Overview and Context
The purpose of this article is to set out the data requirements which apply both on exports from Ireland to GB, imports into GB and exports from GB to Ireland under the EU customs code which has been replicated UK law and will take effect on Brexit and under the existing EU customs code.
The custom dataset set out in this chapter is used almost all customs documents and not just import and export declarations. The so-called entry summary declaration and exit summary declaration which we mention in other chapters are effectively subsets of the full set of customs declarations.
The E manifest which carriers for road, ship (including ferries) and aircraft have to furnish, include part of the dataset. The dataset for imports is a more extensive version of the dataset for exports.
Much of the data required for customs imports and exports is also largely required for transit declarations. These are relevant in traders’ business as they apply to movements through the UK land bridge in respect of the Republic of Ireland imports and traders’ exports to continental Europe through the UK land bridge.
The import requirements apply to the movement of goods between the Republic of Ireland company and the GB counterparty. They are not limited to sales only.
Assembling and Returning the Data
The various ways of handling customs are set out in other sections. It may be that traders’ logistics provider will be in a position to make returns on traders’ behalf in most cases and maybe all cases. In this event, what traders will be required to furnish to them may be little more than the proper product classification, quantities, values, weight and other details which may be little more than what is on the commercial invoice and existing transport documents.
The main purpose of setting out the data requirements here is to deal with the scenario where traders make direct customs declarations. Setting out the data is also designed to give traders a sense of the overall information which must be included on the export and import side in cases where traders feed the information to traders’ carrier/logistics provider. Traders will see that key information includes information about the transaction, the goods, and information about the transport.
Traders’ information systems need the required data in the context of making orders, even in cases where traders do not the customs returns. This may involve modification of traders’ existing IT system or simply adding and associating additional information and codes with customers and products et cetera.
There are IT solutions which may be able to collate the date from the existing digital sources.An Application Programming Interface (API) is an interface that sits on top of other applications and performs a specific function. One such function is data extraction where a customized API can perform automatic data extraction form documents and other data.
Making the Entries
The customs data is in a single internationally recognised format using common codes and the single administrative document. This same document was designed to deal with export, transit, and import. This was part of the logic of the set when it was originally in multi-part paper form.
The information mentioned below in the various boxes is completed by predefined codes for each case. Some of the data is mandatory and some are required only in some circumstances. It can be mandatory in these latter circumstances which might apply to traders in some case.
Many of the actual boxes on the return are completed by insertion of a range of coded entries which are published on Revenue and UK HMRC website. e.g. Revenues Automated Entry Processing Import Traders Guide. There is a particular code associated with the various possibilities for entries such as country name, product type (the tariff), particular customs process et cetera.
In practice, software systems populate the various coded entry requirements in more sensible terms that can be readily used (dragged down and inserted) so that traders don’t have to engage with the codes
Although the return was formerly like returning a coded document of numbers in shorthand modern customs declaration software makes it much more intuitive in that the particular options can be available in the menu for insertion in the particular boxes automatically without having to get into the coded numbering. Just like with other online and software form filling, the software remembers traders’ standard information and makes it easy to full the forms.
Returning to Revenue / HMRC
In practice, whether completed by traders or by traders’ logistics providers, the information is processed and inputted using a serious of screens and by making a final “send” return to Revenue and HMRC. The return may be accepted and a completed e.g. SAD may issues. There are a series of standardised Revenue Messages in this regard.
The final acceptance of a declaration takes place when the arrival is notified. Traders should seek to be routinely green routing and approval in each case), which takes confirms traders can move the goods freely on the exit and entry side from Ireland to the GB on traders’ exports and GB to Ireland on imports to Ireland or supplies from the UK and vice versa on UK sales.
In effect, the data is assessed from a risk management point of view by an automatic online customs algorithm which either requires intervention or gives a free movement signal on each side.
Entry and Exit Declaration
Imports will require an entry summary declaration which may be given by the carrier or which others including a freight forwarder or trader (where possible) may give on its behalf of the carrier. This requires precise information about the transport.
The entry summary declaration is the safety and security declaration on the inbound side. It contains the elements of the customs declaration relative to the identification of the goods and security issues. It must generally be lodged at the office of first entry into the EU (UK) unless otherwise allowed by Revenue / HMRC.
Much of that same information is also required from the carrier in the E manifest. There is some scope for the data being brought in through a number of alternative channels from the importer, logistics provider or if applicable, a customs agent.
In effect, the entry summary declaration must be accepted before the movement can take place or the carrier risks delay. The fact that the entry summary declaration is accepted does not imply that the goods will not be subject to intervention. Notice is given by Revenue or HMRC of intervention (or non-intervention) to the relevant person in charge of the vehicle or ship within certain periods before arrival.
The customs (import and export) declarations are separate from the entry and exit summary declarations. There is some scope for one substituting in whole or in part for the other. Giving the customs import declaration can be postponed until later when the goods are then cleared through customs.
The default is going to “temporary storage” which is the regime where they are subject to possession and control of Revenue and HMRC pending a further declaration to another process such as free movement, involving payment of duties and completion of the customs declaration required for that process.
The customs (import) declaration must be made in advance of shipping (or arrival), accepted and green routed for the goods to move freely through customs. If this is not done, the goods will default into temporary storage in customs on arrival.
In practice, traders can do the exit summary declaration and export declaration as a single return in Ireland. The entry summary declaration is being waived in the UK for a temporary period in the event of a hard Brexit. This combined with the temporary simplified procedure (announced for the 2019 hard Brexit risk dates, if it is reinstated) means some traders could import into the UK under a very simplified procedure is for up to 2 years after Brexit.
The entry summary declaration and the import declaration must be done separately in Ireland. However, as stated the data on import and export summary declaration is on the import and export customs declarations as well as on the shipping/transport manifest. All contain subsets of the below data. There is scope for one being accepted in lieu of the other as long as the minimum data set is communicated.