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.