would include the following

Removal of export health certificates
Removal of plant health certificates
Removal of certificates of inspection for organic products
Routine border checks on agri-food goods removed

UK-EU Emission Trading System Linkage

The EU CBAM has been in force since October 2023, requiring EU importers of CBAM goods to report on these. This level of reporting has affected many UK Businesses, not only traders who export and may act as importers into the EU, but also businesses that manufacture downstream products of these CBAM goods.

It is not a stretch to say that the EU CBAM, also an EU regulation, is far reaching and has left many UK businesses unsure of the requirements under this regulation, and with the UK planning its own version of CBAM, due to come into force in 2027, equally

UK Importers will need to be aware of this, although this is not what is being discussed today.

At the UK–EU Summit on 19 ^th May 2025, it was announced that the two parties would work towards linking the EU's and the UK's emission trading schemes. In doing so, it would create conditions for CBAM goods in both the UK and the EU to benefit from a mutual exemption from both the EU CBAM and the future UK CBAM.

These negotiations are ongoing and represent a significant step towards finalising the agreements. The mutual exemption from CBAM would come as a welcome step for both UK Exporters and EU Importers trading under the current EU CBAM. This mutual exemption would reduce administrative burden and ease trade frictions between the jurisdictions.

https://www.gov.uk/government/publications/methodology-note-preliminary-economic-impacts-of-linking-the-uk-eu-emission-trading-schemes/methodology-note-assessing-the-preliminary-economic-impacts-of-linking-the-uk-eu-emission-trading-schemes

Next Steps for Both the Common Sanitary and Phytosanitary Area and the Linkage of ETS – Recommendation for Council Decision .

On 16 ^th July 2025, the EU published its recommendation for a Council decision on authorising the opening of negotiations between the EU and the UK on common sanitary and phytosanitary areas, as well as linking the UK to the EU's emission trading system. These would be two separate agreements, but each could ease trade and relations between the UK and the EU, thereby strengthening the partnership.

https://ec.europa.eu/transparency/documents-register/detail?ref=COM(2025)408&lang=en

Customs Declaration Service (CDS) Update Version 4.8.0.2

Wed, 23 Jul 2025 11:47:01 GMT

The upcoming CDS update, version 4.8.0.2, is scheduled for release on 30 ^th July 2025. During this period, please note that any pre-lodged declarations that will be affected by the changes should be changed/amended prior to the goods arriving.

If Customs Declarations are not corrected prior to arrival, they will be rejected.

We have been advised that this minor update will not require any downtime for CDS.

Changes for both Imports and Exports

Validation of Document Codes

Further validation has been added for several document codes within this update.

You must ensure that the correct document ID and reason fields are completed for the following:

The Document ID field must be completed for C715 & X866.

The Document Reason Field must be completed for Y169, Y179, Y180, Y181 Y182 Y236

An update to the Electronic Status Codes EA, EE, EL, EP, ES has been added to Code X866.

Should the declared document be an electronic licence, and a non-electronic Status Code is also declared, the declaration will be rejected accordingly.

See appendix 5a

https://www.gov.uk/government/collections/data-element-23-documents-and-other-reference-codes-of-the-customs-declaration-service-cds

Goods Location Codes

Updated and new location codes will be added accordingly from the date of the update release. These new location codes can be found in Appendix 16, as listed below.

https://www.gov.uk/government/collections/goods-location-codes-for-data-element-523-of-the-customs-declaration-service

IMPORT DECLARATION UPDATE:

H7 Declaration Category

When completing a H7 declaration, only a single goods item is allowed. If there is more than one item declared, the declaration will be rejected.

2DP Additional Procedure Code

2DP can now be declared with 4053 procedure code. This is under DE 1/10 and DE 1/11; the full description of the completion instructions in the UK Trade Tariff should be followed.

EXPORT DECLARATION UPDATE

Customs Supervised Exports

The update will now correctly process CDS export declarations under Type J supplementary declarations for the additional procedure code of 16M within DE 1/11.

This will ensure that when the supplementary type J declarations and CSE are declared within DE 3/40, the declarations will now be accepted where previously they were unable to be.

NTE 2025/20: Updated End User Undertaking (EUU) and Guidance

Wed, 23 Jul 2025 11:08:47 GMT

The Export Control Joint Unit has released a notification of the revised End User Undertaking (EUU) form for exporters applying for Standard Individual, Stockist, or Standard Individual Trade Control export licences.

Guidance has been published on the same notice to assist with completing the new document.

The updated undertaking combines the previous separate undertakings for stockist and standard individual export licences and has been released for use immediately.

Clarity on usage to support a new licence application

The previous version of the undertaking will remain valid to support a licence application if signed and dated on or before the 1st September 2025, and such documents may be used up to their date of expiry, which is six months from the date of signature.

However, an older version of the document will not be accepted if dated after 1st September 2025.

A link to the guidance on using the updated undertaking can be found here:

End-user undertaking (EUU) form guidance - GOV.UK

The undertaking itself can be found here:

End-user_and_stockist_undertaking_form.docx

Accepting Digital Signatures

The notice explains that the changes include the acceptance of digital signatures and the removal of the requirement to submit the document on company letterhead. The update also more clearly reflects the questions posed in the new LITE licence application system.

A link to the Notice to Exporters can be found at the link below:

Notice to exporters 2025/20: updated end user undertaking (EUU) and guidance - GOV.UK

Are We Being Compliant with Our CDS Document Codes?

Tue, 22 Jul 2025 11:17:01 GMT

As CDS evolves, it is becoming increasingly important to ensure that the correct document codes and reasons for export or import are accurately declared.

Compliance has always been crucial. However, with the Customs Declaration Service now in full swing, any non-compliance will lead to immediate declaration rejections, a contrast to the previous practice of identifying issues during audits.

Document codes, document IDs, and reasons for the import or export must match.

Ensuring the correct document code, the correct document code ID, or reason for import or export, has always been paramount to ensuring that we, as importers or exporters, are compliant with regulations.

If we are declaring a document code for preference under a trade agreement or a code confirming exemption from an export licence, we, as traders, are responsible for ensuring that the correct document codes and declaration references are accurate on our Customs Declarations.

Depending on the document being declared, there are two potential additional fields that must be completed: the document ID, and the reason field.

The reason field is used to claim an exemption from a licence or measure that may be applicable for the product.

Understanding the Broader Implications

U116 code change from U110: Claiming preference using the Invoice Statement: New coding valid from 14th June

If we, as an importer, are claiming preference under the UK-EU TCA, we must ensure that when we claim using the invoice statement as the reason, the document identification reference matches and is included in the document ID under U116.

The new document code, U116, is now in effect as of June 14, 2025, replacing the previous code, U110.

Important note:

Importers must use the invoice number with the document code U116, not the REX number.

Using the REX number is a non-compliance with this document code.

Similarly, claims for preference at import have been rejected by HMRC because the reason for import was coded as "Importers Knowledge." Still, the reason for the claim was an invoice statement.

HMRC is not tolerating this sort of error, and importers are finding that duty is therefore payable due to inconsistencies on the import declarations.

What has changed?

From a compliance aspect, nothing has changed. The compliance requirements for document ID and Document reference numbers have always been required on CDS. Keeping up with the change to CDS coding is the responsibility of the trader. If the trader is using an agent, the trader is responsible for verifying that the agent accurately makes the declaration.

The CDS changes

Following the CDS update 4.8.0 and 4.8.0.1, CDS now validates the ID or reason fields for documents that are declared.

From now on, a reason of NAI, or not applicable for an exemption, for example, will no longer be accepted. Traders must follow the guidance provided in the UK Trade Tariff, Volumes 2 and 3.

CDS is now validating the information provided against the requirements outlined in the Tariff Volumes. Any data mismatch will cause the declaration to be rejected

An example of this update from 4.8.0 is a snippet from our article here

CDS 4.8.0 update – Validation now active on CDS

The Document ID field must be completed for the following Codes:

‘C121’, ‘L155’, ‘L156’, ‘U078’, ‘U101’, ‘U120’, ‘U121’, ‘U122’, ‘X859’, ‘X860’, ‘X861’, ‘X862’, ‘X863’, ‘X864’, ‘X865’, ‘Y161’, ‘Y751’, ‘Y752’, ‘Y753’, ‘Y754’, ‘Y755’, ‘Y756’, ‘Y766’, ‘Y767’, ‘Y871’, ‘Y881’, ‘Y883’, ‘Y885’, ‘9L49’

The Document Reason Field must be completed for these Codes:

Y147’, ‘Y168’, ‘Y233’, ‘Y234’, ‘Y753’, ‘9Y04’, ‘9Y05’, ‘9Y06’, ‘9Y15’, ‘9Y49’

Electronic Status Codes (EA, EE, EL, EP, or ES) have been added to these Codes:

‘L155’, ‘L156’, ‘X859’, ‘X860’, ‘X861’, ‘X862’, ‘X863’, ‘X864’, ‘X865’.

If the declared document is an electronic licence and a non-electronic Status Code is declared, the declaration will be rejected.

CDS Rejections - Example

If we are to take the first document code C121 as an example, which covers diamonds from Russia, appendix 5a states that the ID to be completed is “ Enter the reference number of the certificate certifying that the diamonds are not mined, processed or produced in Russia.”

CDS will now validate this, and if not completed correctly, the entry will be rejected accordingly.

So, how can I be compliant?

Importers and exporters are required to review the UK Trade Tariff Volumes 2 and 3.

If you are using a third party to complete the declarations for you, ensure that the document code and reference are included in the clearance instructions.

Document codes can be found in Appendix 5A of the UK Trade Tariff Volume 3. These are entered in data element 2/3 for both imports and exports.

By referencing all the information in your clearance instructions, you are ensuring that you are evidencing compliance.

Note: The classification and document codes in the UK Trade Tariff can be updated weekly, and CDS is regularly updated.

UK Export Controls – A Simple Guide

Fri, 18 Jul 2025 10:51:14 GMT

UK export controls are legal restrictions on the export and transfer of goods, software, and technology from the UK to other countries, designed to protect the security interests of the UK and its allies.

The evident and pertinent question to ask is, which items are subject to export control regulations?

In the UK, the go-to place to find the answer is the UK Strategic Export Control List, which provides a list of strategic military and dual-use items that require export authorisation from the Government of the United Kingdom - UK Strategic Export Control List . Essentially, the list is broken down into various sections covering:

UK Military List
UK Dual-Use List
Non-Military Firearms List
Human Rights List
UK Security and Human Rights List
UK Radioactive Source List

The focus of this article is the Military and Dual-Use Lists, which cover the majority of controlled items exported from the UK. The aim is to flag controlled items and identify the applicable control classification (e.g., Military List or Dual-Use category)

Let us begin with military items and ask: What is a military item?

A military item is an item that has been specifically designed for military purposes. Simple examples would include firearms, tanks, bombs, and submarines. In addition, a commercial item that has been changed, adapted, or reconfigured for a military purpose will also be classed as a military item. For example, a commercial vehicle that has been fitted out with a military specification tyre inflation system. All goods classed as military will need an export licence when exported from the UK. You must apply for a licence from the Export Control Joint Unit (ECJU), Export Control Joint Unit - GOV.UK. If your items are on the consolidated control list, or if you have concerns about the intended end-use or the end-user. Applications for export licences should be made via the ECJU’s online export licencing system called SPIRE (Strategic Proprietary Information and Records Environment), which is soon to be entirely replaced by a new system called LITE (Licensing for International Trade and Enterprise.) Currently, only Single Individual Export Licences – SIELs – can be applied for via the LITE system. LITE and Best Practice .

Dual-Use items are goods designed for civilian use but can also be used in a military environment and the production of chemical, and biological weapons. An example of a dual-use item is a pump made of ‘exotic’ materials that can withstand very high temperatures, which potentially could be used to produce chemical/biological weapons.

Dual-Use is based on the technical capability of an item - this means that the technical capability of the item must be known to enable the detail to be compared against the Dual- Use List.

It is essential to note that the government has the authority to require an export licence for items, even if they are not listed on the UK Strategic Export Control List. These are generally referred to as ‘catch-all’ or ‘end-use’ controls. Goods having the capability of being used in the manufacture, development, use, or testing, etc, of weapons of mass destruction (WMD), are subject to control, whether or not they are classed as Military or Dual-Use. This makes obtaining end-use information and checking the validity of the overseas party critical. Note also that some countries are subject to international sanctions which seek to prevent the export of many items, not just Military and Dual-Use items. Russia is one such country that is subject to extensive sanctions from the UK/EU, and the US.

Export controls are not limited to tangible items. Intangibles such as technology (including information contained in software) linked to Military and Dual-Use items are also subject to government authorisation. Examples of technology include technical data (blueprints, drawings, etc) that are capable of use in connection with the development and production of weapons of mass destruction (WMD). Electronic transfers, such as Email, fax, and video conference, can also be subject to export controls if they contain information related to the development or production of strategic goods (Dual-Use/Military).

What measures should a business take to avoid contravening export control laws?

It is highly recommended that businesses conduct due diligence on their existing processes and procedures, that should include a review of your product range to determine product jurisdiction (Military, Dual-Use or Commercial) and also a review of your customer base by utilising a reputable ‘Screening Tool’ to ensure none of your customers are on a sanctions list. Staff training for all segments of the business, supplemented by senior management support, is a key element of due diligence that helps spread awareness of export controls throughout the company.

NTE 2025/19: Foreign Influence Registration Scheme launch - guidance on registering foreign power arrangements

niamho@strongandherd.co.uk (Niamh O'Connor) — Mon, 14 Jul 2025 08:28:10 GMT

The Home Office has released Notice to Exporters 2025/19, publishing details on when and how you must register with the Foreign Influence Registration Scheme, or FIRS .

The new scheme originates from the National Security Act 2023, which received Royal Assent in July 2023, with implementation by the FIRS from 1 July 2025.

Registration of an event becomes necessary when a UK organisation or person finds itself under the direction or influence of a foreign state or foreign government body.

Definitions are given within the guidelines to enable a clear assessment of when to register such influencing direction or activity.

Definitions:

A definition of a ‘direction’ from a specified foreign power or a foreign power-controlled entity can be identified as being formally given by contract, for example, or informally, such as in a quid pro quo arrangement .

The definition of ‘relevant activities’ has a default meaning that encompasses all activities, including, but not limited to, commercial activities, the provision of goods and services, research activities, and attendance at events.

Exemptions are in place for certain activities. These are given in the guidance documents . A link is provided later in this document.

Registration of any relevant foreign influence activity is obligatory as it relates to the safety and interests of the UK.

When to Register with the Foreign Influence Registration Scheme (FIRS)

There are 2 types of activity that may need to be registered under the FIRS scheme: the Political Influence tier and the Enhanced tier, as follows:

Political influence tier:

Registration is necessary if you are instructed by a foreign power to carry out, or arrange for others to carry out, political influence activities in the UK . Details from the guidance are as follows:

The political influence tier requires individuals or organisations to register where they are directed by any foreign power (except the Republic of Ireland ) to carry out, or arrange for someone else to carry out, political influence activities in the UK.

A foreign power includes:

the sovereign or other head of a foreign State,
a foreign government, or part of a foreign government (for example, a ministry or department of a foreign government);
an agency or authority of a foreign government, or of part of a foreign government (for example, a police force or military of a foreign government),
an authority responsible for administering the affairs of an area within a foreign country or territory (for example, a local government authority in a foreign country);
a political party which is a governing political party of a foreign government.

Political influence activities include communications made to senior public officials or politicians (for example, emails or meetings), public communications (for example, the publication of an article) or disbursements (for example, the provision of goods or services) which are intended to influence one of the following:

An election or referendum in the UK
A decision of a Minister or Government department (including a Minister or Government department of Wales, Scotland, or Northern Ireland);
The proceedings of a UK-registered political party (such as their manifesto commitments);
A Member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament, or Senedd Cymru

Enhanced tier – relating to Russian or Iranian influences

Registration is necessary if you are instructed by the Russian or Iranian state to carry out, or arrange for others to carry out, ‘relevant activities’ in the UK

The enhanced tier requires:

Individuals or organisations to register where they are directed by a specified foreign power or specified foreign power-controlled entity to carry out, or arrange for someone else to carry out, “relevant activities” in the UK;
Specified foreign-power controlled entities to register any “relevant activities” that they carry out themselves in the UK.

Details of the foreign powers and entities which have been specified on the enhanced tier for Iran and Russia can be found at the link below:

Foreign Influence Registration Scheme specified powers: Iran - GOV.UK

Foreign Influence Registration Scheme specified powers: Russia - GOV.UK

Further information and links to the legislation and guidance:

A link to the legislation can be found here:

National Security Act 2023

Provision for the Registration scheme within the legislation can be found here:

National Security Act 2023

To find out more and whether you need to register, read the FIRS guidance and FIRS business-specific guidance .

If you have further queries, contact the FIRS General Enquiry Desk at the following link:

firs-general-enquiries@homeoffice.gov.uk .

The Safety and Security GB Service

Thu, 10 Jul 2025 10:39:41 GMT

For Businesses that are established within GB (England, Scotland, Wales), you may need to use the Safety and Security GB service to submit your ENS declarations.

ENS declarations themselves have always formed a requirement for imports from the rest of the world, excluding the EU. This is a common practice and has been in place for all road, air, and sea movements.

ENS stands for “Entry Summary Declaration,” which is the declaration submitted to HMRC that includes safety and security information.

What has changed is the requirement for the EU imports to be declared through a safety and security declaration (ENS). This has been a requirement for ENS declarations for EU imports since January 31, 2025.

The GB S&S service is exclusively for GB imports and is separate from the ICS2 (an EU system) used to declare safety and security declarations at import into the EU.

Just like ICS2, it is the carriers’ responsibility to ensure that the ENS declaration is submitted at import into GB, and we will discuss those responsibilities in this article.

Both systems, that is, GB S&S and IC2, are separate systems, and it is essential to note that they do not communicate with each other. There is no transfer of data or transparency between the two systems. Whether you are a carrier or importer, you may need to register for both systems to complete the declarations. However, we will address this later in the article.

Why do we have to submit them?

The requirement for submitting the ENS declarations is, as the name suggests, for safety and security purposes. It is to ensure that there is visibility at the time of goods import, and that the goods are safe to be imported.

ENS declarations are in place to assess the risk of goods being imported, to identify any safety concerns associated with certain goods, and to protect GB interests.

They conduct a pre-notification goods risk assessment for UK authorities, focusing on goods with the potential to be imported for illicit or illegal purposes, or for goods that may be smuggled into Great Britain.

Are NI goods exempt from Safety and security declarations?

Northern Ireland Qualifying Goods do not require safety and security declarations to be submitted. This is because there is a legislated guarantee for unfettered access for NI businesses to the UK.

This can apply to consignments that are travelling indirectly from NI through Ireland, for example. These consignments can be exempt from the Safety and security requirement as long as they are Qualifying Goods and they are documented through Ireland.

What about imports into NI from GB?

Imports into NI from GB do not use the GB S&S system. NI imports utilise the ICS2 system, which is updated from the ICSNI system, and this system is used to submit NI import safety and security information.

If you require further information on ICS, read our article - The Import Control System and Northern Ireland

What about other movements? Are there any other exclusions from the requirements to submit the ENS declarations?

Yes, there are. There is only a limited number, and they can be found within Article 104 of Commission Delegated Regulation (EU) 2015/2446. Link below:

Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council as regards detailed rules concerning certain provisions of the Union Customs Code

An example of some movements that are excluded is the transportation of electrical energy and goods via pipeline.

Who has the responsibility to submit the ENS declarations?

The sole legal responsibility to ensure that ENS declarations are submitted lies with the carrier of the goods.

Definition of the Carrier: This is the operator of the active means of transport.

Rail – Rail freight operator
Air - The airline
Sea- The shipping line

RORO (roll on roll off):

For accompanied goods, the haulage company
For unaccompanied goods, the ferry operator

If a third party is completing the declaration on behalf of a carrier, there must be a written consent form between all parties, which must be evidenced as such. HMRC guidance states that:

Commercial terms can be used when arranging for a third party to file on a carrier’s behalf. This may involve amending an existing contract or creating a new one.

Safety and security declarations - Safety and security import requirements: entry summary declarations - Guidance - GOV.UK

This is where it is imperative, when using a third party to complete the declarations, that documentary evidence is in place to confirm the permission for the third party to do so.

What about Timelines?

Are there any timelines?

Yes, there are!

Where an ENS is to be declared along with a goods import declaration, the ENS declaration must be completed in a timely manner, as follows:

Maritime containerised cargo - Minimum 24 hours before loading at the port of departure

Maritime bulk or break-bulk cargo- Minimum 4 hours before arrival

Roll on roll off (RoRo) - accompanied freight- Minimum 2 hours before arrival of the ferry operator

RoRo — unaccompanied freight- Minimum 2 hours before arrival of the ferry operator

Short sea journeys- Minimum 2 hours before arrival

Short-haul flights- less than 4 hours’ duration and at least at the time of actual take-off (wheels up)

Long-haul flights- Minimum 4 hours before arrival

Rail and inland waterways- Minimum 2 hours before arrival

Channel Tunnel- Minimum one hour before arrival at the Eurotunnel terminal by the haulier

Road traffic- Minimum 1 hour before arrival

How are ENS Declarations submitted?

In order to submit the declarations, you must first subscribe to the S&S Service. Registration can be made at the following link:

You will need:

Government gateway account
A GB EORI number
In-house software, or by purchasing software or using a CSP (Community service provider)

To complete entry summary declarations

You will need to have the following information in place prior to making the declaration:

Transport information - airway bills, bill of lading, CMR
Commercial invoice/s for the consignment
Definition of the goods and the goods description
Details of the exporter and importer - that is, the consignor and consignee
The type and amount, as well as the packaging information
The mode of transport at the border
Any onward journey details for the consignment
Safety and Security, Great Britain location code for the port of entry

Can we submit the declaration through the GB S&S service?

The answer to this question is that there is no online tool or system available on the government website for submitting S&S declarations.

This means that you must have compatible software to do so, or you can use a CSP (Community System Provider). Information can be found at the following link:

Trade and commercial contacts for Community System Providers - GOV.UK ,

You can also develop your own software or liaise with a software provider if you wish to explore this option.

Some software allows the ENS declaration to be tied to the import Customs declaration, whereas other software requires the information to be submitted separately. It is recommended to liaise with your provider if you are unsure.

Software developers providing customs declaration software - GOV.UK

What type of information is needed for an ENS declaration?

If you are an importer, you may have been asked to provide additional information to your carrier or agent who is making the ENS declaration on your behalf. The necessary information may not always be on the exporter's invoice but can be found within the Customs clearance instructions.

This is because the ENS declaration is often submitted concurrently with the import declaration. The information that might be requested could include the following;

Any documents or licences and transport documents (a bill of lading, for example).
The commercial invoice, along with details of the exporter or importer, a description of the goods being imported, and how the goods are packed.

The Exporter frequently provides insufficient information to satisfy the requirements of an ENS declaration.

There are 20 mandatory fields within an ENS declaration, eight conditional fields, and nine optional fields. Detailed guidance can be found at the following link:

Get ready for safety and security declaration requirements for importing goods from the EU - GOV.UK

Can we amend the declaration if there is a mistake?

There is a legal requirement to ensure that all the information provided is correct at the time of submission, although you can amend an ENS declaration up until the goods arrive at the GB border.

Once the goods have arrived, the ENS cannot be amended, and any amendment to the original ENS submission must have been completed on time.

There is scope for changes with diversions within GVMS and RORO movements.

In the event of a diversion:

If the goods have not already been declared with an ENS, then this will be required. In this scenario, the submission should be made within 2 hours of the arrival time.

If it is the case that you have submitted your ENS declaration, but there has been a diversion from the Customs office at the first entry, then the Customs office of first entry can be amended, and the new Customs office of first entry can be completed.

To Conclude

If you are unsure what information your carrier or agent may need, please refer to the section above.

You may need to contact the exporter for further information if requested to do so by the party making the import ENS declaration.

If any third parties are submitting your ENS declarations for you, ensure that there is a contract in place to support this and that all parties are aware of their responsibilities.

If you wish to undertake the ENS declarations yourself, registration with GB S&S will be required, along with the requirement for software to enable declaration submission.

Ensure that there is an ENS declaration submitted for all consignments unless the consignment is exempt or is being imported from NI, and that the goods are defined as NI qualifying goods.

You may wish to consult with your third-party provider to document this in your internal records.

Should you wish to find out more information or have further questions, please get in touch.

HMRC publish Notice to Exporters 2025/18: Compound Settlement for Breaches of Export Control

niamho@strongandherd.co.uk (Niamh O'Connor) — Thu, 10 Jul 2025 10:25:29 GMT

HMRC have published Notice to Exporters 2025/18 detailing a compound settlement made by a UK exporter for breaches of UK export control conditions to Russia.

The notice, published on 8th July 2025, details a UK exporter being fined for breaching The Russia (Sanctions) (EU Exit) Regulations 2019. The compound settlement for that exporter involves a penalty of £1,160,725.67.

The published article advises that this is the most significant compound settlement that HMRC has concluded for a Russia sanctions offence.

Businesses are reminded of their obligation to comply with UK export controls, licensing, and sanctions conditions. Failure to do so is a serious offence and can result in financial penalties and criminal prosecution.

If a trader has concerns that goods for export have been delivered or diverted for delivery to Russia, they are advised to contact HMRC as soon as possible.

Further information and guidance

Further information is available at the links below:

Guidance on the scope and operation of the UK’s overall sanctions regime .

Assessing and addressing potential sanctions circumvention  and  European Commission guidance on preventing Russian export control and sanctions evasion .

Export controls: military goods, software and technology - GOV.UK

The Department of Business and Trade released the first US Goods Origin documents to support the implementation of the US-UK Economic Prosperity Deal

Tue, 08 Jul 2025 16:08:23 GMT

The Department of Business and Trade have published Preferential Origin and Quota documentation that will support the use of the US-UK Economic Prosperity Deal when importing beef and ethanol from the United States. The General Terms of the agreement were finalised on the 8 ^th May this year.

The deal, which is still under negotiation, is not a full free trade agreement but does follow the compliance protocol of the Customs Tariff (Preferential Trade Arrangements) (EU Exit) Regulations 2020.

The two documents provide guidance on how to utilise the Rules of Origin and Quota to import qualifying beef and ethanol products from the US at a lower duty rate, as agreed under the terms of the EPD.

Lower duty rates and quota numbers for the qualifying products have been effective since June 30 ^th , 2025.

The United States Origin Reference Document

Section A of the Origin Reference Document lists the conditions that goods must meet to qualify for a lower duty rate on import to the UK.

Articles 1-4 give a definition of how goods can be identified as qualifying goods, such as being wholly obtained or sufficiently processed.

Articles 5-7 detail operations, materials, and packaging that would exclude goods as qualifying

Section B of this document outlines the compliance evidence and conditions required to demonstrate that goods qualify as US-originating goods.

Articles 8-9 detail proof of origin and statements required, with Article 10 detailing where evidence of origin may not be required to implement a waiver for goods under the value of £1000

Annexe 1 relates to the minimum data required to evidence applicability for preferential tariff treatment, including how the goods must be clearly identified as applicable on the import paperwork .

Annexe I also defines the qualifying statements of origin needed on the compliance documentation.

The table in Annexe II provides the product-specific rules necessary to define whether products for import are qualifying goods.

The table is provided below:

The United States Preferential Tariff Document

Quota and duty rates for the goods referred to in the Origin Reference Document are set out in a table at Annexe II of the Preferential Tariff document . The table, located in the link to the Preferential Tariff Reference document below, outlines the Tariff Classification, Quota Volumes, and Quota Periods for the import of qualifying products covered by the EPD.

It is anticipated that further origin and quota information will be released for additional products as the EPD trade negotiations progress.

Links to the two documents can be found below:

US_Origin_Reference_Document_V1.docx

The_US_Preferential_Tariff_Reference_Document_V1.docx

The General Terms for the US-UK Economic Prosperity Deal can be found below:

General terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal (web accessible version) - GOV.UK

The regulation can be found here:

The Customs Tariff (Preferential Trade Arrangements) (EU Exit) Regulations 2020

Contact details for the Department of Business and Trade can be found here:

tariff.implementation@businessandtrade.gov.uk

NTE 2025/17: update to the UK arms embargo on Armenia and Azerbaijan published 3rd July 2025

niamho@strongandherd.co.uk (Niamh O'Connor) — Mon, 07 Jul 2025 11:41:49 GMT

The Foreign, Commonwealth & Development Office and the Export Control Joint Unit have jointly issued Notice to Exporters 2025/17, dated 3 ^rd July 2025, updating traders on amendments to the wording and conditions of the UK arms embargo on Armenia and Azerbaijan .

The NTE has been published following a government statement made by Stephen Doughty, Minister for Europe, North America, and Overseas Territories, on July 1 ^st , 2025, advising of changes to restrictions on both countries.

The UK government has refined the wording of the controls detailed initially in the UK's interpretation of the 2014 arms embargo, as issued by the Organisation for Security and Co-operation in Europe (OSCE).

The wording changes are as follows:

from ‘all’ the UK Military List’ to ‘Weapons, ammunition, and munitions’
The text ‘where this equipment could be used in the Nagorno-Karabakh region’ has been removed from the conditions.

Definition:

The UK’s embargo, therefore, applies to weapons, ammunition, and munitions specified in the Military List entries ML1, ML2, and ML3, and is expressly detailed as goods that could be used by either country’s government entities on the land border between Armenia and Azerbaijan. Government entities include the military, police, and security forces.

Controlled Goods

Standard Individual Export Licences (SIEL) are required for all Military and dual-use goods for export to Armenia and Azerbaijan.

A link to the Export Licensing System can be found at the link below:

Apply for a standard individual export licence (SIEL) - GOV.UK

Controlled goods can be identified on the Consolidated List of Strategic Military and Dual Use goods list at the link below, which includes the UK Military List:

Consolidated list of strategic military and dual-use items that require export authorisation

The update from the ECJU reminds exporters that all export licences are assessed on a case-by-case basis against the UK Strategic Export Licensing Criteria . A link is below:

Strategic Export Licensing Criteria

Transit control

Traders are also reminded that a transhipment licence will be required for the movement of controlled goods through the UK with a destination of Armenia and Azerbaijan .

The Ministerial Statement by Stephen Doughty issued on 1 ^st July can be found at the link below:

Written statements - Written questions, answers and statements - UK Parliament

Further Information and Contact Details

For financial sanctions: contact the Office of Financial Sanctions implementation ofsi@hmtreasury.gov.uk

For UK export controls, contact the Export Control Joint Unit (ECJU)

Helpline: 020 7215 4594 or email: exportcontrol.help@trade.gov.uk

To receive updates about export controls and trade sanctions, register for Notices to Exporters at the link below:

Export Control Joint Unit

Transport Sanction information is available from the Department for Transport at the following email address: transportsanctions@dft.gov.uk

For specific queries about the sanctions regime, email the Foreign and Commonwealth Development Office at the following email address: fcdo.correspondence@fcdo.gov.uk

More details on the UK arms embargo for Armenia and Azerbaijan can be found on the Government Guidance page on the link below:

UK arms embargo on Armenia and Azerbaijan guidance page .

Notice to Exporters 2025/17 can be located at the following link:

NTE 2025/17: update to the UK arms embargo on Armenia and Azerbaijan - GOV.UK

The Import Control System and Northern Ireland

Fri, 04 Jul 2025 12:13:51 GMT

Whether you are a business established in Great Britain (that’s England, Wales, and Scotland) or in Northern Ireland, as part of the United Kingdom, you may need to complete Entry Summary Declarations (ENS) if you import goods from abroad. These are also referred to as Safety & Security Declarations.

Safety & Security Declarations are not new to us. In fact, when we were part of the European Union, they were required in the UK for imports from all third countries (where the UK was the EU’s first port/airport of import). Furthermore, we used the EU-wide Import Control System (ICS) to submit them. This, of course, ceased when the UK left the EU.

We now have two separate systems here in the UK: One for imports into Great Britain, known as the S&S GB service, and one for imports into Northern Ireland, known as the ICS2. For those who aren’t aware, the ICS2 is an EU system that is replacing the current Import Control System for Northern Ireland (ICS NI). Carriers responsible for submitting Entry Summary Declarations must use it from 1st September 2025, to continue making Entry Summary Declarations when moving goods from all non-EU countries, including Great Britain, to Northern Ireland.

Carriers will also need to use the ICS2 when moving goods from Great Britain to the EU.

Details of the S&S GB service can be found in a separate article on our website. In this article, we focus on the Northern Ireland service and have compiled some relevant details about the ICS2 service.

Looking at the Import Control System, whether it is the GB or NI version, it is crucial to understand that it is the carriers (the organisations that transport the goods) who are responsible for ensuring that Entry Summary Declarations are submitted. It is not the responsibility of the importer, nor is it the responsibility of the Customs broker or clearance agent. However, carriers can use a third party to submit the ENS, rather than doing it themselves.

To avoid any misunderstanding about who is responsible under ICS2, carriers are defined as airlines, shipping lines, ferry operators, road hauliers, and rail operators.

So, what exactly is ICS2…

What is ICS2?

ICS2, or Import Control System 2, is a new Customs system implemented by the European Union, along with Switzerland, and Norway, to enhance the safety and security of goods entering these territories.

It requires businesses to submit advanced, detailed electronic information about goods (before they arrive), allowing Customs authorities to assess risks and potentially intercept threats earlier in the supply chain. This system aims to improve border security and streamline trade processes.

ICS2 also applies to goods entering Northern Ireland from Great Britain or countries outside the EU.

Under the ICS2, Carriers will need to provide the same data that is provided now, together with some additional data specifically for ICS2 purposes.

Who must use it?

Carriers are responsible for submitting Entry Summary Declarations, but they can use a third party to submit them on their behalf. To remind you, Carriers are defined as airlines, shipping lines, ferry operators, road hauliers, and rail operators.

If it is an EU system, why does it apply to Northern Ireland?

ICS2 applies to Northern Ireland because, under the Windsor Framework, Northern Ireland remains aligned with specific EU rules for goods, including those related to safety and security declarations. This alignment means that businesses moving goods into or through Northern Ireland, including those from Great Britain or other non-EU countries, must comply with the Import Control System 2 (ICS2).

Why doesn’t ICS2 apply to Great Britain (England, Wales, and Scotland)?

Great Britain is no longer part of the EU and is not aligned with the EU’s rules and regulations as they apply to the movement of goods. For goods entering Great Britain, carriers and their agents must use the Safety and Security GB (S&S GB) service. Full details of that service can be found here:

When was ICS2 implemented in Northern Ireland?

Since 1st April 2025 onwards, carriers and their agents are required to use ICS2 for completing Entry Summary Declarations (ENS) for goods arriving from Great Britain or from countries outside the EU.

However, for road freight, there is a Road Deployment Window that runs until 1st September 2025, which includes Ro-Ro movements, both unaccompanied and accompanied, into Northern Ireland.

For established Northern Ireland companies (XI EORI), deployment windows must be requested from HMRC. If you have not already requested to use this deployment window, you must request this from HMRC as soon as possible. Email HRMC at ics.helpdesk@hmrc.gov.uk .

Who can submit an Entry Summary Declaration?

The carrier that moves the goods into Northern Ireland is responsible for ensuring that Entry Summary Declarations are submitted. However, carriers can opt to use a third party to submit the declarations on their behalf, such as a Customs clearance broker or agent. The carrier is the owner of the active means of transport crossing the border, and is defined as follows:

Air: The airline

Sea: The shipping company

Rail: The rail freight operator

RoRo: Driver-accompanied freight: The haulage company

RoRo: Unaccompanied freight: The ferry operator

The border, in the context of Northern Ireland, covers the approved ports and airports. Under the Windsor Framework, there is no border between Northern Ireland and the Republic of Ireland.

Does ICS2 apply to Couriers?

Yes and No.

Safety and Security declarations are only required for certain parcel movements from Great Britain to Northern Ireland under the Windsor Framework. Entry Summary Declarations will be needed for business-to-business (B2B) parcel movements from GB to NI. They are not required for parcels being sent to consumers.

Details about sending parcels between Great Britain and Northern Ireland under the Windsor Framework can be found here:

Sending parcels between Great Britain and Northern Ireland under the Windsor Framework

What about the Trader Support Service (TSS)?

Traders currently registered to use the Trader Support Service to move goods into Northern Ireland do not need to register to use ICS2. Registered TSS traders can continue to use the Trader Support Service to submit entry summary declarations.

However, traders who do not use the Trader Support Service will need to register with HMRC for ICS2, but only if their EORI number starts with 'XI'.

Is the ICS2 Registration Process Complicated?

The word “complicated” is probably too strong. But the process does involve registration on the EU Shared Trader Interface (also known as the EU Customs Trader Portal). It also consists of completing the EU’s mandatory self-conformance testing before using ICS2.

You can register by emailing admin.uum@hmrc.gov.uk and providing your business name, email address, business address, and EORI number (starting XI).

A software package developed for ICS2 will also be required, to submit the ENS itself (in advance), the ‘arrival’ notification and the ‘presentation of goods’ notification (when the goods arrive in Northern Ireland).

The process does appear daunting at first glance, and it is probably worth engaging with a software developer before embarking on the registration process. These organisations possess a wealth of knowledge about ICS2 and may be able to provide valuable assistance.

ICS2 software developers can be found here:

Software developers providing Entry Summary Declaration support

Note that the ICS helpdesk at ics.helpdesk@hmrc.gov.uk can also assist with the registration process.

Once registered on the ICS2, these are the steps in the process:

Entry Summary Declaration (ENS)
Carriers, or their agents, submit a Safety and Security declaration in advance of the goods arriving in Northern Ireland.
Notification of arrival
HMRC/Border Force is notified when the goods arrive.
Presentation of goods:
HMRC/Border Force is notified when the goods are to be presented for inspection.
Risk assessment:
HMRC/Border Force assesses the risk of the goods.

What information will Carriers need to provide?

Carriers will need to provide certain information to ensure the Entry Summary Declarations are completed accurately and submitted on time.

The type of information (data) that is required, before the goods move into Northern Ireland (or indeed the EU), is likely to include the following:

Consignor
Consignee
Mode of transport
Accurate description of the goods
6-digit commodity code
Total amount and weight of goods
Place of delivery
Any additional information or supporting documents (for example, licences and certificates)

In terms of the description of goods, HMRC has made it clear that general descriptions are not acceptable and will lead to delays upon import. For example, the use of the general term “fruit” to describe a consignment of apples will not be acceptable, and the movement will be delayed.

There doesn’t appear to be a data-by-data element guide for the ICS2 (unlike our own Customs Declaration Service). The best we can find can be accessed here:

https://taxation-customs.ec.europa.eu/document/download/84ff4362-3e39-4b5d-a22e-0b994c349b19_en

The Library on the EDU website is also a good directory for reference. It can be found here:

https://circabc.europa.eu/ui/group/18fb5859-3970-4ac5-b30b-6604977a15a7/library/16e29912-d290-417e-a45c-b286407e1770

Summary

So, there you have it. If you are a carrier (as defined) bringing goods into Northern Ireland from Great Britain or any other non-EU country, you must register for ICS2 and begin completing Entry Summary Declarations (ENS), also known as Safety and Security Declarations.

You can, if you wish, subcontract the work to a third party, such as a Customs broker or clearance agent. However, you cannot subcontract your responsibility for the declarations, which remains with you.

You must submit an ENS, follow it up with an arrival notification, and advise HMRC/Border Force when the goods are available.

If you want to find out more about the Import Control System and how to complete Entry Summary Declarations, please get in touch with us for detailed information.

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

That was the News: June 2025

niamho@strongandherd.co.uk (Niamh O'Connor) — Thu, 03 Jul 2025 14:47:53 GMT

While our thoughts may drift to summer holidays, we should remind ourselves that Customs compliance doesn't take a break. Whether it's a subtle update to CDS validation rules or a quiet revision to the UK Trade Tariff, staying alert is essential, as it's often the small things that can trip us up in international trade. At Multimodal, we were reminded just how challenging it can be to stay ahead of ongoing regulatory changes. Many within the industry echoed our thoughts. So often, businesses believe they're fully compliant, only to discover that it's the small, overlooked details that can lead to issues. Unfortunately, it's usually HMRC who identifies these gaps in compliance, often when it's too late.

Our Courses Directory brings all our training programmes together in one convenient location, allowing you to easily navigate and focus on the areas of international trade and Customs where you or your team wish to develop. Stay informed, stay compliant, and don't let the small details catch you out.

For all the latest news & updates, check out our Industry Insights page, and don't forget to follow us on LinkedIn !

Magnified Mistakes: How Minor Preference Errors Are Costing Importers

It’s a tale as old as Free Trade Agreements - you’re importing goods under preference, your supplier gives you an invoice statement, everyone’s happy – until HMRC comes knocking. Recently, an importer found itself facing a duty bill, despite having claimed preference. Why? Because the preference statement wasn’t exactly correct. Not wildly off, just... not replicated word for word in line with the FTA, which was mainly the UK-EU Trade Cooperation Agreement (TCA).

Trading with the US: Importing into the US – Some important things to look for

With the US's approach to its tariff measures shifting, here are some key pointers for a UK business looking for more clarity on how the US Tariff functions.

Changes to how licences are declared on goods imported, exported, or transited through Northern Ireland: Implementation of CERTEX, June 28th, 2025.

Since 28th June 2025, licence data on declarations for goods movements into or out of Northern Ireland will be verified by the EU system CERTEX. This replaces Northern Ireland's Automatic Licence Verification System (ALVS).

Getting it right at the border - Update June 2025

The latest Animal and Plant Health Agency (APHA) newsletter release has been published. It gives the latest operational updates on border controls for importing live animals, germinal products, products of animal origin and animal by-products into Great Britain.

HMRC advise a Workaround for some Northern Ireland Location of Goods Codes being used with Additional Information Codes NIDOM & NIIMP

Some Location of Goods codes for NI have been omitted from the most recent CDS update. This will affect the validation of a location code on a declaration where DE 5/23 is recognised as an NI location and the codes NIDOM and NIIMP are used.

Update to the Customs Declaration Service to Allow the Use of Special Text Characters in UK Import and Export licences – Notice to Exporters 2025/16

Notice to Exporters 2025/16, published 17th June, advised that the Customs Declaration Service (CDS) has been updated to accept the use of special and diacritic characters when declaring UK import and export licences on CDS.

Delay to the implementation of CERTEX

HMRC advised earlier this month that the formatting of CHED referencing would be changing at the end of June due to the transition of the ALVS system to CERTEX, the EU verification system.

Barclays Maintenance scheduled for Saturday 5th July and Sunday 6th July

The Barclays file gateway will be undergoing maintenance on Saturday 5th July between 08:30 and 12:30 which will mean statements are delayed.

Customs Valuation Handbook Published

Wed, 02 Jul 2025 13:15:49 GMT

HMRC has published a Customs Valuation Technical Handbook, its most recent publication of guidance in the handbook style, to join the suite of handbooks available to users.

The Valuation handbook, published on June 25, 2025, explains the six methods used to establish the value of goods on which Customs Duty and import VAT are calculated, and when each method should be employed.

The handbook outlines the six regulatory methods for calculating Customs value, provides explanatory details through calculation examples, and offers information on a range of import types, as well as how the reason for the import can affect the value declared to HMRC.

There is also a useful section on Incoterms®, the internationally agreed commercial terms used to define responsibilities and risk when moving goods across borders.

The handbook explains HMRC’s interpretation of the law; however, traders are reminded that published guidance is not a legal requirement and that care should be taken to ensure compliance with the relevant regulations and the law.

A link to the updated list of published handbooks can be found at the link below: Customs Technical Handbooks - GOV.UK

Law

In the UK, Customs valuation law is provided by the Taxation (Cross-border Trade) Act 2018 (TCTA) and the Customs (Import Duty) (EU Exit) Regulations 2018 (CIDEER).

Additional provisions can be found in Notices made under the Customs (Import Duty) (EU Exit) Regulations 2018 .

Regulations for Northern Ireland

In Northern Ireland, the Union Customs Code (UCC) applies; additionally, the UCC DA and the UCC IA provide further provisions on Customs valuation.

Regulations 952/2013 (UCC), 2015/2447 (UCC DA), and 2015/2446 (UCC IA) can be found on the EU legislation website Eur-lex .

For imports into the UK prior to 1st January 2021, UCC legislation should have been applied.

Updates on Sanitary and Phytosanitary goods imports from Italy and Romania

Tue, 01 Jul 2025 13:10:49 GMT

Lumpy skin disease in Italy: Imports Suspended

Great Britain (England, Scotland, and Wales) has suspended the import bovine products from Italy after an outbreak of Lumpy Skin Disease. Imports of the affected products are therefore forbidden until further notice. Affected goods are:

live animals  
germplasm 
offal (except diaphragm and masseter muscles) 
raw milk and raw dairy products, including raw colostrum 
hides and skins, unless treated in line with point 2b, c or d of Article 11.9.13 of the WOAH terrestrial code 
all animal by-products (except casings, gelatine, collagen, tallow, hooves, and horns), unless processed using heat treatment to a minimum internal temperature of 65°C for at least 30 minutes

The outbreak of the disease found in a cattle farm in Sardinia was confirmed on June 21st, 2025.  

For restrictions on fresh or chilled (untreated) skins and hides and affected animal by-products of bovine origin, links to the declarations of the special measures, effective from June 27th ,2025 are below.

Lumpy skin disease in Italy: declaration of special measures (England)  (PDF, 119 KB, 2 pages)

Lumpy skin disease in Italy: declaration of special measures (Scotland)  (PDF, 112 KB, 2 pages)

Lumpy skin disease in Italy: declaration of special measures (Wales)  (PDF, 128 KB, 2 pages)

Italian hard cheeses for import

Bovine dairy products that have undergone a lower heat treatment than pasteurisation can still be imported if they have been through a process of ripening and ageing or maturation which commenced before May 23rd, 2025.

This means hard cheeses such as Gran Moravia, Parmigiano Reggiano and Grana Padano from Italy may still be imported, provided that all other import conditions are met and attestations in the relevant export health certificate (GBHC416) can be certified.

Sheep pox and goat pox: Romania 

Great Britain (England, Scotland, and Wales) has suspended the import of the following sheep and goat commodities from Romania following an outbreak of sheep pox and goat pox (SPGP) that was confirmed on June 17th, 2025. This updates restrictions that have been in place since July 2024 after an outbreak of Peste des Petits Ruminants (PPR) from Romania. The restrictions apply to the following SPS controlled imports:

live animals 
germplasm 
fresh or chilled skins and hides

The following regulatory declarations have been published to support the implementation of special measures.

Declaration of special measures: sheep pox and goat pox in Romania (England)  (PDF, 104 KB, 1 page)

Declaration of special measures: sheep pox and goat pox in Romania (Wales)  (PDF, 122 KB, 1 page)

Declaration of special measures: sheep pox and goat pox in Romania (Scotland)  (PDF, 103 KB, 1 page)

Restrictions to all SPS imports are given in detail in the published lists in the link below.

EU and EFTA countries approved to export animals and animal products to Great Britain .

Barclays Maintenance scheduled for Saturday 5th July and Sunday 6th July

Mon, 30 Jun 2025 12:09:05 GMT

The Barclays file gateway will be undergoing maintenance on Saturday 5th July between 08:30 and 12:30 which will mean statements are delayed.

HMRC have also advised that due to maintenance on Barclays payment processing system Faster payments will be affected on Sunday 6th July between 00:00 and 05:00.

As Faster payment is the only scheme which would normally process over the weekend, there is no alternative during the maintenance period. HMRC recommends paying into your CDS Cash account or Duty Deferment account in advance of the delays to ensure you have sufficient balance.

If there are insufficient funds available, declarations will be held pending release or clearance until after the maintenance when Faster payment can be made.

The alternative for Immediate Payment would be via the Online Payment Service using a corporate credit or debit card.

Regardless of the Immediate Payment MOP codes used on the declaration, payment can be made by any supported route.

In either of the above scenarios declarations will not be rejected.

Delay to the implementation of CERTEX

Fri, 27 Jun 2025 16:15:12 GMT

SPS Goods - ALVS transition to CERTEX

HMRC advised earlier this month that the formatting of CHED referencing would be changing at the end of June due to the transition of the ALVS system to CERTEX, the EU verification system.

HMRC have urgently advised that the transition to CERTEX will not take place the weekend of the 28th of June as expected and will be implemented in due course.

Presentation of the CHED reference on the declaration will need to be considered according to the type of movement being recorded

Therefore, HMRC request that traders and agents note the following:

CERTEX will no longer be implemented on 28 June 2025. A new implementation date has not been set.

Actions:

Traders may need to take action depending on where goods are being moved from – that is
Great Britain to Northern Ireland or
from the Rest of the World to Northern Ireland. 
Traders should continue to follow standard processes for controlled goods in Northern Ireland including reporting for inspections where required to do so.

Moving goods from Great Britain to Northern Ireland  

The new Common Health Entry Document (CHED) reference format on traders’ declarations will still be implemented from 28th June 2025.
Traders are reminded that the new reference format is letters followed by numbers and includes the full stop character .

For example, 'CHEDA.XI.2025.1234567' 

Declarations using the existing format (e.g., ‘GBCHD2025.1234567’) will not be rejected

However , traders are encouraged to use the new format in readiness for the future implementation of CERTEX

Traders will not receive CERTEX specific messages for these movements in CDS

Therefore, it will be necessary to continue to monitor the Goods Vehicle Movement Service (GVMS) at GVMS locations or the respective inventory system at inventory locations.

Moving goods from Rest of World to Northern Ireland – Continue to use the CHED reference in the existing format:

The delay in the implementation of CERTEX will mean that traders moving goods from the rest of the world to NI must not use the new Common Health Entry Document (CHED) format on their declarations from 28th June 2025 as previously published.
Instead – ROW movements to NI must continue to use the existing format found in Appendix 5a . For example, ‘GBCHD2025.1234567’. 
If a trader has pre-lodged any declarations using the new format - these must be changed before arrival on the Customs Declaration Service (CDS).
Failure to use the correct CHED format will result in rejections or holds on your goods once the goods arrive and potentially delays in getting the goods released.

Detailed guidance can be found at the link below:

Moving licensed goods into or out of Northern Ireland - GOV.UK

Additional support is available here:

For support for goods in movement, contact the Department of Agriculture and Rural Affairs (DAERA) on 0300 200 7852 or email daera.helpline@daera-ni.gov.uk .

For general support with freight movements or if a change is required on your declaration, traders can contact the Trader Support Service team .

For other queries, call the HMRC Customs and International Trade helpline on‌‌‌ 0300‌‌‌ 322‌‌‌ 9434‌‌‌ (textphone 0300‌‌‌ 200‌‌‌ 3719). 

For support with parcels movements, traders can contact their parcel express operator.

Note: this change does not impact express operators moving consumer parcels under the UK Carrier Scheme.

Delay in the implementation of CERTEX

niamho@strongandherd.co.uk (Niamh O'Connor) — Thu, 26 Jun 2025 09:57:42 GMT

On 3 June, we informed you about CERTEX, a system that will verify licence data on declarations for goods movements. It will replace the Automatic Licence Verification System (ALVS) for Northern Ireland. 

CERTEX will no longer be implemented on 28 June 2025. A new implementation date has not been set. 

Action to take for traders  

Traders may need to take action depending on whether they are moving goods from Great Britain to Northern Ireland or from the Rest of the World to Northern Ireland. 

They should continue to follow standard processes for controlled goods in Northern Ireland, including reporting for inspections as required.  

Moving goods from Great Britain to Northern Ireland  

This delay does not affect the use of the new Common Health Entry Document (CHED) reference format on traders’ declarations from 28 June 2025. The reference format is letters followed by numbers and includes the full stop character. For example, 'CHEDA.XI.2025.1234567'. 

Declarations using the existing format (e.g. ‘GBCHD2025.1234567’) will not be rejected; however, we encourage traders to use the new format in readiness for the implementation of CERTEX at a later date. 

Traders will not receive CERTEX-specific messages for these movements in CDS, so they must continue to monitor the Goods Vehicle Movement Service (GVMS) at GVMS locations or the respective inventory system at inventory locations. 

For detailed guidance, please visit GOV.UK . 

Moving goods from the Rest of the World (ROW) to Northern Ireland   

This delay means that traders must not use the new Common Health Entry Document (CHED) format on their declarations as of 28 June 2025. They must continue to use the existing format found in Appendix 5a . For example, ‘GBCHD2025.1234567’. 

If they have pre-lodged any declarations using the new format, these must be changed before arrival on the Customs Declaration Service (CDS). Failure to use the correct CHED format will result in rejections or holds on your goods upon arrival, potentially leading to delays in releasing the goods. 

CDS Alert: Barclays File Maintenance Due Weekend of 28th – 29th June 2025

Tue, 24 Jun 2025 10:22:04 GMT

HMRC is advising that Faster Payments will be unavailable for processing during the Barclays file maintenance periods planned for the weekend of June 28th and 29th 2025.

The Barclays File Gateway scheduled maintenance times are as follows:

Saturday 28 ^th June: 06.00 – 12.00
Sunday 29 ^th June: 05.00 – 12.00

During these times, statements will be delayed.

CDS Cash Account or Duty Deferment Account Payments

As there is no alternative to Faster Payments during the maintenance periods, users are recommended to consider early payment before a maintenance period commences, to ensure sufficient balance is available.

Declarations will be delayed until sufficient funds are available post-maintenance periods.

CDS Immediate Payment

For those using Immediate Payment, the alternatives during maintenance times are using the Online Payment Service or a corporate credit or debit card. Payment can be made by any supported route regardless of the MOP codes used.

Declarations will not be rejected during this time, but will be processed after the Barclays maintenance period.

Update to the Customs Declaration Service to Allow the Use of Special Text Characters in UK Import and Export licences – Notice to Exporters 2025/16

Tue, 24 Jun 2025 10:08:55 GMT

Notice to Exporters 2025/16, published 17 ^th June, advises that the Customs Declaration Service (CDS) has been updated to accept the use of special and diacritic characters when declaring UK import and export licences on CDS.

This change to CDS will also include a provision to exclude case sensitivity when declaring the licence details.

The changes were implemented with CDS release 4.8.0 in mid-June 2025.

The workaround in place since late 2024, announced in NTE 2024/31, will no longer be required going forward.

A link to NTE 2025/16 can be found below:

Notice to exporters 2025/16: updated use of special and diacritic characters on the customs declaration service (CDS) - GOV.UK

A link to the S&H article for NTE 2025/31 can be found below

NTE 2024/31: Use of special and diacritic characters on the Customs Declaration Service (CDS)

HMRC advise a Workaround for some Northern Ireland Location of Goods Codes being used with Additional Information Codes NIDOM & NIIMP

Mon, 23 Jun 2025 15:52:51 GMT

Some Location of Goods codes for NI have been omitted from the most recent CDS update. This will affect the validation of a location code on a declaration where DE 5/23 is recognised as an NI location and the codes NIDOM and NIIMP are used.

The affected location codes are given below and cannot be used on the import declaration until further notice

While HMRC work to amend the error, users are requested to use the following workaround

Where one of the affected Location of Goods codes is on the list above, declarants should use the most appropriate of the following as a workaround until HMRC advises that the situation is resolved:

If the operator has another site in Northern Ireland with a Location of Goods code not listed above, then that code should be used instead
If the location handles mainly maritime freight, then use Location of Goods Code GBAUBELBELBEL temporarily.
If the location handles mainly airfreight , then use Location of Goods code GBAUBELBFSBEL temporarily.

Note: This issue does not impact declarations using either an authorisation or a Customs Warehouse ID

HMRC have apologised for any inconvenience caused and will advise when the issue has been resolved.

Upcoming Events & Training Courses this July

niamho@strongandherd.co.uk (Niamh O'Connor) — Fri, 20 Jun 2025 12:26:58 GMT

Join us in July for comprehensive training courses on Customs compliance and international trade.

Our July sessions are tailored to suit your schedule, offering full-day courses and focused, shorter clinics. Whether you're looking to master the basics of import/export or delve into more advanced Customs regulations, we have a wide range of courses to suit your needs.

See below for further details of July courses.

Getting it right at the border - Update June 2025

Thu, 12 Jun 2025 13:09:35 GMT

The latest Animal and Plant Health Agency (APHA) newsletter release has been published. It gives the latest operational updates on border controls for importing live animals, germinal products, products of animal origin and animal by-products into Great Britain.

There is a lot to keep up with, and signing up for the newsletter on the APHA website is always recommended if your goods are subject to SPS controls. A link to the APHA newsletter registration page, with other useful contact information, is at the bottom of this article.

BTMS system implementation, replacing ALVS: Scheduled downtime on 12 June 2025

BTMS is being phased in, replacing the ALVS system.

Connectivity from CDS to the new BTMS will go live as follows:

Thursday, 12 June 2025, with scheduled downtime between 3 pm and 5 pm .

HMRC advises that traders may experience delays around this time. CDS and IPAFFS declarations will be queued during downtime and released once the system changes have completed.

HMRC advises to clear declarations in good time before the downtime begins, where possible.

Further advice is for consignments to avoid arriving at border control points during the 3 p.m. to 5 p.m. downtime, as processing will not be completed during the system outage.

The NCH cannot assist with clearances at this time. Declarations should automatically clear once system connectivity resumes.

Planned downtime for Customs Declaration Service – 14th-15th June 2025

The update to CDS version 4.8.0 is scheduled for release at 10.30 pm on Saturday, June 14th. It should be completed by 6.00 am on Sunday, June 15th.

HMRC advise the following:

CDS will be unavailable during this period.
Declarations submitted during this time will be processed when the service becomes available.
Creating, updating, or embarking a goods movement reference (GMR) during the downtime may be affected.
Goods with pre-lodged declarations attached to a GMR will be allowed to move using the Goods Vehicle Movement Service (GVMS).

For guidance on GVMS, information on service availability is available at the following link:

  Goods Vehicle Movement Service — service availability and issues .

Also, Traders are advised to note the following:

For import movements using GVMS, the declaration status should be checked and be manually arrived if this is needed: Details on manual arrival of goods movements can be found at the link below:

Manually arrive your goods in the UK - GOV.UK.

If consignments contain controlled goods with pre-lodged declarations, business continuity methods may be employed: The link below gives HMRC instructions on business continuity methods implemented during systems outages.

List of goods imported into Great Britain that are controlled - GOV.UK

Controlled goods with pre-lodged declarations should attend port inspection facilities or inland border facilities for goods to be inspected and released.
Traders are also advised that exports should have Permission to Progress (P2P) before commencing the goods movement.

Easement on medium-risk fruit and vegetables extended until 2027

The easement on medium-risk fruit and vegetables, due to be completed on 1st July, has been extended until 31st January 2027. This is a result of the SPS agreement between the UK and the EU, which was agreed in May.

As a reminder, this easement was implemented in 2024 and means that medium-risk fruit and vegetables are exempt temporarily from SPS controls for goods from the following countries:

EU Member States
Switzerland
Liechtenstein

Lifting of Restrictions on Bulgaria for Classical Swine Fever disease:

The UK has recognised Bulgaria’s disease-free status for Classical Swine Fever (CSF). It has confirmed the lifting of restrictions on imports from Bulgaria as of 30th May 2025 for the following goods:

fresh porcine meat
porcine meat products

Further detailed information can be found at the link below:

EU and EFTA countries approved to export animals and animal products to Great Britain  

Note: Import restrictions relating to Bulgaria’s African swine fever status remain in place.

UK-EU Sanitary and Phytosanitary Agreement

At the UK-EU summit on 19 May, the UK and EU announced that an agreement relating to Sanitary and Phytosanitary (SPS) goods was under discussion. Details have yet to be released, and no anticipated release date has been set.

Although the agreement is expected to ease SPS protocols on methods of UK-EU cross-border trade in agrifood, HMRC reminds traders of the compliance requirements that remain in place for SPS goods moving between the UK and the EU.

Important note : Customs and Rules of Origin requirements will not be included in the negotiations and are not expected to change from their present state.
 
A link to the key document for the UK-EU summit can be found below:

UK/EU Summit - Key documentation - GOV.UK

Foot and Mouth Disease - Avoid processing delays at the border for FMD susceptible goods from Hungary, Slovakia, and Austria  

Enhanced controls remain in place for Foot and Mouth disease-susceptible goods from Hungary, Slovakia, and Austria, which can cause delays at the border.

HMRC have requested that the following information be flowed down to declaring agents to help avoid unnecessary delays and checks at the UK border:

  Multiple CHEDs under the same MRN.      

A container or load may be held if a consignment within it could be subject to an SPS inspection. If an inspection is required, the whole load will be held.

Action to take: Preparation before crossing the border

Check the consignment status of mixed loads via IPAFFS and CDS
Where necessary, discuss options to minimise delays with the Port Health Authority/Local Authority (PHA/LA) at the point of entry into GB
Options may include devanning and separating out consignments that may be subject to inspection
Any action of this kind will likely require resubmitting the Customs Declaration for the load.    
Good communication between the declarant and those involved in the physical movement of the goods will be important to reduce the risk of goods being delayed at the port of entry.

Removal of consignments for inspections and amending a pre-lodged declaration     

If a CHED is cancelled in IPAFFS due to a consignment being removed from a load, the pre-lodged declaration must be amended to remove both the cancelled CHED reference and the relating commodity codes from the pre-lodged declaration. This will also apply if the request to remove the CHED reference has been made with the PHA.

Action to take:

Double-check that the pre-lodged declaration is accurate regarding any changes made to the load. CDS will attempt to access the inspection decision for a CHED. If a CHED is cancelled and the declaration is not amended to suit, the load will be held until the declaration is accurate.

The NCH can help in exceptional cases where the CDS declaration cannot be amended. HMRC advise that this assistance is for exceptional cases and will not release holds for any other reason

   3. If a consignment remains under an SPS hold in CDS: Common errors and action to take      

If the pre-lodged declaration has been checked, invalid CHEDs removed, the most common errors for the persistence of the ‘hold’ instruction are:  

A CHED reference number has been incorrectly entered into CDS    
Commodity codes are not aligning between the CHED, IPAFFS and the pre-lodged declaration. Submitted data must be consistent.
non-English characters/text copied and pasted into CHED fields on IPAFFS. Plain text is essential.
The final destination is not a recognised GB address, or the country code is not given as GB.

The first point of contact for any of these actions should be the Port Health Authority at the point of entry into GB.

Stay informed with the latest Import and Export updates from APHA - UK Plant Health Information Portal

Useful contacts and information sources

Imports of animal products :

Urgent questions regarding the import of animal products, including germinal products, should be addressed to the Port Health Authority or Local Authority at the Border Control Post (BCP) for the goods’ point of entry.

BCP and the PHA/LA contact information can be found at the link below:

Animals, animal products and HRFNAO imports: authorised border control posts in the UK - GOV.UK

Imports of live animals :

Urgent questions regarding the imports of live animals should be addressed to APHA at the following link:

Contact APHA - GOV.UK

Imports of plants and plant products: Urgent questions regarding imports into England and Wales should be made by email in the first instance to APHA at the following email address:

phsi-importers@apha.gov.uk .

APHA can be contacted by telephone on the following number: +44 (0) 3000 200 301

Technical help with IPAFFS:     

Call the APHA helpline on 0330 041 6999 or email at the following address: APHAServiceDesk@apha.gov.uk

Note : this service is not a 24-hour service.

Further sources of information  

Foot and Mouth disease -  Foot and mouth disease: latest situation - GOV.UK  

Importing from the EU:  
Imports, exports and EU trade of animals and animal products: topical issues - GOV.UK  

Products of animal origin for human consumption:

Import animal products for human consumption from the EU to Great Britain - GOV.UK  

Live animals and germinal products: https://www.gov.uk/guidance/import-live-animals-and-germinal-products-from-the-eu-to-great-britain  

High Risk Food and Feed Not of Animal Origin:

https://www.gov.uk/guidance/import-high-risk-food-and-feed-not-of-animal-origin-from-the-eu-to-great-britain  

Plants and plant products:   

Importing from non-EU countries:  

Live animals, animal products and High-Risk Food and Feed Not of Animal Origin:

Importing live animals, animal products and high-risk food and feed of non-animal origin from non-EU countries to Great Britain - GOV.UK   

Plants and plant products: 

Changes to how licences are declared on goods imported, exported, or transited through Northern Ireland: Implementation of CERTEX, June 28th, 2025.

Thu, 12 Jun 2025 13:06:18 GMT

From 28 June 2025, licence data on declarations for goods movements into or out of Northern Ireland will be verified by the EU system CERTEX. This replaces Northern Ireland's Automatic Licence Verification System (ALVS).  

From 28 June 2025, licence data on declarations for goods movements into or out of Northern Ireland will be verified by the EU system CERTEX. This replaces Northern Ireland's Automatic Licence Verification System (ALVS).  

Where a licence is required, the change to CERTEX will impact the following certification types: 

Certificates of Organic Conformity (COI) 
Plants and plant products (CHED.PP) 
Food and feed of non-animal origin (CHED.D) 
Food and products of animal origin (CHED.P) 
Live animals (CHED.A) 
Ozone Depleting Substances (ODS) 
Fluorinated Gases (FGAS)

Top Tip: For licensed goods’ movements for Northern Ireland by import, export, or transit – Double check the details

All licence information to be made on declarations should match those given on the licence.

Therefore, it will be necessary to check the details on the commodity code, the net mass, and

supplementary units. Inaccuracies will cause a stall in the movement.

Update to CHED References: New format required from 28th June 2025

From 28 June 2025, the Common Health Entry Document (CHED) reference must be provided on the declaration in the new format.

The reference format must be letters followed by numbers and include the full stop character to enable alignment with the EU CERTEX verification system

Example, 'CHEDA.XI.2025.1234567' .  

If the reference is not completed correctly:

The licence cannot be validated
The declaration will be rejected
A Movement Reference Number (MRN) will not be issued, and goods will be unable to continue

Pre-lodged declarations to be arrived from 28th June 2025

Pre-lodged declarations that will be arrived from 28 June must include the CHED reference in the new format.

A pre-lodged declaration for arrival from 28 June using the old CHED format must be amended to the new format using the Declaration Service (CDS) prior to the arrival of the goods.

Continue to use the old CHED format if pre-lodging a declaration to arrive prior to 28th June.

Failure to use the correct CHED format will result in rejections on arrival and risk a delay in goods release. 

Troubleshooting: CDS will send a notification if there is a problem with the declaration or goods

Examples:

a valid certificate or licence cannot be found (this will be checked at the pre-lodgement stage)
There is a mismatch between the data supplied on the declaration and the relevant licence or certificate (during the crossing).
The licence has an insufficient quantity remaining (advised during the crossing and is only applicable to certain licenses).

Before goods arrive, checks should be made for the following:

the accuracy of the supporting licence
the accuracy of the declaration, and amend the declaration if the details are inaccurate
respond to any messages you receive from CDS

Some software may not allow a declaration amendment. In these circumstances, the original, inaccurate declaration should be cancelled and a new one submitted. 

If using the Trader Support Service (TSS) for licensed goods movements, the TSS team should be the first point of contact for help.

Processes for making a declaration or obtaining a licence remain unchanged. 

A link to the guidance pages is below:

Moving licensed goods into or out of Northern Ireland - GOV.UK

Additional support for traders  

For support for goods in movement, contact the Department of Agriculture and Rural Affairs (DAERA) on 0300 200 7852 or email daera.helpline@daera-ni.gov.uk . 

For support with parcel movements, traders can contact their parcel express operator. Please note this change does not impact express operators moving consumer parcels under the UK Carrier Scheme.  

CDS Release 4.8.0 to Impact on NCTS Weekend of 14th and 15th June 2025

niamho@strongandherd.co.uk (Niamh O'Connor) — Wed, 11 Jun 2025 11:41:01 GMT

HMRC has advised that the planned release of CDS version 4.8.0 will impact the New Computerised Transit System (NCTS), and declarations may be delayed if not submitted in good time before the CDS downtime scheduled for 22:30 on Saturday, June 14th.

NCTS will be available during the rollout of the CDS upgrade, but declarations may be queued from the late evening of Saturday, June 14th, and not released until the early hours of Sunday, June 15th.

HMRC have released the following details:

Declarations submitted into the New Computerised Transit System (NCTS) may be queued from 10.30pm on Saturday, June 14th, 2025, to 1.00am on Sunday, June 15th, 2025.
NCTS will be available during this time and any declarations queued will be held and processed once the maintenance activity has concluded.

HMRC recommends that declarations be submitted well in advance of Saturday's downtime to avoid any delay in movements. They apologise for any inconvenience.

Trading with the US: Importing into the US – Some important things to look for

Tue, 10 Jun 2025 13:24:04 GMT

Introduction

With the US's approach to its tariff measures shifting, here are some key pointers for a UK business looking for more clarity on how the US Tariff functions.

The importance of accurate classification.

Accurately classifying goods is an essential requirement for international trade.

Accurate classification on an export declaration identifies to the UK Customs authorities exactly what goods are being exported from the UK, and any possible Customs measures or licences required to make a compliant export.

Accurate classification is essential for imports as it identifies the goods being imported to the authorities and what duties, taxes, or import measures may be required to make a compliant import.

The global harmonised tariff system ensures that the first six digits of the Tariff code are uniform on 98% of internationally traded goods. Additional digits will be local to the importing country and will give further indication of any Customs measures applicable to the goods imported to that country.

Accurate Tariff Classification for goods entering the US is the importer's responsibility. Therefore, if a UK business exports from the UK under a DDP Incoterm® rule, the UK exporter will be responsible for paying accurate duties, taxes, and import charges into the US.

Using a US Agent to import into the US

In the USA, it is not possible to employ a US importing agent under Indirect Representation terms. The US uses a more formal and legal approach.  

The foreign importer taking on the importer of record role must appoint an agent using a Power of Attorney (POA).  The POA signed in the UK will usually include the submission of photo and passport details of the responsible UK person, who must agree to extradition and to paying any US fines levied on non-compliance.  The POA also includes the agent as partly liable for fines/penalties.  

A link to the US legislation on penalties for fraud and negligence is below:

19 USC 1592: Penalties for fraud, gross negligence, and negligence

Accessing the US Tariff and the US Tariff Structure

A link to the US Harmonised Tariff can be found here:

Harmonised Tariff Schedule

The U.S. Tariff Structure has no formal volumes but is organised by content. The content includes the General Rules of Interpretation, WCO agreed rules that direct how to classify goods, information on Free Trade Agreements, appendices that include statistical annotations, the Tariff Schedule itself, and Chapters 98 and 99 as part of the special rules and procedures section, which must be referenced when goods classification has been completed.

The chapters are set out in .pdf format for download, and classification should be harmonised to 6 digits. Therefore, if goods have been accurately classified in the UK, it will generally follow that the chapter headings in the US Tariff will be accurate to the first six digits of the classification code.

Chapters 98 and 99 of the US Tariff contain special classification provisions, temporary legislation, and additional duties that may affect goods imported to the US.

Once the 10-digit Tariff Classification has been identified on the US Tariff, the Tariff code must be checked in Chapters 98 and 99 for any import measures applicable to that Tariff Classification.

Chapter 98 (Special Classification Provisions)

Chapter 98 details duty-free or reduced duty provisions. For example, Chapter 98 is where you will find information on how to manage goods imported for repair, personal exemptions, and goods returned. Measures are presented in columns against the applicable Tariff Classification code for the goods for import, with supporting footnotes. Country codes are presented to support any duty changes applicable to imports from those countries.

Chapter 99 (Temporary Legislation, Additional Duties)

The Tariff measures that have been so volatile recently are presented in Chapter 99.

Chapter 99 details temporary legislation and additional duties that are subject to legislative changes.

If goods are captured in the recent Tariff measures referenced in the Presidential Proclamations or Executive Orders, the exact details of these measures will be located in Chapter 99.

This chapter is essential reading for a UK business investigating how its goods exported from the UK will be addressed on import into the US.

Importing into the US

Import Charges and Tax

Import taxes include Tariffs, Customs duties (indirect taxes), and other fees collected by Customs and Border Protection, such as the Merchandise Processing Fee.

Goods valued under $800 are generally exempt from U.S. import duties, but the application of this measure has fluctuated during the Trump administration.

There is no VAT on imports into the US. Import taxes are levied at the state level on the receiver of the goods as a form of purchase tax and are seen as an integrated cost of the goods.

Merchandise Processing Fee (MPF)

The Merchandise Purchasing Fee is an additional fee for most U.S. imports. The fee is based on the value of the shipment and applies to both personal use imports under the $2,500 value and to business imports over this threshold.

The merchandise processing fee can appear small, but it can escalate for a small business making multiple imports of smaller value.

Importers using Free Trade Agreements may be exempt from paying the MPF.

Details on the MPF for 2025 can be found at the link below:

CBP Adjusting Merchandise Processing Fee Limitations in Fiscal Year 2025 due to Inflation - IMS Worldwide, Inc

Changes in legislation relating to the Merchandise Processing Fee are published in the Federal Register. Link below for reference:

Federal Register: Customs User Fees To Be Adjusted for Inflation in Fiscal Year 2025

Additional Duties Collected by the Customs and Border Protection Agency

The U.S. Customs and Border Protection (CBP) collects several other types of taxes and fees on behalf of other federal agencies. Examples include:

Federal Excise Taxes: These taxes apply to specific goods like alcohol, tobacco, and firearms.

Environmental Taxes : Imports of ozone-depleting chemicals may be subject to environmental taxes, collected by CBP but regulated by the Environmental Protection Agency (EPA).

User Fees : Certain agricultural products may be subject to user fees, which fund inspection and safety processes regulated by the U.S. Department of Agriculture (USDA).

Each of these additional duties is applied on a case-by-case basis, depending on the type of goods for import and any applicable U.S. regulations.

A basic understanding of US charges on imports may help you identify charges that your business may be invoiced for if you use an import agent to move goods across the US border.

US Delivery Terms

Delivery terms in the US have historically been based on the Uniform Commercial Code (UCC), which originated in 1952. The UCC was intended to standardise the varying state laws that govern commercial transactions and incorporate terms that cover domestic deliveries within the US.

For international commercial transactions, Incoterms ® are more appropriate.

A UK business may find that a US company could still refer to US domestic delivery terms in their international contracts, which may easily cause delivery issues and incur unexpected costs if not provisioned for.

US agencies that impact imports into the US

US International Trade Commission

Publishes and maintains the US Harmonised Tariff System

Home | United States International Trade Commission

Customs Border Protection

The CBP has a comprehensive responsibility for US border management and control, combining Customs, immigration, border security, and agricultural protection.

U.S. Customs and Border Protection | U.S. Customs and Border Protection

US Census Bureau

The Census Bureau is responsible for statistics and the maintenance of the US Schedule B classification system.

Census.gov | U.S. Census Bureau Homepage

Schedule B

FDA – US Food and Drug Administration

The Food and Drug Administration is responsible for protecting public health and regulating drug and food safety. It also has some responsibility for emerging public health threats, including those posed by possible terrorist sources, and is responsible for regulating tobacco products.

U.S. Food and Drug Administration

USDA Department of Agriculture

The Department of Agriculture (USDA) oversees food, agriculture, natural resources, and related issues.

U.S. Department of Agriculture (USDA) | USAGov

EPA Environmental Protection Agency

The EPA's mission is to protect human health and the environment by developing and implementing regulations set by Congress.

The EPA are responsible for writing environmental regulations, setting US national standards on environmental issues, and ensuring compliance with these standards.

U.S. Environmental Protection Agency | US EPA

FCC Federal Communications Commission

The Federal Communications Commission (FCC) is an independent U.S. government agency that oversees all interstate and international communications. It maintains standards and consistency among types of media and methods of communication while protecting the interests of consumers and businesses. The FCC allocates cellular and wireless access, regulates media company mergers and acquisitions (M&A), protects intellectual property rights, and regulates standards of content and distribution for all media companies operating in the United States.

The agency is accountable to the U.S. Congress, and investors monitor its actions closely.

Federal Communications Commission | The United States of America

That was the News: May 2025

niamho@strongandherd.co.uk (Niamh O'Connor) — Tue, 03 Jun 2025 14:32:56 GMT

Wave Goodbye to May… and Say Hello at Multimodal 2025!

As we bid farewell to May, we look forward to greeting many of you in person this June at Multimodal 2025 at the NEC Birmingham. We're proud to exhibit again at this leading event for the logistics, supply chain, and freight sectors. We look forward to reconnecting with our valued clients and meeting new ones!

Make sure to visit Stand 1035 from 17th - 19th June, where our experts Sandra, Bernard, Niamh, Andy, and Jawad will offer tailored advice on Customs compliance and international trade. This is an excellent opportunity to streamline your processes and strengthen your compliance framework in the ever-changing landscape of Customs compliance.

Register in advance as a VIP Guest for complimentary access to the VIP Lounge , which includes:

Private meeting areas for confidential discussions
Quiet workspaces, charging points, and free Wi-Fi
Complimentary refreshments
Cloakroom and concierge services
Daily newspapers

We look forward to connecting with you in person at the event - if you have anything in particular you'd like to discuss, please reach out to one of us to book a specific time slot on the stand, and we'll be happy to help.

➡️ Register here as our guest.

For all the latest news & updates, check out our Industry Insights page, and don't forget to follow us on LinkedIn !

Getting it Right at the Border

Any trader moving animal or plant products over the borders into the UK will attest to the difficulties experienced if goods are not presented precisely as required by the cross-border IT systems supporting the UK Import Regulations.

UK and India Sign Trade Deal

The UK Government Department of Business and Trade has issued a press release announcing the signing of a trade agreement between the UK and India.

The Export Control (Amendment) Regulations 2025

On May 2nd, 2025, Notice to Exporters 2025/13 was published confirming the details that we have been expecting since 11th March (NTE 2025/06) regarding updates to the UK Strategic Export Control List, also known as the consolidated list.

NTE 2025/14 Update to Thirteen Open General Licences (OGELs)

NTE The Export Control Joint Unit (ECJU) has published Notice to Exporters 2025/14 advising of updates to 13 open general export licences (OGELs). The licences have been updated to exclude military nuclear power generating and nuclear power propulsion equipment from the scope of the licences.

French Customs releases an English User Guide for the French Smart Border Obligatory Logistics Envelope (ELO)

French Customs has released an English user guide to support UK users of the French Border Obligatory Logistics Envelope (ELO), which was released last month.

CDS Update Version 4.8.0 Scheduled for Release on June 14th 2025

The upcoming CDS update, version 4.8.0, is scheduled for release on 14th June 2025. During this period, please note that any pre-lodged declarations that will be affected by the changes should be changed/amended prior to the goods arriving. If Customs declarations are not corrected prior to arrival, they will be rejected.

NTE 2025/15 Export Control Update

On Friday, 16th May 2025, the ECJU (Export Control Joint Unit) communicated via Notice to Exporters 2025/15 that the process for applying for an F680 (MOD Security Approval Form 680) will be transferred from SPIRE to the replacement portal. The new licensing system was previously named LITE, Licensing for International Trade and Enterprise, but the Notice advises that “apply to export controlled goods” is the new name.

Next Chapter for UK – EU Relations

Announced at the Leaders’ Summit in London on 19 May 2025, the EU and the United Kingdom reached an agreement to promote prosperity on both sides. Is this a much-needed reset following the initial EU Exit agreement?

Managing VAT at the Border if the Goods do not Belong to the Importing Business

Before the UK left the EU, the VAT payable on goods moving between the UK and EU member states was managed through comprehensive EU VAT Directive (Council Directive 2006/112/EC) measures.

HMRC has started to Publish New Customs Technical Handbooks (CTHs) on GOV.UK

This is not an exhaustive list of Customs Technical Handbooks, and HMRC says that it is subject to change. Other topics are also being considered, but they are still in the scoping phase, and other handbooks may be developed in the future as required.

Reclaiming a Security Deposit Relating to Proof of Origin

HMRC has advised that it is now possible to reclaim a security deposit or guarantee paid on import where evidence of the goods' origin was not available at the time the goods were imported.

Government Prepares to Scale Compliance Audit Efforts

There is a hint of a warning that UK businesses should think about possible Customs compliance audits sooner rather than later, as the government strongly suggests that it’s time to ramp up audits to collect outstanding debt.

Important information about Transit fallback procedures and updates to the Goods Vehicle Movement Service (GVMS).

niamho@strongandherd.co.uk (Niamh O'Connor) — Tue, 03 Jun 2025 10:27:09 GMT

HMRC have confirmed that the GVMS service will be updated on 3 June 2025 to allow for reference to the Transit Manual Fallback procedures to be used during any NCTS5 system downtime and Business Continuity procedures.

Previously, the SAD/C88 process could be used during a system outage; however, this process was withdrawn in January of this year. Users have been waiting for an update on a procedure to follow should the Transit system be unavailable for GVMS users.

The update will provide further information about the Business Continuity Process for NCTS5, where transit movements are made through GVMS locations in Great Britain and Northern Ireland. It will be particularly relevant to users of NCTS5 and GVMS (traders, agents, declarants, hauliers) and providers of third-party commercial software packages.

NCTS 6 is due for release later this year

A link to the Transit Manual Supplement containing the BSP can be found here:

Transit Manual Supplement - 7. The Business Continuity Procedure - Guidance - GOV.UK

Details on the creation of a GMR during a Business Continuity period can be found below:

Create a goods movement reference - GOV.UK

Magnified Mistakes: How Minor Preference Errors Are Costing Importers

SandraS@strongandherd.co.uk (Sandra Strong) — Mon, 02 Jun 2025 13:38:15 GMT

It’s a tale as old as Free Trade Agreements - you’re importing goods under preference, your supplier gives you an invoice statement, everyone’s happy – until HMRC comes knocking. Recently, an importer found itself facing a duty bill, despite having claimed preference. Why? Because the preference statement wasn’t exactly correct. Not wildly off, just... not replicated word for word in line with the FTA, which was mainly the UK-EU Trade Cooperation Agreement (TCA).

Now, at Strong & Herd LLP, we’ve said it time and again – and we’ll keep saying it until it’s printed on mugs and mouse mats: the preference statement must be used word for word. No freestyling. No “close enough.” It’s not karaoke – you don’t get points for improvisation. And suppose you’re the importer claiming preference. In that case, you are responsible for verifying that the statement is accurate and complete (even if it isn’t printed in English), and that the REX number or other exporter approval number is valid.

In this case, HMRC took issue with more than just the wording and zoomed in on two particular points:

The REX number was wrong – instead of just “IEREX” for Ireland, for example, the statement read “IE! Only. A small typo? Sure. But in the eyes of HMRC, it is enough to void the claim.
The statement of origin doesn’t correspond to the trade agreement being used – the statement said, “German preferential origin” instead of the required “EU preferential origin.” Again, not a massive leap, but still incorrect according to the FTA.

The rules are the rules. But let’s be honest – it probably seems harsh and pedantic to a lot of UK businesses. When you’re trying to do things right and get tripped up by a missing word or a rogue country name, it feels like being penalised for spelling mistakes on a driving test. So, what can we learn from this?

Double-check the preference statement. It must match the wording in the agreement exactly. Word. For. Word.

Check the REX or approved exporter number. Is it valid? Is it formatted correctly? “IEREX” might sound like an airline, but it won’t fly with Customs.

The preference origin must confirm EU preference, not just the specific member state. Even if you know it originated from Germany, if the statement doesn’t specify “EU,” it’s incorrect and should not be used to claim preferential treatment. And one more thing: keep your documentation ready and available at the time of import. This proactive approach can prevent potential issues.

This case serves as a sharp reminder that when it comes to preference claims, the devil is truly in the details. And HMRC, with their meticulous scrutiny, have the magnifying glasses.

Government Prepares to Scale Compliance Audit Efforts

Fri, 30 May 2025 08:41:52 GMT

There is a hint of a warning that UK businesses should think about possible customs compliance audits sooner rather than later, as the government strongly suggests that it’s time to ramp up audits to collect outstanding debt.

The recruitment of 5000 Customs compliance staff was announced in the Autumn Budget 2024, with a further 500 announced in the March Spring Budget. This clearly indicates a trend towards customs audits being likely very soon, and customs officers arriving to audit give little prior warning.

After leaving the EU, many UK businesses that traded with EU Member States only struggled with unfamiliar customs import processes, particularly in relation to the management of import VAT. Goods classification, valuation, and origin were unfamiliar terms, with many UK importing businesses leaving the declaration of all three to their forwarder, agent, or fast parcel operator.

EU Exit is five years past; any slack cut for UK importers has been slowly tightened. There is no excuse for an importing business not understanding the regulations governing UK cross-border trade in working practice. Compliance records for imports from any 3rd country, not just the EU, must support international trade.

Customs will focus on import records, as duties and taxes are levied at import. The Spring Statement indicates that the government is looking to recoup debt. It is a very clear message.

Adhering to best practices, such as maintaining up-to-date customs compliance records and conducting regular checks, is essential. Equally important is investing in staff training, as it ensures your team is equipped to handle any compliance issues that may arise. Remember, customs prefer efficiency, and so does a competent team.

It is so very easy to fall foul of a government audit. It would be better to be safe than sorry and have the compliance records up to date and accurate in the first place.

If things aren’t looking good, a pre-audit will help determine customs debt risk exposure and assist in preparing and implementing a compliance ‘get-well’ plan before the HMRC officer arrives. Non-compliance is never good, but being non-compliant, aware of it, and working on it is a far better situation.

Spring Statement 2025 - GOV.UK

Reclaiming a Security Deposit Relating to Proof of Origin

Wed, 28 May 2025 09:52:04 GMT

HMRC has advised that it is now possible to reclaim a security deposit or guarantee paid on import where evidence of the goods' origin was not available at the time the goods were imported.

This online service requires a CDS subscription to reclaim a deposit or guarantee made against missing evidence of the origin of goods.

This new service adds to those already in place for temporary admission, inward processing relief, and authorised use (Great Britain) or end use (Northern Ireland) relief.

This service is available to importers, customs agents, freight forwarders, or express operators acting on behalf of importers. It is not open to private individuals or parties other than businesses or companies.

Once the request for a reclaim has been submitted, the claim will be visible on the CDS claims dashboard.

The guidance pages updated on 21 ^st May can be found at the link below:

Claim back an import security deposit or guarantee - GOV.UK

Further information

HMRC is keen to receive user feedback on claiming security deposits, overpayments (C285), or rejected imports (C&E1179) and has supplied an email address for this purpose.

Feedback or views should be addressed to HMRC at the following email address:

sruthi.james@digital.hmrc.gov.uk

HMRC has started to Publish New Customs Technical Handbooks (CTHs) on GOV.UK

Tue, 27 May 2025 13:12:51 GMT

This is not an exhaustive list of Customs Technical Handbooks, and HMRC says that it is subject to change. Other topics are also being considered, but they are still in the scoping phase, and other handbooks may be developed in the future as required.

S&H is publishing the catalogue of Customs Technical Handbooks here, and we will add to it as and when new Handbooks become available.

Where a Handbook has been published, we will include the publication date and a link to the relevant page on GOV.UK.

A Spotlight On: Changing US contract delivery terms from DDP to DAP

Fri, 23 May 2025 14:12:23 GMT

Overseas customers often require an export supplier to deliver under the DDP (Delivered Duty Paid) Incoterms® rule, arguably the most difficult term to use for an export delivery, as all import formalities and charges are the responsibility of the delivering party.

Many UK suppliers who had previously delivered from the UK before the EU Exit found themselves working with unfamiliar delivery terms as they navigated new territory, supplying into the EU as a UK exporter.

Import VAT has become a new challenge, as it is non-recoverable for a UK supplier delivering DDP into the EU without having EU VAT fiscal arrangements in place to support import VAT reporting and payment.

Delivering DDP into the US has its challenges, especially with the new US import tariffs being as volatile and unpredictable as they are.

With contract delivery dates to be met and goods ready for export, UK exporters with DDP delivery terms are seeking ways to manage variable DDP costs, as these costs can be unclear at the time the goods leave the UK.

Some UK suppliers have amended the Incoterm® rule from DDP in their export paperwork, leaving it for the US customer to sort out on import. This is not a recommended practice if the underlying commercial contract has not also been amended.

If the US importer isn’t paying close attention to how their import is being managed by their agent, it may be a while before their increased costs are noted. A little like the UK exporter lighting the blue touchpaper and standing well back.

Some UK exporters may prefer a more measured approach to the change in the Incoterms® rule from DDP, as this change could significantly impact their US customers.

Changing an Incoterm® from DDP, where the onus for import formalities and charges is on the UK exporter, to a DAP term, will shift the obligation for import formalities and costs onto the US customer making the import.

Force Majeure

If the export contract has a ‘force majeure’ contract clause, the salient point will be to check the definition of that clause within the contract terms.

Traditionally, force majeure clauses are defined as acts of God, adverse weather conditions (which affect delivery), and wars.

These conditions have evolved over time and now often include other specific events, such as acts of terrorism, changes in government policies, or a government's approach to border or export controls.

Steps to Consider

Checking the contract terms and conditions.

Purchase Order acceptance conditions may allow for a change in Incoterm® rule or refer to an overarching contract with a force majeure clause.

If a force majeure clause is present, the definition of the force majeure clause will be within the contract term. After that, it is a case of determining whether force majeure can be used to trigger a renegotiation of the delivery Incoterm® away from DDP, to a Delivery at Place term that is favourable to the UK exporter.

Note: The Executive Orders published by the White House rely largely on regulations that refer to U.S. national Security. This fact may strengthen the argument regarding whether a clause conditional on a change in US trade policy applies.

Negotiating a New Sales Contract

When negotiating a sales contract that involves deliveries to the US, it is essential to include trade control measures in your contract checklist.

A key factor to address will include the origin of goods.

U.S. tariff measures are heavily determined by the country of origin, making accurate origin data critical for customs compliance and cost control.

Import declarations require verified origin information, and errors can result in delays, penalties, or unexpected duty costs.

To mitigate these risks, ensure that the export paperwork includes precise and validated origin details, particularly for goods affected by the evolving US trade measures.

In short, don’t leave the goods' origin as an afterthought. Build this into your contract requirements from the start to protect your supply chain and ensure smooth customs clearance.

Contract terms should be consistent with any related purchase order terms.

The devil will be in the details.

Managing VAT at the Border if the Goods do not Belong to the Importing Business

Fri, 23 May 2025 11:26:18 GMT

Before the UK left the EU, the VAT payable on goods moving between the UK and EU member states was managed through comprehensive EU VAT Directive (Council Directive 2006/112/EC) measures.

After leaving the EU, VAT management became an import consideration for traders exporting to EU member states, with VAT being due on import into the EU.

Accounting for VAT on Imports into the UK

UK import VAT is payable on import unless the business uses a VAT easement.

Available options for declaration are Postponed VAT Accounting (PVA), where VAT is accounted for in the business records, or payable via a Deferment, where the business holds a Deferment account and the VAT is paid against that account and reclaimed from HMRC later.

Importers may also consider other payment options, such as a CDS Cash account or Immediate payment. In these instances, a C79 certificate will be produced along with payment via a deferment account.

Importing goods for repair and re-export: Point of Order

Importing for repair and re-export

When goods are imported for repair, a Customs Special Procedure, such as IP (Inward Processing), must be applied.

PVA, VAT deferment, or any other payment method cannot be used to import goods for repair and re-export. VAT is not reclaimable for goods not owned by the importing business.

Inward processing is the method of VAT management that traders should use to avoid an outlay of unreclaimable VAT. Misusing PVA or VAT deferment measures will result in a VAT audit failure and penalties.

Importing zero-duty goods for repair

Where goods for import are zero duty, VAT is still payable and must be accounted for.

HMRC will require the full payment of VAT for goods imported for repair, even if the subsequent re-export is recorded.

VAT Audits are ramping up

The recruitment of 5000 Customs compliance staff was announced in the Autumn Budget 2024, with a further 500 announced in the March 2025 Spring Budget.

The UK Government is investing in HMRC’s debt management capacity to collect unpaid tax debt. VAT will fall into this category.

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

Next Chapter for UK – EU Relations

Wed, 21 May 2025 12:02:33 GMT

Announced at the Leaders’ Summit in London on 19 May 2025, the EU and the United Kingdom reached an agreement to promote prosperity on both sides. Is this a much-needed reset following the initial EU Exit agreement?

This new agreement consists of several economic areas, including:

The negotiation of a new sanitary & phytosanitary (SPS) agreement
Energy & Climate change
Security and Defence.

SPS Agreement

The new sanitary and phytosanitary agreement is a beacon of hope, aiming to significantly reduce the administrative burden currently experienced by exporters and importers on both sides. The goal is to facilitate the movement of animal and plant products without the need for SPS checks.

Following the initial uncertainty of Brexit, this area of SPS goods has caused businesses a significant amount of extra administrative work, with additional SPS checks now required for both exports and imports. The removal of these checks for goods moving into and out of the UK to and from the EU will significantly reduce the administrative burden on businesses, potentially leading to smoother trade operations.

Energy & Climate Change

The announcement of the retrospective Emissions Trading Schemes being linked is a significant step towards improved security for the energy sector. This will be particularly welcome news to UK businesses grappling with the EU CBAM, which comes into full effect in January 2026. The cooperation means not only improved security but also relieves the burden of the EU's Carbon Border Adjustment Mechanism (CBAM) on UK exporters, and subsequently, when it is implemented, the UK's CBAM on EU Exporters.

Security & Defence

A new Security and Defence Partnership was also announced, which will enable the defence industry to participate in the EU’s proposed new £150 billion Security Action for Europe (SAFE) defence fund. The UK, despite its exit from the EU, will be permitted to join in common procurements alongside Member States, ensuring interoperability with allies and contributing to cost reductions, thereby demonstrating the UK's commitment to European security.

At a time of increasing global uncertainty and volatility, this will formalise UK-EU co-operation on defence to ensure Europe’s safety and security.

Further details on how the agreement will work on a practical level are yet to be announced. Still, with the announcement that bilateral summits will be held annually at the Leaders' level, and the EU High Representative, as well as the UK Foreign and Defence Secretaries, meeting every six months, this is a much more pragmatic and fluid approach than has been sought previously.

https://www.gov.uk/government/news/pm-secures-new-agreement-with-eu-to-benefit-british-people?utm_medium=email&utm_campaign=govuk-notifications-topic&utm_source=a6d00dda-138b-4403-af12-ce7ff1aaa38e&utm_content=immediately

https://ec.europa.eu/commission/presscorner/detail/en/ac_25_1280

NTE 2025/15 Export Control Update

Mon, 19 May 2025 12:31:51 GMT

On Friday, 16th May 2025, the ECJU (Export Control Joint Unit) communicated via Notice to Exporters 2025/15 that the process for applying for an F680 (MOD Security Approval Form 680) will be transferred from SPIRE to the replacement portal. The new licensing system was previously named LITE, Licensing for International Trade and Enterprise, but the Notice advises that “apply to export controlled goods” is the new name.

F680 applications will be the second service available on the new portal, which was launched as a “Public BETA” in September 2024 to enable users to apply for a SIEL (Standard Individual Export Licence), with some exceptions, meaning an application on SPIRE was still needed.

Signing onto the new portal, the Account Screen reads that the “Apply” sections cover a SIEL and an F680, although the latter option is not yet live.

If users do not already have an account on “apply to export controlled goods”, the first step is to register at GOV.A UK. One login will be required, along with the ability to access a Security Code via Mobile Phone or an Authenticator App.

The ECJU’s intention is to transition all applications away from SPIRE in the coming weeks, Updates will be provided on Notice to Exporters .

The F680 Security Approval is not an Export Licence. Still, it is an integral compliance document that allows the sharing of equipment or information classified with a security rating of Official-Sensitive or above with non-UK entities. The classification process means that the Ministry of Defence has classified the information or equipment to confirm that a security classification is applicable.

On GOV.UK, there is a link to the F680 Policy and Guidance information, which confirms that approval is also required for some material classified OFFICIAL, but only where the information or equipment connected with the release holds a higher classification. If both the equipment and information are classified OFFICIAL, a Form 680 is not required.

The requirement to check and obtain an F680 is a feature of Military Open General Export Licences, as outlined in the Terms and Conditions. If required, based on the security classification, the F680 must be obtained prior to using the OGEL and be available for inspection during an ECJU audit to demonstrate compliance. To use an OGEL, there is a one-time registration; however, every time the licence is subsequently used, the exporter, as the licensee, must be aware of the associated responsibilities. UK Military Export Licences that permit the tangible export of goods typically require “Open Licence Returns”, which declare the number of licence uses for the calendar year, based on destination and type of end-user.

Compliance and the additional requirements relevant to the Security Classification are another specific example of the licensee’s responsibilities to demonstrate that they are using the OGEL correctly. For an exporter, the ECJU’s expectations and their preparation in readiness for a Compliance Visit are vital. It is recommended to conduct internal audits on a regular basis, rather than waiting for the ECJU Visit. By undertaking regular checks, the official audit can potentially feel less onerous, as the ongoing checks are an integral part of the process. From a compliance perspective, a significant amount of activity is undertaken after the collection of goods from the exporter’s premises, including verifying the customs declaration and obtaining proof of export. We recommend subscribing to HMRC Data for Imports and Exports to check that there are no discrepancies.

In terms of OGEL compliance, the registration process for using the licence could have been completed by the exporter recently or a few years ago. The year after the “GBOGE” Prefix will confirm when the registration took place.

The best advice for an exporter is to be aware of the specific Terms and Conditions to use the licence(s) that the business is registered for. Never lose sight of the responsibilities to use an OGEL. Each use means the exporter is agreeing to the Terms and Conditions.

It is important to be aware that OGELs can be updated, so any changes to the licence should be reviewed to ensure it is still valid for the exporter’s requirements. By using the OGEL, the exporter is agreeing to use the latest version. To demonstrate compliance at audit the best practice approach is to retain any updated versions of OGELs on file.

The one-time registration is a relatively simple process on SPIRE (for the time being) but on going OGEL compliance is imperative.

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

Upcoming Events & Training Courses this June

Fri, 16 May 2025 11:02:57 GMT

Join us in June for comprehensive training courses on Customs compliance and international trade.

Our June sessions are tailored to suit your schedule, offering full-day courses and focused, shorter clinics. Whether you're looking to master the basics of import/export or delve into more advanced Customs regulations, we have a wide range of courses to suit your needs.

See below for further details of June courses.

Last Minute Availability

Focus on Food: Tariff Classification

19th May 2025

International Trade Compliance Manager -F2F

This course caters for both manufacturers , exporters and Importers who are currently looking to classify food products. Covering aspects of classifying food related products this course offers an in depth and practical approach to what this will mean for your business to have a better understanding of classify food items.

20th May 2025

Focus On: Controlling Technology & Intangible Transfers

This course is designed for professionals responsible for managing or overseeing international trade and customs compliance within their organisations. It is ideal for those looking to strengthen their understanding of global trade regulations, streamline operations, and reduce compliance risks.

20th May 2025

Focus on Food: Export Procedures

This session covers the export licensing regulations for intangible transmissions of controlled items, including technology, software, and goods. It reviews the types of licences available and their usage and maintains a technology log for audits. Additionally, it addresses the use of technology by employees working overseas.

22nd May 2025

https://www.gov.uk/guidance/goods-vehicle-movement-service-service-availability-and-issues

This course is designed for manufacturers, exporters, and freight forwarders involved in exporting food products, including plant and composite goods. It provides a practical, in-depth understanding of the requirements for exporting these products, making your business export-ready. Topics include the latest rules and regulations for exporting to the EU and other global markets, and the necessary compliance with customs and regulatory bodies.

Clinics

Courses

CDS Update Version 4.8.0 Scheduled for Release on June 14th 2025

Thu, 15 May 2025 12:23:51 GMT

The upcoming CDS update, version 4.8.0, is scheduled for release on 14 ^th June 2025. During this period, please note that any pre-lodged declarations that will be affected by the changes should be changed/amended prior to the goods arriving. If customs declarations are not corrected prior to arrival, they will be rejected.

Changes for both Imports and Exports

Zimbabwe Currency Code

Currency Code ‘ZWG’ has been added for use when trading with Zimbabwe. This code replaces all previous currency codes for Zimbabwe.

The workaround that was in place to manually calculate the goods value in ‘GBP’ has now been withdrawn and should not be followed.

Commodity Code

When entering a commodity code in DEs 6/14 and 6/15, only numeric characters should be entered.

Entering any non-numeric character in DEs 6/14 or 6/15 will result in the declaration being rejected.

This change does not affect Additional Codes entered in DEs 6/16 or 6/17

Authorisation Document Codes

When declaring certain Authorisation Document Codes, Document Status Code ‘XW’ is no longer available for use. The affected Authorisations and their associated Document Codes are:

Inward Processing – ‘C601’
Outward Processing – ‘C019’
Temporary Admissions – ‘C516’

If Document Status Code ‘XW’ is used with any of these Document Codes, the declaration will be rejected.

If goods are moved under these Special Procedures using Authorisation by Customs Declaration, the relevant guidance under the applicable Procedure Code in the Declaration Completion Instructions should be followed.

D-series Document Codes

Document Status Code ‘XB’ cannot be declared with the following Document Codes: ‘D005’, ‘D008’, ‘D017’, ‘D020’, ‘D022’.

If any of these document codes are declared in DE 2/3 with a Document Status Code of ‘XB’ then the declaration will be rejected.

Previous Document Code DCS

When declaring Previous Document Code ‘DCS’ in DE 2/1, the Goods Item identifier must be declared as part of the document reference.

This Goods Item identifier must reference the items position on the document being declared in DE 2/1, rather than the item identifiers from the current declaration.

Failure to declare a Goods Item identifier when using Previous Document Code ‘DCS’ in DE 2/1 will result in the declaration being rejected.

New Document Codes

New Document Codes have been added to the CDS Codelist: ‘C083’, ‘Y119’, ‘U078’, ‘U088’, ‘U101’, ‘U113’, ‘U114’, ‘U115’, ‘U116’, ‘U117’, ‘U118’, ‘U119’, ‘U120’, ‘U121’, ‘U122’, ‘U177’, ‘U178’, ‘U500’.

AI Code SDSMI

Additional Information Code ‘SDSMI’ can be declared in DE 2/3 for both imports and exports.

This code is only to be used when instructed.

Changes to Document Codes

Document Codes Y071, Y080 & Y229 will cease to be used in the UK tariff measures after 31st May 2025.

Y071 will be replaced by 9071.
Y080 will be amalgamated under existing code 9022.
Document Code Y229 will be replaced by 9229 in the UK import tariff measures. Document Code Y229 will continue to be used in the Northern Ireland export tariff measures.

Document Codes Y071, Y080 & Y229 will continue to be valid for use against the UK tariff measures on Supplementary Declarations with an acceptance date prior to 1st June 2025.

Statistical Value

The Declaration Completion Instructions will be amended to stop making declaration of DE 8/6 Statistical Value dependent on whether there is a sales contract or not for consignments involving Inward Processing or Outward Processing.

This means that DE 8/6 will become mandatory on the H1, H2, H3, H4, H5, I1 B&E & B2 data sets. DE 8/6 will also be mandatory on B1, B1MOU and B4 declarations unless all goods on the declaration are covered by Additional Procedure Code 3NS.

This change is initially being implemented by guidance updates, but system changes will be implemented later this year which will reject declarations if a Statistical Value is not declared when necessary.

I1 C&F Controlled Goods

When making a Simplified Declaration with Regular Use (I1 C&F Declaration Category), the Net Mass must be completed in DE 6/1 when one of the following APCs has been declared: 1CD, 1CG, 2CD, 2CG

Failure to declare the Net Mass on an I1 C&F declaration when one of those APCs has been declared will result in the declaration being rejected.

Amendments to existing Document Codes

The system behaviour for the following Document Codes has been amended:

Document Code Y870 can only be used on Import declarations.
Document Code Y229 can be used on both Import and Export declarations

Goods location codes

The addresses of some GLCs have been amended. Full details will be published in Appendix 16. You can find appendix 16 at the bottom of the guidance.

IMPORT DECLARATION UPDATE:

Requested Procedure Code 40- Further validation has been introduced for Requested Procedure Code ‘40’ on type ‘Y’ or ‘Z’ import declarations:

Previous Procedures ’00’ or ‘78’ are usable with type ‘Y’ declarations (Procedure Code combinations ‘4000’ and ‘4078’)
Previous Procedures '00', '51', '53', '71' or '78' are usable with type ‘Z’ declarations (‘4000’, ‘4051’, ‘4053’, ‘4071’, and ‘4078’)

Any other Previous Procedure Code combined with Requested Procedure Code ‘40’ on a type ‘Y’ or ‘Z’ will be rejected

Requested Procedure Code 42

Further validation has been introduced for Requested Procedure Code ‘42’ on a type ‘Y’ declaration.

Requested Procedure Code ‘42’ can only be declared with Previous Procedure Code ‘00’, ‘21’, or ‘78’ (Procedure Codes ‘4200’, ‘4221’, or ‘4278’) on a type ‘Y’ declaration.

Any other Previous Procedure Code combined with Requested Procedure Code ‘42’ will be rejected

Item Price

When making a declaration using the H1 Declaration Category, DE 4/14 must be completed at item level in all cases, unless one of the following APCs is declared in DE 1/11 on that goods item: ‘E01’, ‘E02’, ‘1SV’

If DE 4/14 is not completed on a H1 declaration, and none of ‘E01’, ‘E02’, or ‘1SV’ have been declared in DE 1/11, the declaration will be rejected.

Small Producer Relief

Further validation has been introduced for claims to Small Producer Relief (SPR).

CDS will now only accept a single value for SPR.

If 2 or more ‘SPR’ codes are entered in DE 4/4 on the same goods item, the declaration will be rejected.

APCs 62G and 63G

When making a C21i CCR under SPIMM only one of APCs ‘62G’ and ‘63G’ may be declared in DE 1/11 for a single Goods Item.

If both of these APCs are declared on the same Goods Item, the CCR will be rejected

Supervising office with SPIMM declarations

When a Supervising Office is required by a Procedure Code (PC) or APC on a SPIMM declaration, Supervising Office ‘GBBEL004’ must be declared in DE 5/27.

Supervising Office ‘GBBEL004’ must be used when the following items are declared:

Requested Procedure Code ‘07’ has been declared in DE 1/10 with either of APCs ‘1EL’ or ‘1EN’ declared in DE 1/11
One of Previous Procedure Codes ‘07’, ‘51’, ‘71’, or ‘78’ has been declared in DE 1/10 and one of APCs ‘1SG’, ‘1EL’, ‘1LG’, or ‘71G’ has been declared in DE 1/11

Failure to declare Supervising Office Code ‘GBBEL004’ when the above code combinations are declared will result in the declaration being rejected.

Procedure Code 7851

APCs ‘A10’ and ‘F46’ are now able to be declared with Procedure Code 7851.

Please see the Declaration Completion Instructions for Imports for guidance on using these APCs.

Licence Document Codes

A DUCR is no longer mandated in DE 2/1 by use of the following documents codes in DE 2/3: ‘9005’, ‘9100’, ‘9101’, ‘9102’, ‘I004’, ‘L001’ and ‘L079’.

A DUCR may still be mandated for other purposes.

Chicago Convention

A new APC, ‘1CC’, has been introduced for goods being imported under the Chicago Convention.

This APC can only be used with Procedure Code ‘4000’ on a full declaration.

Simplified Procedures and EIDR cannot be used with APC ‘1CC

NI imports

When importing goods using AI Codes ‘NIDOM’, or NIIMP’ to indicate the goods are being moved into Northern Ireland, a valid NI Goods Location Code (GLC) must be declared in DE 5/23.

If a GB GLC is declared in DE 5/23 and either of ‘NIDOM’ or ‘NIIMP’ are declared in DE 2/2, then the declaration or CCR will be rejected.

Valid NI GLCs are indicated in Appendix 16. This change does not impact on the use of an authorisation for the Location of Goods code in DE 5/23. For example, when removing goods from a Customs Warehouse in Northern Ireland.

SPIMM-Specific Code Combinations

Validation of the Procedure Code and Declaration Type combinations allowed on SPIMM declarations:

Procedure Codes 0751 and 0771 can only be declared with declaration type A on a H8 declaration.

Procedure Codes 4051 and 4071 can only be declared with declaration types A and Z on a H8 declaration.

When using declaration categories H8, I1 C&F, C21i, and C21i EIDR NOP, and one of the APCs 1EL, 1EN, 1LG, 1SG, 61G, 62G, 63G, or 71G, then one of the following Document Codes must also be declared: 'N703', 'N704', 'N705', 'N710', 'N714', 'N720', 'N722', 'N730', 'N740', 'N741', 'N750', 'N760', 'N785', 'N787', 'N820', 'N821' or 'N933'.

When APC 1SP is declared in DE 1/11 and Previous Procedure Codes ‘51’, ‘71’, or ‘78’ is used, then one of the following APCs must also be declared: 1EL, 1EN, 1LG, or 1SG

Postponed VAT Accounting

When making a declaration using Postponed VAT Accounting (PVA), the VAT Number declared in DE 3/40 must belong to a trader registered for VAT at the taxpoint date of the declaration. DE 3/40 should be completed using:

role code ‘FR1’
the valid VAT Number of the Party responsible for payment of VAT

Onward Supply Relief

When making a declaration for goods claiming Onward Supply Relief (OSR), a valid VAT number must be declared in DE 3/40.

For Role Codes FR1 and FR3, the VAT number must be a valid GB or XI VAT number
For Role Code FR2, the VAT number must belong to the customer receiving the goods in the EU Member State of destination

Full guidance for these role codes can be found in the Import Declaration Completion Instructions for DE 3/40.

If a PC from the 42-series has been declared in DE 1/10 and the VAT number in DE 3/40 is not valid, the declaration will be rejected.

Composite Goods containing mineral oil

AI Code ‘COMNE’ has been added to the CDS Codelist for use when declaring commodity codes for composite goods containing mineral oil that are not subject to excise duty.

AI Code ‘COMNE’ can be declared in DE 2/2 when one of the following National Additional Codes are declared in DE 6/17: ‘X520’, ‘X521’, ‘X522’, ‘X541’, ‘X542’, ‘X551’, ‘X556’, ‘X561’, ‘X570’, ‘X571’, ‘X572’ and ‘X589’

The commodity codes that AI Code ‘COMNE’ can be declared against are:

3811119000
3811190010
3811190090
3811210010
3811210090
3811900040
3811900050
3811900090
3814009020
3814009040
3814009070
3814009099
3817005010
3817005090
3817008090

If the goods are declared using one of those commodity codes and AI Code ‘COMNE’ is declared in DE 2/2, no excise duty will be charged on the Goods Item.

If the goods are subject to excise duty, AI Code ‘COMNE’ must not be declared in DE 2/2, and the excise duty must be accounted for.

EIDR Authorisation Validation – INVENTORY IMPORTS

When declaring Document Code C514 in DE 2/3 to indicate an Entry in Declarant Records (EIDR) authorisation has been used Authorisation Type Code ‘EIR’ must be used in the Document Reference, followed by a valid EIDR authorisation number. Authorisation Type Code ‘EIR’ must also be declared in DE 3/39 with the EORI number of the Authorisation Holder.

If an incorrect Authorisation Type Code is declared against Document Code C514 in DE 2/3, the authorisation number in DE 2/3 is not valid, or the authorisation holder in DE 3/39 is not valid, the declaration or CCR will be rejected.

Authorization code ACT

When making a C21i or C21i EIDR NOP Customs Clearance request (CCR) and Authorisation Type Code ‘ACT’ (authorised consignee for TIR Carnets) is declared in DE 3/39, DE 2/2 must also be completed with Document Code ‘C520’ and a valid ACT authorisation number.

Failure to declare Document Code ‘C520’ with Authorisation Type Code ‘ACT’ will result in the CCR being rejected.

EXPORT DECLARATION UPDATE

Customs Supervised Exports (CSE)

When making a declaration using the CSE process, the declaration type declared in DE 1/2 must be one of ‘A’, ‘B’, ‘C’, ‘J’, ‘Y’ or ‘Z’, and APC ‘1CS’ must be declared in DE 1/11.

If Authorisation Type Code ‘CSE’ is declared in DE 3/39 and DE 1/2 contains a declaration type that is not one of ‘A’, ‘B’, ‘C’, ‘J’, ‘Y’ or ‘Z’, or APC ‘1CS’ is not present in DE 1/11, the declaration will be rejected.

Document Code 90W8

Document Code ‘90W8’ has been added to the CDS Codelist. This Document Code should be used to declare Form W8 (or other suitable alternative commercial documentation) for the movement of goods that qualify for an exemption from the use of Excise Movement Control System (EMCS).

If the goods do not qualify for an EMCS exemption, one of Document Codes ‘C651’ or ‘C658’ must be declared instead, or the goods must be covered by a CSE authorisation.

When declaring Document Code ‘90W8’ in DE 2/3, a Document ID is mandatory

GVMS arrived-export locations

When completing a GVMS movement through a GVMS location that only allows arrived exports, the declaration type declared in DE 1/2 must be one of ‘A’, ‘B’, ‘C’, or ‘J’.

The arrived export-only Goods Locations and their associated GLCs are:

Dover/Eurotunnel - DEUDEUDEUGVM
Dover - DVRDOVDVRGVM
Eurotunnel - EUTEUTEUTGVM
Fishguard - FISFISFISGVM
Heysham - HYMHEYHYMGVM
Holyhead - HLYHLDHLYGVM
Liverpool - LIVLIVLIVGVM
Pembroke - PEDMILPEDGVM

If a declaration is made at one of these GLCs where the declaration type in DE 1/2 is one of ‘D’, ‘E’, ‘F’, or ‘K’, the declaration will be rejected.

This does not affect Supplementary Declarations where the original Simplified Declaration was made through one of these GLCs.

Additional Procedure Code 18I (Indirect Exports) -INVENTORY EXPORTS

APC 18I (Indirect Exports) can only be used on prelodged Customs Clearance Requests (type K).

If APC 18I is declared in DE 1/11 on an arrived CCR, the CCR will be rejected

Additional Procedure Code 42P – INVENTORY EXPORTS

When making a declaration using APC 42P in DE 1/11 AI Code PAL02 must not be declared in DE 2/2.

If AI Code PAL02 is declared in DE 2/2 and 42P is declared in DE 1/11, the declaration will be rejected.

Further guidance to the new codes can be found within :

Appendix 4 – Additional Information Statement Codes: https://www.gov.uk/guidance/additional-information-ai-statement-codes-for-data-element-22-of-the-customs-declaration-service-cds

Appendix 5 – Documents and Other Reference Codes: https://www.gov.uk/government/collections/data-element-23-documents-and-other-reference-codes-of-the-customs-declaration-service-cds

Appendix 16 – Goods Location Codes: https://www.gov.uk/government/collections/goods-location-codes-for-data-element-523-of-the-customs-declaration-service

List of fixes being implemented within 4.8.0

CDS was unable to retrieve some declarations where declaration type ‘CO’ had been declared in DE 1/1.

CDS will now retrieve declarations correctly, regardless of the value declared in DE 1/1.

When trying use a CDS-related GOV.UK service, such as registering for an EORI number, using an Isle of Man (IoM) VAT number beginning with ‘GB00’, an error is generated.

IoM VAT numbers beginning with ‘GB00’ can now be used to access CDS-related services on GOV.UK.

When viewing the declaration online, all Data Elements are viewable, but when the declaration is printed, DE 4/9 is not visible.

All DEs are now visible when a declaration is printed from the online service.

Mismatches in the licence quantity type between different CDS components causing delays in licence processing.

CDS will now correctly process error messages when licence quantity type mismatches occur, reducing processing delays.

Declarations were getting stuck on CDS when a container number was declared.

The issue was being caused by a missing sequence Numeric tag in the XML. This is now mandated when a container number is declared.

Declarations were being delayed because licences that contained special characters in data fields were being rejected when loaded into CDS.

Special characters now verified when licence details are loaded into CDS so they can be matched when licences are declared by traders.

There have been problems verifying RPA licences when loaded into CDS.

RPA licences will be correctly verified when loaded into CDS so they can be declared correctly by traders.

When a trader made more than 5000 transactions with their Cash Account in a monthly period, the Cash account dashboard was not able to display any transactions.

The Cash Account dashboard has been updated to display up to 1000 transactions per monthly period.

A .csv report will be available for download that details up to 200,000 transactions per monthly period.

Some updates of Quota details on CDS were failing, leading to quotas being unavailable for claiming.

Quota addition/amendment process now correctly creates and updates Quotas.

Some EORIs belonging to traders that are ‘Established in the Union’ were incorrectly displaying as not established.

CDS now displays the correct establishment status.

Out of sequence declaration Notify messages that were not received were unable to be manually re-sent due to missing information.

CDS now stores the correct information so that Notify messages can be manually re-sent as needed.

The storage capacity allocated for extraction of Tariff update files was determined to be too low in some case.

An alternate storage location has been identified that has adequate capacity for the extraction of these files.

Performance issues with SPS declarations causing delays and stuck declarations.

Performance has been improved for SPS declarations, resulting in faster processing and fewer delayed declarations.

CDS performance when searching for licence data was very slow.

The CDS licence search algorithm has been updated for faster performance.

A conflict has been identified between NCTS and the CDS alert notifications service that means monitoring of NCTS is unreliable.

Updates have been made to the alerts monitoring process to remove these conflicts.

When a declaration was made using AI Code ‘NIIMP’ and APC ‘B05’, CDS was calculating the tax due to be a negative amount.

The tax calculation for APC ‘B05’ has been redesigned so CDS will show the actual revenue due.

The CDS audit process was causing a high processor load, reducing system performance.

The audit process has been redesigned to avoid excessive processor load and improving performance.

When multiple Small Producer Relief (SPR) values were declared on a CDS declaration, the acknowledgement message could not be sent.

Validation has been introduced to limit goods items to a single SPR value.

When CDS had to retrieve trader information where the trader had an XI EORI, both the GB and XI EORI were returned, doubling the processing workload, and causing delayed responses.

Refinements to the search algorithm mean that only the correct GB or XI EORI are returned, reducing delays in record processing.

When a Document Code was declared with an invalid Document ID, this caused validation failures for other Document IDs declared on the same declaration, even when they were correct.

CDS will now validate Document IDs correctly and only reject those Document IDs that are invalid.

Delays were being encountered when CDS was writing information to a database.

Code has been re-written to more efficiently process database updates, reducing delays.

HMRC Confirm Systems Downtime for the Customs Declaration Service for 31st May - 1st June 2025

Wed, 14 May 2025 08:14:23 GMT

The CDS is scheduled to be unavailable at the end of May as follows:

From 9:30 pm on Saturday, 31st May 2025

To 06:00 am on Sunday, 1st June 2025.

HMRC have advised that declarations submitted during this time period will be processed when the service becomes available after 6am on 1st June.

Those involved in the creation, updating, or embarking of a goods movement reference (GMR) during this time may find that their goods are affected by CDS being unavailable.

Important Note for Pre-Lodged Declarations:

Goods must have a pre-lodged declaration attached to a GMR to be permitted to move using the Goods Vehicle Movement Service (GVMS) during downtime.

GVMS service availability can be accessed at the link below:

Import Movements using GVMS

Import movements using GVMS may need to be manually arrived. HMRC advise that the declaration status should be checked in good time and manually arrived where needed. Guidance can be found at the link below:

https://www.gov.uk/guidance/manually-arrive-your-goods-in-the-uk .

Importing Consignments Containing Controlled Goods with Pre-Lodged Declarations

If moving consignments containing controlled goods with pre-lodged declarations where goods may be subject to inspection, guidance for port inspection facilities and inland border facilities can be found at the link below:

https://www.gov.uk/guidance/list-of-goods-imported-into-great-britain-from-the-eu-that-are-controlled

Exports

Exporters are reminded to ensure the receipt of the Permission to Progress (P2P) before travelling to a port.

French Customs releases an English User Guide for the French Smart Border Obligatory Logistics Envelope (ELO)

Tue, 13 May 2025 16:00:35 GMT

French Customs has released an English user guide to support UK users of the French Border Obligatory Logistics Envelope (ELO), which was released last month.

The ELO went live on 28th April and is in its transitional phase until early autumn, when the use of the ELO becomes mandatory for trade traffic across the channel.

What is the ELO?

The ELO is a data collation database that consolidates all border logistics and regulatory information required for a compliant entry into and exit from France.

All data is collated under one barcode, simplifying the requirements of the French smart border procedures.

From the 28th of April 2025, truck drivers, whether or not they are carrying loads, will be required to present a single ELO reference to cross the French border.

The creation of the logistics envelope must be completed before a truck crosses the border.

It is intended that the envelope is created and controlled by a single point of contact within the logistics chain.

ELO Deployment Schedule:

28th April 2025:  ELO is live and ready to use

April to August 2025:  Transitional phase

1st September 2025:  ELO becomes mandatory

UK users of the ELO will need to create an account on the French Customs website. The French Customs recommendation is to register, use, and become familiar with the ELO before the database becomes mandatory in the Autumn.

A link to the UK version of the user guide can be found below:

20250430_ENG_User Guide_VF.pdf

NTE 2025/14 Update to Thirteen Open General Licences (OGELs)

Tue, 13 May 2025 10:37:07 GMT

NTE The Export Control Joint Unit (ECJU) has published Notice to Exporters 2025/14 advising of updates to 13 open general export licences (OGELs). The licences have been updated to exclude military nuclear power generating and nuclear power propulsion equipment from the scope of the licences.

Changes to OGELs: Affected licences

The following OGELS have been revised to exclude nuclear power generating and naval nuclear propulsion equipment under ML17g and ML9 from the scope of the licence.

The following OGELs have been revised to exclude naval nuclear propulsion equipment under ML9 from the scope of the licence:

Older versions of the licences should no longer be used but should be filed for reference at audit.

The Export Control Joint Unit can be contacted using the details below:

Contact ECJU

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Email:   exportcontrol.help@businessandtrade.gov.uk

Telephone 020 7215 4594

The Export Control (Amendment) Regulations 2025

Wed, 07 May 2025 14:11:12 GMT

On May 2nd, 2025, Notice to Exporters 2025/13 was published confirming the details that we have been expecting since 11th March (NTE 2025/06) regarding updates to the UK Strategic Export Control List, also known as the consolidated list.

NTE 2025/13 advises that The Export Control (Amendment) Regulations 2025 (the Regulations), amend the Export Control Order 2008 and the assimilated Council Regulation (EC) No 428/2009 of May 2009, setting up a Community Regime for the control of exports, transfers, brokering and transit of dual-use items.

To align with the regulations administered by multilateral export control regimes as part of the UK's International commitment to Export Controls, the following changes have been made:

Schedule 2 to the 2008 Order (Military Goods, Software and Technology):

Amendments to reflect routine technical updates to controls on the exports of conventional weapons agreed through the Wassenaar Arrangement. Included are the deletion or replacement of some definitions and editorial amendments relating to the following categories: ML1, ML2, ML7, ML10, ML13, ML19 and ML21 and associated Technical Notes

A link to Schedule 2 of the 2008 Order can be found below:
UK Strategic Export Control Lists

Schedule 3 to the 2008 Order (UK Dual Use Goods, Software and Technology)

UK Dual Use Category PL9013.a4 – administrative amendments to the Technical Parameters. PL9013 was added to the consolidated list in April 2024 and relates to Integrated Circuits

A link to Schedule 3 of the 2008 Order can be found below:
UK Strategic Export Control Lists

Annex I to the assimilated Dual Use Regulation 428/2009 (Dual Use Goods, Software and Technology)

Amendments to Annex I, 428/2009, to reflect routine technical updates to controls implemented by four of five contributors to the Dual Use List: The Wassenaar Arrangement, Australia Group, Nuclear Suppliers Group and Missile Technology Control Regime, which includes definitions to technical notes and several control entries, including:

Category 0: 0B004a and 0B004b
Category 1: 1A202, 1A225, 1B228, 1C002, 1C005
Category 2: 2B352
Category 3: 3A002
Category 5: 5A001, 5E001, 5A002
Category 6: 6A005, 6A225
Category 8: 8A001, 8A002
Category 9: 9A004, 9B, 9E003

A link to Annex 1 to the Assimilated Dual Use Regulation 428/2009 can be found below:
Council Regulation (EC) No 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items (Recast)

The Export Control (Amendment) Regulations 2025 (the Regulations) come into force on 20th May 2025. The amendments will be reflected in an updated version of the consolidated list, which will be republished in due course.

The Regulations and Explanatory Memorandum to the Regulations can be accessed here:
https://www.legislation.gov.uk/uksi/2025/532/contents/made

In addition to the amendments listed, The Export Control (Amendment) Regulations 2025 (the Regulations), also advise changes to fines which may be imposed for certain offences set out in Part 6 of the Export Control Order 2008. Part 6 relates to Offences, Enforcement and Penalties

NTE 2025 advises an increase to the maximum level of fine that may be imposed under the 2008 Order for certain offences on summary conviction, from level 3 on the standard scale (£1,000) to level 4 (£2,500), which is confirmed in the Sentencing Act 2020

Notice to Exporters regularly updates subscribers on settlements relating to unlicensed exports of strategic goods. As recently as February 2025, £3,231,762.40 was paid as a compound settlement to HMRC for unlicensed exports of Military Goods.

Since February 1st, 2025, the UK Integrated Online Tariff has been updated to reflect changes to Document Codes which may be relevant to your Commodity Code. The recommendation is to check the Export Tab of the Commodity Code to confirm the controls that could apply to your goods. Under Strategic Controls, EX001 means potential control under the Export Control Order 2008, and EX005 is a signpost to a potential control under Regulation 428/2009, the Dual Use control.

When providing instructions to your forwarder or carrier, it must be confirmed that the goods are licensable and that they are declared in CDS Data Element 2/3. However, if a control doesn’t apply, it is advisable to confirm this on your commercial documentation by declaring “No Licence Required” In addition, if EX001 and/or EX005 relate to your Commodity Code, declaring that a licence isn’t required has extra emphasis. By declaring that a licence isn’t required, with the appropriate document code, the Tariff confirms the exporter is making “a legal declaration that the consignment does not require an export licence” Being able to support this decision with evidence is a requirement if challenged by HMRC or Border Force. “Sufficient evidence must be held in records to demonstrate eligibility for this exemption and must be produced on demand.”

Many exporters use a third party to complete their Customs Declaration and work with the entity under “Direct Representation.” Due Diligence for Customs and Export Control requirements has increased with the implementation of new changes, and Exporters must be aware of their responsibilities in an ever-changing world of compliance.

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

UK and India Sign Trade Deal

Tue, 06 May 2025 15:06:19 GMT

The UK Government Department of Business and Trade has issued a press release announcing the signing of a trade agreement between the UK and India.

The press release details that the agreement marks the most economically significant bilateral trade agreement made by the UK since EU exit, and the best deal that the Indian Government have ever agreed.

The deal will include a significant drop in Indian tariffs on importing UK goods, including goods from the automotive and advanced manufacturing sectors.

According to the information released, tariffs on UK goods for export to India will be reduced over 10 years. The exact tariff details and UK exports affected will become clear when the agreement is fully published.

The agreement is said to champion improved import procedures for UK goods into India, a joint UK-India project on one streamlined portal supporting UK-India trade, and the online publication of Indian customs procedures and related regulations in English.

What the Press Release Says:

A multi-billion-pound boost to the UK economy, with a landmark India trade deal to make working people better off  

Huge economic win for UK as trade deal with India agreed, which will deliver for working people and British businesses 
Deal will slash Indian tariffs on key products such as whisky, cosmetics and medical devices, locking in reductions on 90% of tariff lines for UK exports to unleash opportunities for businesses across regions and nations of the UK 
Delivers on Plan for Change as £4.8 billion added to the UK economy and £2.2 billion in wages every year in the long run under the deal 
The UK and India have today (Tuesday, 6 May) agreed to a landmark trade deal that delivers on this government's core mission of growing the economy, raising living standards, and putting money in people’s pockets.

Indian tariffs will be slashed, locking in reductions on 90% of tariff lines. 85% of these will become fully tariff-free within a decade. 

Whisky and gin tariffs will be halved from 150% to 75% before reducing to 40% by year ten of the deal, while automotive tariffs will go from over 100% to 10% under a quota. 

Other goods with reduced tariffs, which can open markets and make trade cheaper for businesses and Indian consumers, include cosmetics, aerospace, lamb, medical devices, salmon, electrical machinery, soft drinks, chocolate, and biscuits.  

As the UK liberalises tariffs, British shoppers could see cheaper prices and more choice on products such as clothes, footwear, and food products, including frozen prawns. 

The deal is expected to increase bilateral trade by £25.5 billion, UK GDP by £4.8 billion and wages by £2.2 billion each year in the long run. 

UK businesses gain a competitive edge over international competitors when entering India’s enormous market, as it gets even bigger and is forecasted to become the 3rd largest global economy within three years. 

Business and Trade Secretary Jonathan Reynolds and Indian Commerce Minister Piyush Goyal held final talks in London last week after relaunching negotiations only two months ago. Negotiators across both sides have worked around the clock since February to achieve this deal, which is the biggest and most economically significant bilateral trade deal the UK has made since leaving the EU and the best deal India has ever agreed to. 

Technical Details on Ratification, Publication and Putting the Agreement into Working Practice

After completion of the negotiations, the trade agreement will go through a ratification process in both countries.

In the United Kingdom, the ratification of treaties follows the Constitutional Reform and Governance Act 2010 (CRAG). The key steps include:

Laying Before Parliament: The treaty must be presented to Parliament for 21 sitting days.
Parliamentary Scrutiny: During this period, Parliament can scrutinize the treaty. If either House objects, the government must address concerns, which could extend the process.
Implementation Legislation: If the treaty requires changes to domestic law, additional legislation must be passed, which can add to the timeline.

Given these steps, the UK ratification process typically takes several months. However, the government may expedite the process for significant agreements like the UK–India FTA.

 In India the ratification process appears more streamlined, as follows:

Executive Approval: The agreement is approved by the Union Cabinet.
Parliamentary Oversight: While not always required, Parliament may be involved if the treaty necessitates changes to existing laws.
Once ratification is complete, the full text of the UK-India FTA, including detailed chapters and annexes, will be published on GOV.UK.

Working Practice

As with all trade agreements, the details will be published in the annexes to the agreement.

Lower or zero duty rates will be calculated using the Product Specific Rules of Origin published in the annexes.

Further information can be found at the links below:

Press Release from the DBT can be found here:

UK signs trade deal with India - GOV.UK

Technical statistical data can be found on the DBT Technical note at the link below:

Technical note of the preliminary economic impacts of the UK-India Free Trade Agreement - GOV.UK

UK-India trade deal: conclusion summary - GOV.UK

UK-India Free Trade Deal: A Deal For Growth - GOV.UK

For information: A link to the Indian Government Tax website that covers India Customs Regulations can be found here: Tax Information

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

That was the News: April 2025

niamho@strongandherd.co.uk (Niamh O'Connor) — Fri, 02 May 2025 15:25:33 GMT

April showers appeared not as rain but as tariffs for businesses operating in the international trade sector. Trying to keep abreast of the rapidly changing landscape felt overwhelming, especially for those businesses that export multiple-origin goods from the UK. What it did highlight, however, is the importance of understanding your supply chain and the importance of non-preferential origin. Whether it is understanding fully the impact Incoterms® have within your contracts or if Customs special procedures could be utilised, now is the time to be proactive and review processes and compliance documents to ensure you can continue to navigate this uncertain weather, which will undoubtedly continue beyond the April showers.

For all the latest news & updates, check out our Industry Insights page, and don't forget to follow us on LinkedIn !

NTE 2025/07: Update to Open General Export Licence

The Export Control Joint Unit (ECJU) has released Notice to Exporters 2025/07, dated 20 March, advising that the Open General Export Licence (AUKUS Nations) has been revised to better align with the U.S. excluded technologies list.

We Told You Non-Preference Origin Was Important!

If the events of early April 2025 have taught us anything, it’s this: non-preference origin is no longer a box-ticking exercise. It’s a central piece of trade compliance, especially for any business exporting to the United States.

LITE and Best Practice

Applying for a Standard Individual Export Licence (SIEL) can be daunting, particularly if the applicant is unused to terminology or unsure why the application questions are phrased the way they are.

Department of Business and Trade announce temporary tariff suspensions for successful product applications in 2024

The Government have announced tariff suspensions on products successfully submitted for temporary tariff suspension quotas during the 2024 application window.

The EU Pauses Reciprocal Tariff Measures on US Imports

The EU has announced that it is pausing the implementation of reciprocal tariffs on the US.

Update of the OGEL for Oil and Gas Exploration Dual Use Items

The Export Control Joint Unit has issued Notice to Exporters 2025/09 advising of the update of the Open General Export Licence, Oil and Gas Exploration Dual Use Items

French Customs set to employ the Obligatory Logistics Envelope or ELO from Spring 2025

The French Customs Authorities are preparing to roll out the release of the ELO, or Obligatory Logistics Envelope, into its Transitional Phase this Spring.

The EU Commission Recommends Member States' Data Sharing on Dual Use Export Controls

The EU Commission has released a recommendation proposed initially in the January 2024 White Paper on Export Controls, aimed at enhancing coordination and communication between the EU Member States of their national control lists of dual-use items. 

Standby Letters of Credit (SBLC / SLOC) are Back in Demand

Banks have reported a resurgence in the use of Standby Letters of Credit (SBLC / SLOC), a facility which can provide assurance against defaults in supply contracts. We look at the benefits and limitations of SBLC and the reasons for their increasing popularity.

NTE 2025/11: Further Sanctions Against Russia were Introduced in April 2025 for Imports and Exports

The ECJU have published a further Notice to Exporters relating to Russian Sanctions.

Getting it Right at the Border

Thu, 01 May 2025 10:42:13 GMT

Any trader moving animal or plant products over the borders into the UK will attest to the difficulties experienced if goods are not presented precisely as required by the cross-border IT systems supporting the UK Import Regulations.

The Animal and Plant Health Authority releases regular updates to its processes and procedures to help traders present data in the right order on the right systems at the right time.

It is very easy to miss something that could influence an authority's decision to hold goods at the border, whether at the behest of the Port Health Authority or by the Border Force.

Good communication within the supply chain for goods coming from EU Member States is pivotal, as is good contact between logistics providers and declaring agents.

There can be many actors in one movement across the border, particularly if that movement involves multiple consignments and mixed loads. The level of cross-border compliance difficulty multiplies according to the type of goods making the crossing, the documentary evidence needed, how the goods are presented through the cross-border IT systems, and the accuracy of the data submitted.

Top Tips

1. Multiple CHEDs under the same MRN.      

There is an increased risk of a whole load being held at the border if one part of the load has a higher risk of requiring an SPS border check. A mixed load or groupage can cause the whole load to stall until checks have been completed.

Suggested Action

Traders and their agents are asked to check the status of their consignments in both IPAFFS and CDS and, if necessary, discuss options to negate the chance of delays with the Port Health Authority/Local Authority (PHA/LA) at the point of goods entry.

Options may include unloading the goods and separating consignments vulnerable to checks from the load. Of course, this will require resubmitting the Customs Declaration for the load.    

Good communication is essential between all parties, including the driver, who will be responsible for separating the load and any consignments that could cause the movement through the port to stall.

  2. Removal of consignments for inspections with a pre-lodged declaration.     

Action to take:

If a change is made to a consignment in a pre-lodged declaration before the goods reach the GB border, it will be necessary to:

Cancel the accompanying CHED notification in IPAFFS
Amend the pre-lodged declaration to remove all commodity codes relating to the cancelled CHED and remove the CHED reference number from the declaration.

Likewise, the PHA should be advised of the CHED cancellation.

Cancelled CHEDs should be removed from the Customs Declaration, or CDS will continue to look for an inspection decision, and the goods will stall at the port because the SPS hold indicator remains in place
Consignments will not be released until the Customs Declaration is amended and the SPS hold is lifted.
In exceptional cases where the CDS entry cannot be amended, the National Clearance Hub can issue a manual release.

Important Note: NCH will NOT release holds for any other reason.     

3. Consignment remains under an SPS hold in CDS      

If all the SPS checks are complete, the CHEDs are indicated as valid on IPAFFS, and the consignment remains on an SPS hold, the likelihood is that there are inconsistencies in the data submitted between the CHED import notification and the Customs Declaration.

Where action should be taken:

Traders and agents should check the data submissions for the CHED against those made in the declaration and make amendments, as necessary. The most common errors include:    

The CHED reference number is incorrectly entered onto CDS   
Commodity codes do not match.   
Non-English script characters have been copied and pasted into the CHED fields on IPAFFS

CDS will not recognise script characters used in other languages that do not appear in English, such as the acute accent or cedilla, which are common in European languages. Copying and pasting verbatim where such script characters are present will result in rejection on CDS.

The final destination code has not been entered as GB, or the GB address is not recognised as a GB address.

The authorities advise that further assistance with the above issues should be addressed to the Port Health Authority applicable to the point of entry of the goods into GB    

Animal by-product (ABP) Importer declarations  – How your EU supplier can help
ABP Model Health Certificate templates are available to traders in the EU. If completed by the exporting trader, they would assist the GB importer in completing accurate and compliant import formalities into GB.

The model certification is not obligatory, but voluntary use of the certification could help reduce the margin for error in product identification and accurate data entry, therefore assisting the smooth movement of ABPs through the import procedures.
Model Health Certification templates are available for the following products:

a. GBHC141 – for bones and bone products, horns and horn products and hoof products intended for use other than as feed material, organic fertilisers, or soil improvers

b. GBHC586 – for untreated wool and hair, depending on the country of origin and intended destination

c. GBHC144E – for intermediate products

Note: The model health certificate should support, not replace, commercial documentation

GOV.UK guidance can be found at the link below:

Import animal by-products from the EU to Great Britain - GOV.UK

Model Health Certificates can be found for download at the following link:

Hides, horns and trophies: model health certificates - GOV.UK

Foot and Mouth Disease  
Enhanced import controls remain in place for affected commodities from Germany, Hungary, Slovakia, and Austria.

The hand carrying of affected commodities are also forbidden entry from all EU Member States into the UK.

The Foot and Mouth landing page can be found below:

Foot and mouth disease: latest situation - GOV.UK

A link to the Animal and Animal Products topical issues page, which includes information on other disease-related restrictions, can be found below:

Imports, exports and EU trade of animals and animal products: topical issues - GOV.UK

Useful contacts  

Imports of animal products :

If you have urgent questions about imports of animal products, including germinal products, contact the Port Health Authority or Local Authority at the Border Control Post (BCP) at the goods’ point of entry.

BCP and PHA/LA contact information can be found on the following link:

Animals, animal products and HRFNAO imports: authorised border control posts in the UK - GOV.UK

Imports of live animals :

Urgent questions regarding the imports of live animals should be addressed to APHA, details at the link below:

Contact APHA - GOV.UK

Imports of plants and plant products:

Urgent questions regarding imports of plants and plant products into England and Wales should be addressed to the Animal and Plant Health Agency (APHA) by email:

The email address is: phsi-importers@apha.gov.uk

Contact can also be made by telephone on the following number: +44 (0) 3000 200 301 

IPAFFS

Technical Help can be found by contacting the Animal and Plant Health Agency as below:

APHA Helpline is at 0330 041 6999 or email APHAServiceDesk@apha.gov.uk . This service is not available 24 hours a day.

Information on importing products of animal origin for human consumption can be found here: Import animal products for human consumption from the EU to Great Britain - GOV.UK  

A link to the guidance pages for the import of live animals and germinal products can be found here: https://www.gov.uk/guidance/import-live-animals-and-germinal-products-from-the-eu-to-great-britain  

Further information on the import of High-Risk Food and Feed Not of Animal Origin can be found at the link below:

HRFNAO: https://www.gov.uk/guidance/import-high-risk-food-and-feed-not-of-animal-origin-from-the-eu-to-great-britain  

Plants and plant products:   

Importing from non-EU countries:  

Guidance on the import of live animals, animal products and HRFNAO from third countries can be found below:

Importing live animals, animal products and high risk food and feed of non-animal origin from non-EU countries to Great Britain - GOV.UK   

Guidance for the import of Plants and plant products from third countries can be found at the links below: 

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

NTE 2025/11: Further Sanctions Against Russia were Introduced in April 2025 for Imports and Exports

Wed, 30 Apr 2025 11:39:08 GMT

The ECJU have published a further Notice to Exporters relating to Russian Sanctions.

The notification NTE2025/10 was published on 25 April 2025, and the additions to restrictions on trade with Russia came into force on 24 April.

New measures

New measures have been applied in the following schedules to the legislation:

Schedule 2A (critical-industry goods and critical-industry technology)
Schedule 3 (energy-related goods and energy-related technology)
Schedule 3C (defence and security goods and defence and security technology)
Schedule 3E (G7 dependency goods and G7 dependency technology)
Schedule 3I (Russia’s vulnerable goods and Russia’s vulnerable technology)

Additional new sanctions include the export, supply, and delivery of chemicals, electronics, machinery, plastics, and metals. Further restricted actions include making captured items available to or for use in Russia. Ancillary services related to the goods will also be subject to the change in regulation.

If goods for export are captured within the above schedules, ensuring compliance with the legislation will be essential before attempting to export goods.

Technology and software

The new sanctions measures also capture software and technology relating to the following industries:

Energy
Advanced industrial manufacturing
Business enterprise
Industrial design
Oil and gas

Prohibited actions include both the transfer and making available to Russia of captured technology and software. Ancillary services related to the technology and software captured in the legislation are also prohibited.

The detailed amendments and additions to the 2019 Regulations can be found in:

Chapter 4 (energy-related goods, energy-related technology, and related activities)
Chapter 4H (G7 dependency and further goods and G7 dependency and further technology)
Chapter 4M (Russia’s vulnerable goods and Russia’s vulnerable technology)
Chapter 4N (sectoral software and technology)

Additional Restrictions on Imports

Import bans are now in place for synthetic diamonds processed in third countries and on the import of helium. Affected imports can be found in the following chapters:

Chapter 4JC (certain diamonds mined in Russia processed in a third country)
Chapter 4JD (certain Russian-manufactured synthetic diamonds processed in a third country)
Schedule 3DA (revenue-generating goods - Helium)

Exceptions

Some exceptions to the prohibitions are set out in detail within the chapters in the 2019 Regulations. Where an exception may be noted as possible within the chapter, licences can be granted in minimal circumstances, and applications should be made through the ECJU.

Link to the NTE: NTE 2025/11: further sanctions against Russia introduced in April 2025 - GOV.UK

Further guidance and support

The guidance pages for Russian sanctions are in the process of being updated. Updates will be found at the link below:

  Russia sanctions: guidance page .

Technology and Software:

Guidance on the transfer of technology and software sanctions can be found at the links below:

  Complying with technology transfer sanctions  

Complying with sectoral software sanctions .

Standalone services

Businesses offering standalone services can find further information on licensing, compliance, and enforcement for trade sanctions by completing the online form at the link below, to be submitted to the Office of Trade Sanctions Implementation.

Contact the Office of Trade Sanctions Implementation (OTSI) - Contact OTSI – GOV.UK

Export Controls

Enquiries related to Export Controls and trade sanctions that could affect the provision of ancillary services should be directed towards the Export Control Joint Unit. The landing page for the ECJU can be found at the link below:

  Contact the Export Controls Joint Unit (ECJU) .

Contact with the ECJU can be made directly as follows:

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Export support for UK businesses

Telephone 020 7215 4594

Importing:

For further information on import-related sanctions, the DBT’s landing page can be found here:

Import controls - GOV.UK

Details on Import Controls and Trade Sanctions can be found at the link below:

Trade Sanctions - GOV.UK

If your goods are not subject to export licences and your business is considering trade with Russia or Ukraine, the Export Support Service is a suggested source of information.

A link to the ESS landing page is below:

The legislation for the new measures is the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, found here:

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025

The latest version of the original 2014 sanctions regulation can be found in the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”), found here:

https://www.legislation.gov.uk/uksi/2019/855/contents

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

A Spotlight On: A business approach to a UK Defence Export Project from a Trade Compliance Perspective

Fri, 25 Apr 2025 14:09:08 GMT

With the UK government set to increase the UK Defence budget against the backdrop of growing defence and trade tensions, there are rising opportunities for smaller businesses to sub-contract to the larger defence contractors, or if their business is niche, contract directly with the MoD.

If a business has never considered a defence contract and an opportunity arises, or if the company generally has limited experience in a cross-border supply chain and wants to get started, here are some pointers on managing trade compliance as a project:

From submitting a response to a request to tender, working the supply chain, and delivering.

Larger MoD projects are generally managed by the more prominent players in the defence sector, such as BAe, Rolls-Royce, Thales Group and Leonardo, to name a few. This doesn’t mean that SMEs are excluded. The salient point is for a business to understand its role in a defence project and plan for success. Trade compliance will be central to that success.

Building the contract and project definition from a trade compliance perspective:

Define:

Goods from a trade compliance perspective. Data must include tariff classification, origin, and value of goods.
Goods from a military or controlled goods perspective, and what licences would be needed to fulfil contractual obligations.

This will include any other country controls related to the goods on your inventory, an example being the US International Trade in Arms Regulation (ITAR) or Export Administration Regulations (EAR) controls.

Any security documentation or specific security obligations to be met to support the contract schedule, including but not limited to: F680, F1686 and project security requirements flowed down in a contract Security Aspects Letter.
Where the goods will be delivered and any delivery term (Incoterm®) used to make deliveries. This will influence any export licence requirement, and which party will be responsible for export licence provision, declaration, and regulatory audit.
Logistics. Are there any restrictions within the contract regarding specific delivery schedules or methods that may influence goods being delivered other than through anticipated delivery routes? For example, controlled goods will be delivered to a site in one country where the nearest airport is in a third country.
Procurement: The goods the business purchases overseas or as part of a contract supply chain must be interpreted in Customs terms. This will include the tariff, origin and value of the goods, with the Incoterm® for delivery clearly managed and visible on any contract or purchase order.

A business may purchase controlled goods from another country, subject to export licences from that consignor country. Lead time for an export licence could add lead time to project delivery and affect the business assessment of contractual risk

Goods imported for manufacturing. Raw materials for manufacture in the UK and subsequent re-export may require compliance evidence in the importing country regarding the origin of those raw materials.

Re-exported manufactured goods may also be subject to other regulatory reporting, such as Carbon Border Adjustment Mechanism (CBAM) reporting.

The potential use of Customs Special Procedures for the import of goods that will be subject to subsequent re-export.

Inward Processing measures could be employed where raw materials are imported for manufacture and re-export, or goods are returned for contractual repair.

Customs Warehousing could be used to import larger quantities of raw materials to be kept available for the duration of longer projects. Materials could then be transferred to an IP authorisation for processing before export.

If goods are being imported for test and return, consider using Temporary Import measures to manage import VAT.

Employing Customs Special Procedures may not be cost-effective, but should be considered.

Top Tip: A UK company that imports goods without the intent for the goods to belong to that importing business would need to pay VAT on import for those goods. Import VAT under these conditions is not recoverable and must not be imported using Deferred or Postponed VAT Accounting (PVA) processes.

Any support contract considerations, including guarantees and warranties. Goods repair clauses may necessitate the use of Customs measures where goods are imported for repair or replacement.

Regulatory definition: What is important and why

Origin: Accurately declaring the Origin of goods on a Customs declaration is a regulatory requirement. The origin of a good must not be assumed.

Origin is often unrelated to the country from which the goods were consigned. This is an easy mistake to make. Goods origin requires compliance evidence, whether by declaration or supporting origin documentation.

Delivering goods nationally will also require confirmation of the goods' origin if the goods further down the supply chain are for export, for example, international sanctions on controls relating to metals of Russian origin. Confirmation of originating country will become increasingly important within the supply chain.

Fluctuating US Tariff measures may require a detailed breakdown of the origin of all materials used in a good for import to the US. This will likely be subject to change, but if the data is unavailable at import into the US, the import will wait at US Customs with charges accruing until the required compliance data is submitted to support the Customs declaration.

Goods Definition: Accurate classification of goods moving across borders is essential.

A sound understanding of the UK Global Tariff and how it works is necessary on import, as duty and import VAT are calculated using the Tariff code presented at import. The importer's obligation is the correct declaration of a Tariff code subject to audit.

If goods are designed or adapted for military purposes, or already carry a control rating when procured, they will require a licence to export from the UK.

A Tariff code may carry a dual-use classification flag that must be addressed before goods are exported. Dual-use goods require an export licence, and accurate classification against the Strategic Export Controls list must be established.

How the classification was arrived at should be saved for audit. If the classification identifies that a control does not apply, the information supports the use of a positive coding on the export declaration to this effect.

Taking a broad view of a contract requirement from a trade compliance perspective makes good business sense. Removing the segmented departmental approach and replacing it with a broad technical definition of the contract requirement from a trade compliance perspective can save the business a lot of time, effort and money.

Understanding goods’ definition from a trade perspective is essential when manufacturing or presenting goods as a compliant export. Ensuring accurate goods definition from both a Customs and a control perspective has never been more critical.

Working with Defence - Defence Equipment & Support

Standby Letters of Credit (SBLC / SLOC) are Back in Demand

Thu, 24 Apr 2025 12:14:34 GMT

Banks have reported a resurgence in the use of Standby Letters of Credit (SBLC / SLOC) , a facility which can provide assurance against defaults in supply contracts. We look at the benefits and limitations of SBLC and the reasons for their increasing popularity.

A Letter of Credit (LoC) is an undertaking from a bank, at the request of a buyer, to pay the supplier an agreed payment on presentation of agreed documents within a stipulated time. LoC’s offer security to both parties in a transaction for goods. The supplier can rely on the bank's status to ensure payment will be made, provided they can fulfil the contract as agreed. The buyer gets assurance that the goods as ordered have been shipped as agreed. The security of LoC’s needs to be measured against the costs of such facilities and the inevitable lack of flexibility they place on the supplier. The strict compliance that banks are obliged to impose on presented documents also causes problems; in fact, it’s reported that most requests for payment are refused at first presentation.

When a buyer defaults on payment, an SBLC provides a 'fall-back' that suppliers can call on. Invoking an SBLC involves presenting the necessary documents to the issuing bank, which then makes the payment to the supplier. This facility is only used if direct payment from the buyer is not received, providing a safety net for the supplier.

Issuing banks have specific rules of practice to follow for SBLC, under International Standby Practices (ISPB98) issued by the International Chamber of Commerce. Understanding these rules is crucial, as while SLBC can be seen as an unwelcome expense, it poses increased risks of country default and political risks.

With increasing uncertainty in world finance, reliance on LoC’s as a method of payment that offers some security is a means for exporters to secure trade without exposing the business to unattractive levels of risk.

The EU Commission Recommends Member States' Data Sharing on Dual Use Export Controls

Wed, 23 Apr 2025 10:21:52 GMT

The EU Commission has released a recommendation proposed initially in the January 2024 White Paper on Export Controls, aimed at enhancing coordination and communication between the EU Member States of their national control lists of dual-use items. 

Dual-use controls can apply to goods and technology with high specifications that can be used in civil, military, or other controlled or sanctioned regimes. The national control lists stem from internationally agreed conventions and arrangements.

The Commission Recommendation is a set of voluntary standards, guidelines, and a coordination mechanism where pertinent dual-use control information can be shared on a voluntary basis between EU Member States.

It also outlines key principles for aligning national dual-use control lists with EU and multilateral agreed standards. 

Export controls are subject to national security regulations and restrictions; therefore, the recommendation could only be for implementation voluntarily by each member state, and with possible national member state conditions.

The EU has advised that implementation of the recommendations in the paper would promote a more integrated and unified EU approach towards global export control issues.

Links to the Commission Recommendation can be found below:

Commission Recommendation (EU) 2025/683 on coordination of national control lists

The White Paper on which the recommendations are based can be found below:

White Paper on export controls - 24 January 2024

Details of the EU Trade Policy on the export of dual-use items can be found below:

Exporting dual-use items

The UK Strategic Export Control lists and links to the UK Export Control legislation can be found here:

UK strategic export controls - GOV.UK

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

French Customs set to employ the Obligatory Logistics Envelope or ELO from Spring 2025

Tue, 22 Apr 2025 13:14:40 GMT

The French Customs Authorities are preparing to roll out the release of the ELO, or Obligatory Logistics Envelope, into its Transitional Phase this Spring.

The ELO is a system where all Customs paperwork can be collated under one barcoded reference number allocated to the driver. One truck or lorry, one ELO barcode.

This French smart border implementation will be discretionary until the end of August, but mandatory from 1st September 2025.

The ELO must be created by a pre-designated party or ELO creator, who will hold the responsibility as the one point of contact for creating all Customs regulatory paperwork before the goods begin crossing to France. Goods are then risk assessed during the crossing and directed to either the Green or Amber lane when they reach France.

This process is the same for both full and empty lorries crossing into France.

Actors in the Process:

ELO Managers: Responsible for the French Customs ELO account, collating all goods data and relevant regulatory paperwork from the supply chain supporting the goods that are making the crossing.

Economic Operators: A single designated contact appointed to create the ELO and be the point of contact while the ELO process progresses to import in France.

Drivers: Will have one barcode reference for presentation to French Customs. All goods in the load will be grouped under this one barcode.

Calendar Dates:

Spring 2025:  ELO will be released
April to August 2025:  Transitional phase
1st September 2025:  ELO becomes mandatory for goods entry into France

Note: ICS2, Delta, G/IE, Delta T and ECS/SDS will continue to be used alongside the ELO and SI Brexit systems.

SI (Statutory Instruments) Brexit is an interface between the maritime companies’ systems, the existing Customs clearance systems (Delta G, Delta T and ICS), and the existing sanitary IT system (TRACES).

Users are recommended to become familiar with the new border processes before full implementation in September.

The French Customs website gives all the necessary details translated into English, with further information translated into 9 languages.

A link to the French Customs website can be found below:

Obligatory Logistics Envelope (ELO) - A Key Transition for RoRo Trade with the United Kingdom | Portail de la Direction Générale des Douanes et Droits Indirects

Slides from the ELO public webinar of the 18th of February can be found below:

Slides from the ELO webinar on 18022025

A link to a flyer for the Economic Operator can be found here:

The Brexit border crossing is changing

A link to a flyer for lorry drivers, with translation from French into 9 languages, can be found at the link below:

Multilingual-flyer-for-lorry-drivers.pdf

Upcoming Events & Training Courses this May

niamho@strongandherd.co.uk (Niamh O'Connor) — Thu, 17 Apr 2025 12:25:08 GMT

Join us in May for comprehensive training courses on Customs compliance and international trade.

Our May sessions are tailored to suit your schedule, offering full-day courses and focused, shorter clinics. Whether you're looking to master the basics of import/export or delve into more advanced Customs regulations, we have a wide range of courses to suit your needs.

See below for further details of May courses.

Clinics

Courses

Update of the OGEL for Oil and Gas Exploration Dual Use Items

Wed, 16 Apr 2025 13:05:50 GMT

The Export Control Joint Unit has issued Notice to Exporters 2025/09 advising of the update of the Open General Export Licence, Oil and Gas Exploration Dual Use Items

The licence, which allows a range of dual-use hydrographic goods, software and technology that are exported to support industrial oil and gas contracts, has been updated from 15th April, 2025. The licence was first issued in 2013.

The licence can be used for a wide range of destinations. However, exporters are reminded that use of the licence is dependent on compliance with licence terms and conditions and is subject to the annual licence returns reporting.

Open general export licence oil and gas exploration: dual-use items - GOV.UK

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

The EU Pauses Reciprocal Tariff Measures on US Imports

Tue, 15 Apr 2025 14:02:30 GMT

The EU has announced that it is pausing the implementation of reciprocal tariffs on the US.

The EU, through Implementing Regulation 2025/77 amending Implementing Regulation (EU)2018/886 of 2018, has taken a hopeful step by placing the rebalancing measures on hold for a 90-day period. This pause in implementation clearly indicates the EU’s commitment to negotiation over retaliation.

In her statement dated 10 ^th April, President von der Leyen makes it clear that there is firm support from all EU Member States to retaliate in kind to President Trump’s tariff increases. She also confirms that the EU is prepared to implement further countermeasures as and when necessary, a sign of caution in these uncertain times.

The statement can be found below.

STATEMENT_25_1036_EN.pdf

A list of goods affected by the Implementing Regulation (EU)2025/778, where retaliatory measures may be actioned, can be found within the text of the regulation at the link below. This list serves as a guide for potential trade implications and is subject to change. It may be updated as the present US tariff situation develops.

Implementing regulation - EU - 2025/778 - EN - EUR-Lex

Department of Business and Trade announce temporary tariff suspensions for successful product applications in 2024

Mon, 14 Apr 2025 13:54:12 GMT

The Government have announced tariff suspensions on products successfully submitted for temporary tariff suspension quotas during the 2024 application window.

A published list of goods ranges from spices to gardening supplies.

The government regularly publishes a tariff quota application window, during which any UK business may apply for a temporary duty suspension to be applied to their products. Successful products then have a temporary tariff suspension added to the UK Trade Tariff against the product classification.

An announcement for an available open tariff quota application window is published on the Duty Suspensions and Autonomous Tariff guidance pages, with a corresponding Notice to Importers to advertise that the tariff window is open.

A link to the list of tariff suspension quotas from the 2024 application window can be found below.

list-of-2024-duty-suspensions-to-come-into-effect.odt

Note: any business trading in the goods listed can import the goods applying the published duty suspensions, which are published on the UK Global Tariff against the commodity codes:

A link to the guidance page can be found below:

UK Trade Tariff: duty suspensions and autonomous tariff quotas - GOV.UK

A link to the press release can be found at the link below:

Government cuts price of everyday items and summer essentials - GOV.UK

LITE and Best Practice

Thu, 10 Apr 2025 14:21:52 GMT

Applying for a Standard Individual Export Licence (SIEL) can be daunting, particularly if the applicant is unused to terminology or unsure why the application questions are phrased the way they are.

Most commonly, the applicant is considering using a SIEL to support an export where licence conditions prevent the use of an open licence. Some businesses prefer to apply for a SIEL to support their exports in general, preferring the security of knowing that they are compliant with the exact application they have made, and having the security of that individual government approval to export.

A business may be unclear whether their export is compliant with UK law and wants to make sure. Regulations supporting sanctions against Russia were updated in steps, making it harder to interpret whether a licence was needed. The safest option in some cases was to create a licence application.

These are valid reasons for a SIEL application.

How to approach applying for a Standard Individual Export Licence

The IT system that supports the process of applying for a Standard Individual Export Licence has changed, and exporters will now be applying for SIELs using the new Licensing for International Trade and Enterprise, or LITE data interface, rather than applying through SPIRE.

LITE asks the same questions as SPIRE but in a revised format that is intended to support easing the application process for the exporter.

Best Practice is Preparation

Be sure of what you want your licence to support your business to do. The licence is a legal document giving the government permission to fulfil an export purpose. Make sure you apply for what you need.
Make sure the end user undertaking is fit for purpose.

Top Tips :

The undertaking needs to be submitted at the time of licence submission. One of the most common errors with an application is that the end user undertaking does not match the application.
Complete the goods list in the same order that they are presented on the undertaking. Your Case Officer will appreciate this.

Collate all the documentation to be submitted as part of the application process in one file ready for upload. Double-check that it is all relevant and accurate.

Top Tips:

Do not be afraid of adding additional explanatory documents, particularly in relation to the route of supply or technical data.
The licence will pass through many government departments, including a technical review. The technical team needs to assess the goods for export against the UK Strategic Controls Lists, so it is essential to define the goods and their design intent.
If a goods rating is submitted with the application, this rating will be checked. If no rating is submitted, the technical team will provide one using the technical data submitted with the application.
Be clear as to what will happen to the goods post export. Consider goods integration, onward processing post export, and final or ultimate end use. The government want to understand where controlled goods are going, and what they will be used for.
Understand any security grading associated with the goods.
A security grading may be associated with a goods type previously supplied to the UK MoD. Goods with higher security grading may therefore need the appropriate permissions from the UK MoD to support exports.
These permissions come in the form of an F680 document, and applications are made through SPIRE.
Goods for export to support a UK MoD collaborative project may require an F1686. An F1686 is supplied through commercial channels relating to the given project or contract.

Ready to press ‘submit’?

Top tips:

Have someone double-check that the application is accurate and fit for purpose.
A SIEL is quantity specific, so an error in the goods quantity fields can cost time, which may be in short supply if goods are to support an imminent export.
Consider using someone within the business who is familiar with the contract, project, or supply route to check the application. It is often at this stage that changes to the contract or supply route are captured.

Save the application reference number that appears after the application has been submitted. This will be the reference used in any correspondence with the ECJU licensing unit while the application is in progress.

Note: This is not the licence number at this stage. The licence number will be given on the licence when the licence is granted.

A link to the UK Strategic Export Control Lists can be found below

UK Strategic Export Control Lists

A link to The Export Control Order 2008 can be found below:

The Export Control Order 2008

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

We Told You Non-Preference Origin Was Important!

Mon, 07 Apr 2025 11:52:01 GMT

If the events of early April 2025 have taught us anything, it’s this: non-preference origin is no longer a box-ticking exercise. It’s a central piece of trade compliance, especially for any business exporting to the United States.

When President Trump announced sweeping new baseline and reciprocal tariffs on 2 April 2025, suddenly the origin and the details on your shipping paperwork came under the spotlight. A universal 10% tariff was imposed on all imports into the USA effective 5 April, with sharply higher country-specific duties (up to 49%) applied from 9 April 2025, and this is based on where the goods are made, not where goods are shipped from.

That’s why non-preference origin matters.

Let’s be clear: non-preference origin is not the same as preferential origin used for free trade agreements. It doesn’t matter whether your goods qualify under the UK–USA Mutual Recognition Agreement, the South Korean-USA Free Trade Agreement (KORUS) or a zero-duty regime somewhere else. The US new tariff system applies duties based on the origin defined under WTO Customs rules, typically the country where the product was last substantially transformed.

Under this new structure, if you ship a £50,000 mixed origin consignment to the US from the UK — but £15,000 of that is Chinese-origin and £10,000 is Japanese-origin — then that portion of the consignment is going to be hit with 34% and 24% tariffs respectively, regardless of the UK being the exporter. Even if you hold stock in the UK, apply your own branding, or do final assembly here, you’re not off the hook unless you meet strict origin transformation rules.

Is your company one of the exporters that rely on guesswork to identify origin, assume it’s UK origin because you bought it from a UK company, or assume the shipping country and country of origin are the same? Declaring non-preference origin is mandatory under global Customs regulations, but freight forwarders/ intermediaries and Customs brokers often fail to separate values and commodity codes against origins on Customs declarations. Going to America this could trigger incorrect duty payments, audits, and penalties. With the new tariffs in force, the cost of getting the origin wrong just skyrocketed.

It also exposes the risk of routing goods through the UK or EU as a way of “laundering” origin. U.S. Customs and Border Protection (CBP) is likely to scrutinise entries closely for misdeclared origin, and applying UK origin to goods that are clearly made in Asia or Europe won’t survive an audit. There is also the opportunity of claiming a zero duty on goods of USA origin going back into the USA under the newly introduced HSTUS 9801.00.10 .

U.S. goods returning (HTS 9801.00.10) must be unmodified abroad, be supported by proper documentation (e.g., declaration from U.S. exporter, proof of prior export) and be declared correctly at entry to be duty-free and exempt from MPF (a tax Merchandise Processing Fee).

There’s still time to act. Companies need to:

Conduct a line-by-line origin review of any products exported to the U.S.A
Check what information is on your invoices, is the origin clear?
Keep manufacturer declarations and bills of materials on file.
Train commercial and logistics teams on the difference between the shipping country and the origin.
Work with Customs brokers to ensure the correct Harmonized Tariff Schedule codes and origin declarations are made at entry.

Non-preference origin has always been a legal requirement. But now it’s also a financial one, with direct bottom-line consequences.

So yes, we told you origin was important! Hopefully now, everyone’s listening.

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

That was the News: March 2025

niamho@strongandherd.co.uk (Niamh O'Connor) — Fri, 04 Apr 2025 15:28:51 GMT

As we enter the month of April, we take a moment to remember our dear colleague, Sarah. It’s hard to believe a year has passed without her vibrant presence. While this time naturally brings a sense of sadness, we choose to reflect on the joy she brought into our lives and her lasting impact on us all. Sarah remains a cherished part of our memories, from her infectious laughter during team meetings to her thoughtful nature.

For all the latest news & updates, check out our Industry Insights page, and don't forget to follow us on LinkedIn !

Case Study UK Trade Remedies: Countervailing Measures (Subsidies)

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Countervailing duties (CVD) are specific tariffs imposed on imported goods to offset subsidies provided by foreign governments to their domestic producers, ensuring fair competition.

CDS - Changes to Ozone Depleting Substances Import and Export Measures

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Foot and mouth disease in Hungary Important information for importers

DEFRA issued information as of 10th March 2025 confirming that Foot and Mouth disease has been reported in Hungary.

NTE 2025/06: upcoming updates to the UK strategic export control list - GOV.UK

The Department of Business and Trade has issued a Notice to Exporters 2025/06 published on 11th March 2025. This notice gives advance warning of updates due to be made to the UK Strategic Export Controls List.

US Imposition of Safeguarding Measures and EU Response: Countermeasures on US Steel and Aluminium Tariffs Explained

The Trade Expansion Act of 1962 (19 U.S.C. §1862) Article 232 makes provision for the US President to impose import trade measures where he considers there to be a threat to US national security.

Exporters, Importers and Declarants – Who Can Act and Who is Liable?

The question of who can appear on a UK Customs declaration is one that is not as simple as it might seem when it comes to the current rules and regulations, as laid down in UK legislation and in the UK Trade Tariff, Volume 3 for CDS. So, who can act as an exporter, importer or declarant and where does that leave them in terms of liability for the declaration and for the Customs debt?

Transit Movements - Important Information from HMRC

The Office of Transit penalty for missing Transit MRNs on the GVMS will commence on 7th April 2025.

The Windsor Framework and Parcels – All Change!

New arrangements for sending parcels from Great Britain to Northern Ireland by parcel carriers from 1st May 2025.

Important NCTS5 Information About Unloading Remarks Carried Out During British Summertime (BST)

Since NCTS5 went live with Transitional rules on 28th June 2024 and Final State Rules on 21st January 2025, HMRC has been providing ongoing support to assist customers. In this update, they are providing information on potential issues traders may encounter when entering unloading remarks during British Summertime (BST), which runs from 30th March to 26th October 2025 inclusive.

Simplified access to the Customs Declaration Service (CDS) through your Business Tax Account (BTA)

HMRC have introduced a change, adding a new CDS section to the Business Tax Account (BTA) homepage.

NTE 2025/07: Update to Open General Export Licence

niamho@strongandherd.co.uk (Niamh O'Connor) — Wed, 02 Apr 2025 12:07:13 GMT

The Export Control Joint Unit (ECJU) has released Notice to Exporters 2025/07, dated 20 March, advising that the Open General Export Licence (AUKUS Nations) has been revised to better align with the U.S. excluded technologies list.

The revised licence includes a more precise explanation of US terminology and definitions, intended to assist users in licence compliance.

A link to the updated licence can be found below:

Open general licence (AUKUS Nations)

Contact Details for the ECJU

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY