Import/export: CHIEF extension applications and guidance

HMRC has provided an update to the Joint Customs Consultative Committee stakeholders on the temporary CHIEF extension, including closure of the application scheme to new requests, reconsideration requests for rejected applications, and guidance about providing reasons to HMRC in order to grant the extension. This may be of interest to taxpayers who import and/or export goods.

Stakeholder Update – CHIEF extension applications

On 20 September 2022, we announced an extension process where businesses could apply to use CHIEF for their import declarations for a short period of time beyond the 30 September deadline. The extension was in response to feedback from our trade partners and to provide a little extra time to those that needed it to complete the move of their import declarations to the Customs Declaration Service (CDS). We know many of our Trade Association partners welcomed this move. 

We plan to close this extension process to new applications on 31 October 2022. By this date everyone who asked for a one-month extension should be fully migrated to CDS. Declarants that applied for a longer extension will find out this week if they have been successful. 

Extensions beyond 31 October 2022 have been granted only in exceptional circumstances, such as the software developer not being ready and where the applicant provided HMRC with clear plans to show when the development will be completed and when they will start to use the new software. 

Where extensions have not been granted, declarants will be expected to make all their imports declarations on CDS. However, to accommodate import month-end activities these declarants will be able to continue to use
CHIEF until 7 November 2022 and they have been notified of this decision in writing. 

Those declarants whose extensions have not been granted can ask for that to be reconsidered by replying to the email notifying them of the decision and providing detailed plans that demonstrate the steps required to complete migration.  his plan will be expected to include detailed
milestones and dates, and demonstrate that the applicant is doing everything possible to quickly complete their migration. 

Guidance for providing further information for CHIEF applications 

Every decision on whether to grant a further extension to use CHIEF
is based on the specific circumstances presented so the examples below are intended to provide indicators of what a successful application might contain.   

General principles

1. The purpose of an extension is to give firms already actively engaged in migrating to CDS a little extra time to complete that work.  Firms should be able to show that they have been actively pursuing this aim e.g. by being active in TDR.
2. Firms are expected to prioritise their migration activity and demonstrate this in their applications for an extension – making every effort to complete migration as quickly as possible.   
3. Applicants granted an extension to facilitate some clients or scenarios are expected to use CHIEF only for those scenarios – every declaration that can be made on CDS should be made on CDS.  
4. If your client cannot register for CDS because of issues with their data held by HMRC, they are entitled to continue to use CHIEF until we resolve the issue.  Unless another reason applies, if you are an intermediary you are entitled to an extension to use CHIEF for those clients only. 
5. If your clients are able to register for CDS but have not done so or have done so but not completed a direct debit instruction, that is not a reasonable case to continue using CHIEF. 

Examples