HMRC update - Development of the single trade window paused for 2025

29 Jan

This report provides a summary of recent HMRC updates and their implications for traders and operators. Further guidance and communications will be issued as necessary.

HMRC Trade and Customs Update

1. Voluntary Disclosures

Current guidance states that voluntary disclosures should be made through the National Clearance Hub (NCH). However, there is no clear process within the NCH for processing the necessary information to charge the required tax and regularize the position. HMRC is working on a solution to allow voluntary disclosures through the Customs Declaration Service (CDS), enabling traders to retrospectively submit declarations by referencing a bespoke code to identify them as voluntary disclosures.

2. CDS Updates

Progress: HMRC confirms that all targets for the year remain on track.
December Key Update: Cash accounts can now be used for those with over 5,000 transactions. A fix is in place to address reported difficulties, and communication and guidance will be issued.
Trade Reports: Reporting and extraction functionality is expected for delivery in March 2025. Screenshots and a demo will be shared next week.
December Release Risks: Concerns have been raised about potential disruption due to major updates coinciding with peak trade periods. However, the December release is fixed as it includes updates for the CPTPP.

Release and Downtime Information

CDS 4.7.0 Release: Planned for January 2025.
- Trade test environment starts: 17 January 2025.
- Internal update: 22 January 2025.
Incident Reports: Major outage on 12 November; a prolonged slowdown occurred on 2 December.
Future Changes: A "non-impacting" CDS change is planned for February 2025, with a downtime-requiring release scheduled for March 2025.

3. Single Trade Window

Development Pause: Due to fiscal constraints, the government has paused development of the Single Trade Window for 2025/2026. The first strategic release, including the private beta user interface for Safety & Security (S&S), will not be publicly launched this year.
Stakeholder Engagement: HMRC is working with trade organizations in preparation for 31 January 2025. The pause allows the government to reassess border priorities and optimize trader experience.
S&S Service Impact: The private beta S&S service was limited in scope and required further investment. It will not be continued due to the anticipated low user uptake.
S&S Declaration Requirements: From 31 January 2025, all imports into Great Britain will require S&S declarations, with limited exceptions (e.g., letters, postcards, printed materials, personal luggage). The carrier or operator of the transport vehicle is responsible for S&S declarations.

4. Goods Movement Reference (GMR)

ENS Reference: There is no current mandate for ENS reference inclusion in a GMR when arriving at GVMS-controlled locations. HMRC will assess whether this requirement should be implemented in the future.
Penalties for Non-Submission of Transit MRNs via GVMS:
- For inbound transit movements through a GVMS port, the transit MRN must be included in the GMR and entered into GVMS before boarding a ferry in the EU.
- Initially, non-compliance will result in education and warning letters.
- From 1 April 2025, civil penalties of up to £2,500 will apply. Many non-compliant traders are likely to be non-established in the UK.

5. Transit

NCTS5 Launch: Goes live at 00:15 on 21 January 2025.
Key Changes:
- Mandatory six-digit tariff classification.
- Electronic MRN presentation; no paper TAD required (barcode or number sequence sufficient).
- Use of data fields instead of box numbers (no additional data required beyond the above).
Documentation: A new Transit Manual Supplement has been published.

6. Exports

Waiver Document Code 999L:
- From 1 February 2025, code 999L will no longer be valid for export declarations.
- Declarants must use an alternative document code for waivers.
- At the same time, Y999 will also be removed from most tariff measures.

Phillip Henwood