Import/export: CDS 3.9.0 Update 14 January – additional steps for 'representative status' details

17 Jan 2023

HMRC has contacted JCCC stakeholders with the following update:

As part of the CDS 3.9.0 update, scheduled to take place on January 14th, a minor BAU change will be implemented mandating that if Representative status details are not provided (when required), then the declaration must contain an additional information code for self-representation. These are as follows:

  • Where on an Import declaration (All Types and Categories) where Representative status code in DE 3/21 is not declared (left blank) then DE 2/2 must include additional information code 00400 or 00500
  • Where on an Export declaration (All Types and Categories) where Representative status code in DE 3/21 is not declared (left blank) then DE 2/2 must include additional information code 00400 or 00500
  • Where Agent is omitted from the declaration, DE 2/2 must include additional information code 00400 or 00500.
  • Where Agent is omitted from the declaration and a trader has not submitted AI codes 00400 or 00500 in DE 2/2, CDS will reject the declaration and send a DMSREJ to the submitter

This change will ensure that the above declarations are completed in line with tariff completion instructions. In order to prevent rejections upon the implementation of CDS 3.9.0, please ensure that all pre-lodged declarations comply with the above.

Please note that there remains a known error that when submitting a Final Supplementary Declaration (FSD) by self-representation, CFSP/SCDP traders are only required to complete DE 3/18 with their EORI. CDS will however currently mandate that either DE 3/21 must be completed with a representative status, or that an AI statement is entered on all declarations including the FSD.

This can be avoided by submitting an FSD under self-representation, and entering an AI statement in DE 2/2 to indicate self-representation is used ('00500-importer' for imports and '00400-exporter' for exports).