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.