5. Simplifications

Details the simplifications for Transit movements, how to apply for them and the authorisation process.

This section deals with the following simplifications for Transit movements, how to apply for them, and the authorisation process. This section also applies to simplifications available for CTC movements specific to UK, for Rail and Air movements and for NI only Regular Shipping Services.

5.1 How to apply for simplifications

A number of simplifications are available to traders who meet certain criteria.

The simplifications available are:

a) use of a comprehensive guarantee or guarantee waiver
b) use of a special loading list (for NCTS business continuity documents only)
c) use of seals of a special type
d) authorised consignor status (for CTC Transit)
e) authorised consignee status (for CTC Transit or TIR)
f) procedures specific to certain modes of transport (goods carried by rail, air, sea)
g) authorised issuer (for Proof of T2L Status declarations)
h) use of port inventory systems based on transfers within Temporary storage - for further guidance see Managing your Temporary Storage Facility

To apply for simplification (a), the applicant should complete application form CCG1 and send it to the Customs Comprehensive Guarantee Team (see information on how to Apply for a customs comprehensive guarantee to cover customs debts.

To complete form CCG1, you’ll need to make sure you’re using an up-to-date browser - find out more about browsers.

To apply for simplifications (b) to (f), the applicant must complete form C1343. Advice on how to complete the form can be obtained from the National Simplification Team at the CCTO.

To apply for (g) Authorised Issuer you need to follow the instructions as laid out in section 2.7.

To apply for use of port inventory systems, (h) above, your premises must be approved for Temporary Storage purposes (see Apply to operate a temporary storage facility).

A list of the legal provisions relating to each of the simplifications can be found in Annex 4.

5.2 Procedure for authorisation

To be eligible for authorisation, applicants will have to meet certain criteria and provide supporting evidence to the CCTO. Under CTC Article 62, ‘contracting parties’ can process applications within the time limit set by them. The time limits applicable in the UK are set out below. The CCTO has 30 days to decide whether the application is complete, and the conditions are met. The CCTO then has 120 days from receipt of a fully completed application in which to process it to a conclusion. To avoid any unnecessary delays, applicants are therefore advised to fully complete the form, referring to the explanatory text where necessary.

As part of the process for approving an application, customs may visit the applicant. The visiting officer will have received a copy of the application and a pre-authorisation checklist from the CCTO. UoE has produced an aide memoir to assist officers in carrying out visits to Transit traders. The visit will be documented, and the information retained in the trader’s folder. See section 5.4 for further information.

If an application is successful, the CCTO will issue the successful applicant with an authorisation letter, which will state the conditions of approval. Failure to comply with these conditions may result in the authorisation holder being subject to a civil penalty and/or the authorisation being amended or revoked.

This letter will include an authorisation Reference Number. This will identify the applicant simplification approval and should be quoted in any correspondence with the CCTO simplifications team.

If an application is rejected the CCTO will inform the applicant of the reasons in writing. Any applicant who does not agree with the decision to reject an application has the right of appeal.

For further information on the appeals procedure see Part 12.

5.3 Simplifications restricted to the UK

The criteria, conditions and procedures for the use of the simplifications are fully explained in the Transit Manual. This part concerns specifically the UK’s national simplifications.

5.3.1 National Transit simplifications

The UK has the following national simplified procedures in place:

movements between the UK and the Channel Islands
automated inventory procedures – CCS(UK), CNS and Destin8 (this is now referred to as transfer within Temporary Storage)
modernised unloading rules
simplified requirements for ships stores and spares

5.3.2 Movements between the UK and the Channel Islands

The Channel Islands are special territories that form part of the customs territory but not the fiscal territory of the UK. Goods arriving from the Channel Islands and remaining in the UK are liable to VAT and Excise duty but not customs duty or agricultural duties (if appropriate).

Import declarations are not required for Domestic goods moving solely between a port/airport in the United Kingdom and a port/airport in the Channel Islands in either direction, provided that the goods are cleared at the port/airport of arrival. Customs controls are exercised by reference to operators’ commercial records. This procedure operates mainly at three UK ports – Portsmouth, Poole and Weymouth.

The full CTC Transit procedure is required where goods are moving:

from one CTC country/EU Member State to another via the Channel Islands
from the Channel Islands to a CTC country/EU Member State via the UK or a CTC country/Member State
from a CTC country/EU Member State to the Channel Islands via the UK or a CTC country/Member State
between the Channel Islands and the United Kingdom when the goods are moved inland from a port or airport before a customs entry for payment of duties and taxes is made

The full Transit procedure is also required for Rest of World goods that are non-EU or CTC contracting country goods, moved from United Kingdom to Channel Islands without being imported into the UK.

Further information on this procedure may be obtained from customs at the relevant port/airport of departure.

Note that where goods are moving between the Channel Islands and the UK without going via a CTC country/EU Member State, CTC is not required.

5.3.3 Use of port/airport inventory systems

Electronic procedures have been developed through the local Community Systems Providers, CCS(UK), CNS and Destin8, which facilitate the transfer of goods within Temporary Storage. The procedure applies to goods not in free circulation, which have been directly imported into the UK from a third country or T1 goods from a CTC country. It is used for the removal of the goods from the temporary storage premises at the UK port/airport of arrival to a destination elsewhere in the UK that is also linked to the inventory system, either for entry or direct re-export.

For guidance, see Trade and commercial contacts for Community System Providers.

Further information on this procedure may be obtained from Customs/Border Force at the relevant port or airport.

If you are considering applying for a temporary storage approval, you must first contact the National Frontiers Approval Unit (NFAU) to register your interest by emailing nationalfrontierapprovalsunit@homeoffice.gov.uk.

5.4 Assurance of simplifications

5.4.1 Introduction

Goods moving under CTC Transit pose a revenue risk as the customs duty and other charges on them are suspended until they reach the Office of Destination. As the simplified CTC Transit procedures allow the authorisation holder to operate with reduced customs intervention/control, checks will be carried out to ensure that the trader is reliable, responsible and can meet their obligations.

5.4.2 Authorisation checks prior to approval to use simplified CTC Transit procedures

Traders will send their applications to the CCTO. The CCTO will in turn ask Local Compliance officers to undertake pre-authorisation checks on the applicants to confirm the details that are provided in the application form. To perform this task the officer may need to visit the applicant. The CCTO has 30 days to decide whether the application is complete, and the conditions are met. The CCTO has 120 days for receipt of a fully completed application in which to process it to a conclusion.

5.4.3 General pre-authorisation checks applicable to all applicants

Is the applicant established in the Customs territory of one of the CTC countries?
Has the applicant been checked in compliance with the general criteria (AEO standards) of TCTA 2018, S22?
Does the applicant understand the CTC Transit procedures and are they otherwise able to meet their obligations regarding the simplification applied for?
Will the applicant be able to comply with the conditions of the simplification applied for?
Is the applicant’s declared premises/location adequate for the purpose?
If the goods are of non-Domestic status, are the applicant’s premises/location approved to hold those goods such as a customs warehouse or temporary storage?
What is the nature of the goods that the applicant intends to move or receive? Are they sensitive goods? Should the applicant also apply to use seals of a special type? Any other government controls required (such as Defra, Licencing and so on)?
Has the applicant committed any serious or repeated offences against customs or tax legislation? Does the applicant have any outstanding convictions or County Court Judgements (CCJs) against them? Has any other offence action been taken against the applicant?
Does the applicant assist in resolving discrepancies?
Could customs supervise the procedure and carry out their controls without an unrealistic administrative effort? Are there any mitigations such as a complete audit trail from the Transit movement to the export/import declaration in the applicant’s records? Can individual transactions be traced?
How efficient is the applicant’s record keeping? Are the records complete and comprehensive? All documents should be made available to customs during an audit visit. These can include air waybills, shipping/sales invoices, packing lists, bills of lading, proof of payment) to check that the correct values have been declared and proof of status.
Have the applicant’s records been archived for the correct length of time? These would be 4 years for imports and exports, 6 years for VAT and excise and 2 years for Domestic status.
Does the applicant hold a comprehensive guarantee or guarantee waiver?

5.4.4 Pre-authorisation checks for a comprehensive guarantee or guarantee waiver

Customs will complete the general checks at section 5.4.3 plus those set out in the guidance on comprehensive guarantees.

The following are the Pre-authorisation checks that HMRC will carry out for an authorised consignor.

Customs will complete the checks as at section 5.4.3 and the guidance on guarantees plus the following checks below.

For NCTS software, check:

does the applicant maintain their own NCTS software or commercially available NCTS software or will they use the HMRC provided web declaration?
how robust is the applicant’s system? How often do they revert to business continuity procedures?

The locations listed in the application must:

be associated with an Office of Departure
be fit for the purposes of control
have a dedicated area for examination of the goods prior to release

Where an authorised consignor nominates the customs approved area of a port or airport as an authorised location there will not necessarily be a specific area or examination facilities for the authorised consignor’s goods. The goods will be handled the same as any other goods clearing through the (air)port.

Customs will also agree the following procedures with the applicant. These will form part of the authorisation:

arrangements for informing the Office of Departure of forthcoming CTC Transit operations and the location of the goods
duration of the automatic ‘time out’ period
the time limit within which the goods must be presented at destination

5.4.5 Pre-authorisation checks for an authorised consignee

Customs will perform the checks at section 5.4.3 plus the following:

For NCTS software, check:

does the applicant maintain their own NCTS software or commercially available NCTS software or will they be using the HMRC provided web declaration?
how robust is the applicant’s system?

The locations listed in the application must:

be associated with an Office of Destination
be fit for the purposes of unloading and control
have a dedicated area for examination of goods prior to release from Transit

The following procedures, agreed with the applicant, will form part of the authorisation:

the arrangements and time limit for making available or sending to the Office of Destination, the Transit Accompanying Document/List of Items TAD/LoI)
how and where the goods will be made available for examination by customs
the duration of the authorised consignee’s ‘time-out’ period
time-limit within which the authorised consignee must communicate the unloading remarks to customs electronically
the arrangements for the temporary storage of the goods received at the authorised locations and/or for fulfilling the legal obligation to subsequently assign them to a customs-approved treatment or use

HMRC will prescribe controls that the applicant must apply regarding:

damage to seals and other apparent external damage
any irregularities/discrepancies concerning the goods (such as substitution, misdeclaration, shortage and so on)
the format and content of the authorised consignee’s arrivals register (if required)
the type of goods excluded from the authorised consignee’s authorisation

For Transit operations covered by a business continuity document the arrangements and time limit for:

notifying the Office of Destination of the arrival of the goods
receiving the unloading permission, subsequent to notifying the Office of Destination of the arrival of the goods
return of the relevant copies of the documents with the unloading remarks

5.4.6 Authorised consignee simplification

If you are regularly importing goods using the Common Transit Convention for Great Britain, you can apply for authorised consignee status, which will allow you to end the movement of goods at your own premises rather than at an office of Destination.

As an authorised consignee you are able to:

receive goods without needing to present the goods and transit accompanying document to customs at the customs office
send your arrival notification message to the relevant office electronically
receive automatic permission to unload the goods (if the goods are not subject to further controls or inspections by the customs office)

Applying for authorised consignee status

You will need to have an approved temporary storage facility at the location where you would like to operate as an authorised consignee. The approved temporary storage location will need to be either:

an external temporary storage facility which allows you to store goods in your premises for up to 90 days
an authorised consignee temporary storage facility that allows you to store goods for up to 6 days

The approved temporary storage location can only be approved for one type of temporary storage facility. For example, you cannot operate an authorised consignee temporary storage facility and an external temporary storage facility at the same location. You may also need to apply for a customs comprehensive guarantee.

If the temporary storage facility is in Great Britain (England, Scotland and Wales), you will only need a customs comprehensive guarantee if HMRC tell you that one is needed after applying for authorisation.

If the temporary storage facility is in Northern Ireland, you’ll need to apply for a customs comprehensive guarantee. If you have Authorised Economic Operator (C) status, you’ll qualify for a 100% guarantee waiver. If you do not have Authorised Economic Operator (C) status, you can still qualify for up to a 100% waiver depending on your circumstances.

How to apply

You will need to follow the guidance for Applying for authorised consignor or consignee status.

If you are applying for an external temporary storage facility as part of your Authorised Consignee application, you will need to Apply to operate a temporary storage facility.

If you are applying for an Authorised Consignee Temporary Storage facility you will need to complete forms C1343 and C1343b.

If you want to add additional locations to an existing authorised consignee account download and complete form C1343d from the guidance on Apply to add a location to a consignor or consignee authorisation.

If your application for authorised consignee is successful

We must be able to supervise and monitor the temporary storage facility without having to introduce administrative arrangements that are out of proportion to the economic need involved. After you’ve been approved, you must continue to:

operate within the law
keep fully up to date with legislation
continue to comply with the terms and conditions of your approval

You’ll be allocated a freight location code. If you input your own entries, you must also get access to the Customs Declaration Service, see Subscribe to the Customs Declaration Service. The location code is different from the Authorisation reference number described in section 5.2.

If your application for authorised consignee is unsuccessful

If your application is unsuccessful and you still want to make declarations yourself, you will need to start or end transit movements at a customs office.

CCTO National Simplifications Team contact details

HM Revenue and Customs
National Simplifications Team
BT-CCTO
BX9 1EH

Phone number: 0300 322 7905 (select option 2)

Email: nationalsimplificationsteam@hmrc.gov.uk

5.4.7 Operating an authorised consignee temporary storage facility

When you can operate an authorised consignee temporary storage facility

If you are an authorised consignee, you can store goods at an authorised consignee temporary storage facility (after you have ended a transit movement) for up to 6 days, before you do any of the following:

release the goods into free circulation
re-export the goods
put the goods into another customs (non-transit) special procedure

An authorised consignee temporary storage facility does not require an inventory-linked system (a computerised system connected to a Community System Provider).

When you cannot operate an authorised consignee temporary storage facility

You cannot operate an authorised consignee temporary storage facility if any of the following apply:

you already offer external temporary storage as a service
you are bringing goods into the UK that are not ending a transit movement
you are moving goods that are not under transit to or from another temporary storage facility — this is known as ‘movements in temporary storage’
you are ending a goods movement under Transports Internationaux Routiers (TIR), which you can read about in the ’TIR Carnets’ section of the UK Trade Tariff - for example, if you have the same premises authorised for TIR and common transit then it will only be the goods ending under common transit that can use the authorised consignee temporary storage

How to end movements

There are 2 ways you can end transit movements at an authorised consignee temporary storage facility.

You can end the movement either:

when the goods have arrived, at the same time as an arrived (and accepted) import declaration that covers the goods on the Transit Accompanying Document
by moving the goods to the authorised consignee temporary storage facility, even if an arrived import declaration is not available when the goods arrive

If an arrived import declaration is unavailable, the Transit Accompanying Document serves as the temporary storage declaration. You must keep this in your temporary storage stock account records.

Individual consignments on the Transit Accompanying Document will need separate temporary storage declarations. Each import declaration for the onward movement of the goods (for example, in free circulation) will need to be submitted within 6 days of the transit goods entering temporary storage.

What conditions you’ll need to meet

To end transit movements in an authorised consignee temporary storage facility, you must meet certain conditions.

Your authorised consignee temporary storage facility must:

only keep goods for up to 6 days after the transit movement has ended — if you think they will be kept for longer, you should advise the relevant office of the CCTO by emailing either:
be marked internally and externally so your goods can be easily found — all other goods arriving, leaving or being stored that are not subject to temporary storage controls should also be easily identifiable
not be:
- used for the purposes of retail sales
- an external temporary storage facility
- an internal temporary storage facility

You must also:

contact the Simplifications Team by emailing nationalsimplifications.ccto@hmrc.gov.uk if you make a change to your approved area or move your facility
maintain a record of when you use your ullage cage (a secure lockable facility for seized or detained goods which has restricted access) and provide this to your local HMRC or Border Force officer when asked - you may be asked by your local officer to have an extra cage for the storage of valuable cargo

You’ll also need to follow the same rules as you would for operating an external temporary storage facility for:

Site facilities

Your facility must:

have parking areas for vehicles under the control of HMRC or Border Force officers
have furnished office accommodation to make sure interviews carried out by officers can be conducted
have basic amenities (for example, lavatory facilities, electricity, gas, water and drainage)
be clean, clear of waste, well lit, ventilated, at an adequate temperature and in a state of repair reflecting fair use
have professionally calibrated weighing machinery capable of measuring the tare, net and gross weights of goods and their packaging

Storing goods that are not banned or restricted

Your facility must be located in an appropriate place and be the right size for the goods you wish to store. There must be a separate area for hazardous goods if you plan to allow them at your facility.

There must also be space for:

officers to unload, examine and count goods properly, both without and with any specialised equipment
officers to examine vehicles properly, both without and with any specialised equipment
goods to be stored securely that are subject to investigation by HMRC - you must have a secure lockable facility for seized or detained goods which has restricted access

Storing banned or restricted goods

You must tell customs authorities immediately when you find any:

banned goods
goods that you’re suspicious about
goods not listed on a Transit Accompanying Document

You must provide a secure area or lockable compartment within your authorised consignee temporary storage facility to keep any prohibited or restricted goods you discover during unloading.

Goods not listed on a Transit Accompanying Document must also stay there until the paperwork supporting the goods being in the UK arrives.

You can check if goods are prohibited or restricted using the UK Trade Tariff import prohibitions and restrictions or email the tariff classification service at classification.enquiries@hmrc.gov.uk.

You must not store goods that are not in temporary storage within your approved authorised consignee temporary storage facility, unless approved by HMRC.

You must also make sure that all poisonous and hazardous or dangerous goods are clearly marked and are separated from all other goods in your premises.

Removing goods from your facility

You must make sure that goods are not removed from the approved area until the goods have been declared and released by customs and clearance has been given. You can do this through either:

applying to remove goods from a transit shed
making a Customs Declaration Service (CDS) declaration, with an equivalent print for goods declared through the Customs Declaration Service — this could be documents attached to an email sent from the declarant, or manual storage of a printed copy
presenting a Transit Accompanying Document for onward transit movements

You must make sure that all customs cleared goods are removed from the temporary storage designated area of your premises within 3 days of the date of customs clearance. The goods can be moved to an appropriate area within your facility whilst awaiting pick up for onward delivery.

If requested, you will need to provide your UK customs authority control officer with a written explanation about why goods have not been removed from the temporary storage area of your facility within 3 days or another agreed time limit.

Destroying goods

If you need to destroy any goods (for example, if they’re damaged or out of date) you should write to your supervising office giving details of the:

goods
intended place and the way you’re going to destroy them
reason you’re destroying them

Your supervising office will tell if you need to do it under customs (or other authority) control, and whether they’ll attend. There’ll be no liability to a customs debt if you’ve destroyed the goods.

You’ll need to keep evidence and a C21 form audit trail on the temporary storage stock account record for the goods.

Records you’ll need to keep

You’ll need to keep records for a minimum of 4 years of:

the date and details of goods and their description including:
- identifying numbers
- the amount and kind of packages
- the identification marks of the container necessary to identify the goods
- if the goods are domestic or chargeable goods
any customs documents about the goods stored
the location of the goods including their storage position inside the facility
any handling of the goods while they are in the facility, including details of any handling needed to preserve the goods
any movement of the goods into or out of the facility, including the times and dates of the arrival and departure, the name and address of the person receiving or taking the goods and the time and the date the recipient receives the goods
the Transit Accompanying Document (which will serve as the temporary storage declaration) for any goods stored in the facility
the customs procedure into which any goods stored in the facility are released
the master reference number of the transit procedure
the unique consignment reference for the declaration to the customs procedure, and evidence that the declaration has been cleared (for example, confirmation of an equivalent print for goods declared through the Customs Declaration Service — this could be documents attached to an email sent from the declarant, or manual storage of a printed copy)

If you want to change the type of facility you operate

If you already operate a temporary storage facility, and you want to change that facility to an authorised consignee temporary storage facility, you’ll need to:

email the Border Force National Frontier Approvals Unit at nationalfrontierapprovalsunit@homeoffice.gov.uk asking them to withdraw your temporary storage facility approval
make sure your temporary storage facility approval is in the process of being withdrawn, because your authorised consignee temporary storage facility cannot be approved before this
email nationalsimplifications.ccto@hmrc.gov.uk who will send you the form for applying to operate an authorised consignee temporary storage facility

Border Force will check that there are not any:

outstanding liability issues about historical outstanding inventory records
liability issues from uncleared goods still in the temporary storage facility
seized or detained goods in your temporary storage facility

5.4.8 Pre-authorisation checks for air/sea simplified procedures

Air Simplified procedures

The simplified procedures for air traffic cannot be used for goods consigned from an inland CTC Transit Office of Departure or travelling inland beyond the airport of destination.

The CCTO will also undertake a consultation procedure which involves sending copies of each application to customs in the Other CTC countries in which the airline operates. If an airline based in another CTC country also operates in the UK, national customs in that country will send copies of the applications to the UK so that we can carry out checks on the company’s national representative. Applicants are required to provide a comprehensive list of all airports of departure and destination to facilitate the consultation process.

Customs in the other CTC country have up to 45 days in which to carry out their enquiries. They must respond within this deadline in order that the CCTO can issue the authorisation within the overall deadline.

Customs in the UK must reply to queries from OMS in sufficient time for customs in the OMS to meet their deadline.

Sea Simplified Procedure for NI ports only

Only shipping companies that operate a ‘Regular Shipping Service’ can apply for approval to use the maritime simplified procedures. The maritime simplification is restricted to ports within the EU and vessels may not make any calls at ports outside this territory or at any free zone in a Union port. See the EU Transit Manual Part II, (status of goods) Paragraph 4.2.1 Definition of a regular Shipping Service for a definition of the procedure.

From 31 December 2020 ports in GB were no longer in the EU and the Sea Simplified procedure cannot be used for routes that call at those ports.

For NI only: For Transit purposes, ports in NI will be regarded as being in the EU. Routes that call at NI ports (but not GB ports) can use the Sea Simplified procedure and the sections of the following paragraphs that refer to shipping lines will apply.

For both Air and Sea simplifications

Customs will perform the general checks at section 5.4.3 plus the following:

Does the airline/shipping company operate a significant number of flights /sailings between the (air)ports (in common Transit countries) named in the application?
Does the airline/ shipping company undertake to become the holder of the CTC Transit procedure and become completely accountable to the customs authorities in meeting its obligations and accounting for and resolving all discrepancies and irregularities?
Who will be the representative of the airline/ shipping company? For example, confirm where they are based outside the UK.
Where will the goods be controlled? Is the location fit for the purpose? Where the airline /shipping company has applied to use the Electronic Transport Document, the use of electronic manifest transmission is a condition of approval for the simplified procedures. Customs must satisfy themselves that the system is reliable/secure (the system must be tested before approval can be granted).
Does the electronic manifest contain the correct information? See the Transit Manual Supplement: Electronic Transport Document manifest data. Please note they must demonstrate that they are able to correctly declare the status of the goods as per TM Part VI Sections 3.9.4.1 and 3.10.4.1.
Will prints/copies of the manifests be made available to customs at departure and destination when required? Please note they must be able to demonstrate that this will be the same document throughout the movement.
Does the airline /shipping company readily notify customs of any irregularities or discrepancies found when using customs procedures? Does it assist in resolving any anomalies found?
The application must include a screenshot of a manifest. This must be overwritten to show where the required data is placed.
The applicant must tell us what data it is impossible for them to supply. If several traders report this problem, HMRC may be able to resolve the issue.

The extent of the checks at any particular airport/port will depend upon the operation carried out there. If the airport/port is the airline/shipping company’s main operational base, customs will fully examine the systems to be used. At a subsidiary airport/port the checks may be confined to matters concerning local control.

Refer to the Transit Manual Supplement: Electronic Transport Document manifest data.

5.5 Post authorisation assurance

Once a trader has been authorised to use a Transit simplification, customs may visit the authorisation holder to ensure that they are complying with the conditions of their authorisation.

5.5.1 General assurance checks for simplifications

General assurance checks may include the following.

Does the authorisation holder understand their responsibilities such as do they understand the conditions of their authorisation and are they aware of the Transit Manual (EU Guidance and the UK Supplement to the Transit Manual)?
Does the electronic manifest contain the correct information? See the Transit Manual Supplement: Electronic Transport Document manifest data. Are manifests completed correctly in accordance with the authorisation conditions?
Does the authorisation holder’s system adequately identify the goods dispatched, received and handled?
Are the goods assigned in a proper manner?
Are revenue accounting requirements complied with? Does the authorisation holder calculate and declare all customs duties, VAT and other duties and charges correctly and in a timely manner?
Does the authorisation holder identify any errors, irregularities and underpayments and bring any amounts due to account correctly and in a timely manner?
Has the authorisation holder ever failed to comply with any of the other conditions of authorisation not covered by the above questions and do they still comply with the required conditions for their authorisation? Confirm there have been no changes or factors arising that may affect this, or they had not previously informed HMRC of or do not meet requirements due to change in legislation.

5.5.2 During assurance visits

During an assurance visit customs may:

confirm that the authorisation holder’s details are correct and ensure that the authorised locations is/are consistent with the declared business activities
address any risks that customs have identified via previous assurance visit reports, from sifted information and movement data
address any risks identified during the visit
review the authorisation holder’s records - an audit trail should be evident from the CTC Transit declaration through to any associated import invoices, packing lists or evidence of goods entering a customs procedure
request details of any consignments that are still at the authorisation holder’s authorised locations and select some for examination to confirm that the goods, quantities and origins are as stated
address any educational and advice requirements
discuss any findings with the authorisation holder and issue a letter confirming completion of the visit. The letter should include any audit recommendations that customs have made. The authorisation holder will be asked to sign a copy of the letter confirming receipt of the letter and acceptance of the recommendations made therein.

Results will be recorded on the customs central database. These will be used as part of the authorisation holder’s compliance record to inform risk on future assurance visits.

On the next visit customs will check the authorisation holder’s records/data held to ensure that any previous recommendations made have been implemented.

In addition to visits by assurance officers, authorisations to use comprehensive guarantees are reviewed regularly by the Central Guarantee Team at the CCTO to ensure that the guarantee amount is adequate.

5.5.3 Non-compliance with the conditions of an authorisation to use a simplification

Authorisation holders must inform the CCTO of any factor that arises that could influence the continuation or content of the authorisation. If customs establish that the authorisation holder is not complying with a condition of authorisation, HMRC will take appropriate action in accordance with section 8 of this guidance.

In serious or repeated cases of non-compliance a visiting officer may also recommend to the CCTO that the authorisation be revoked or amended. The CCTO will inform the authorisation holder in writing of HMRC’s intention to revoke or amend an authorisation stating the reasons and giving the authorisation holder a period of 30 days in which to provide further evidence or arguments that could change the decision. Where no valid evidence or arguments are provided, the CCTO will then issue the decision stating the date from which it will take effect. In exceptional cases where the authorisation holder’s legitimate interests may be endangered, the date of revocation or amendment may be postponed.

5.6 Controls on CTC Transit simplified manifest procedures for goods transported by air/sea

5.6.1 Aims

Customs’ aim is to ensure that:

all non-Domestic goods have been properly accounted for
the Customs status of Union and Domestic goods has been correctly declared

5.6.2 Responsibility

Ultimate responsibility for control of the simplified procedures rests with the customs office at the designated airport of departure/destination although much of the work in the UK has been centralised at the CCTO.

Where it is considered appropriate for a local office to visit the authorised airline or shipping company (for example, where records are held at the airline ’s head office), the local office should request any relevant documents or information from Border Force at the airport of departure/destination.

5.6.3 Frequency of assurance visits

Visits should be made based on local risk assessment. They should also be made reasonably soon after authorisation in order to obtain early assurance of reliability and accuracy of status indicators. Declarations that goods have ‘Domestic’ Customs status can be checked mainly by reference to commercial evidence held in the airline’s records and selectively by verification at the office of the agent/exporter. Acceptable evidence of Customs status of Domestic goods held by the airline/shipping company may include a statement, signed by a responsible officer of the consignor, that all goods are of Domestic status unless otherwise indicated.

5.6.4 Risks/considerations associated with the use of Proof of Customs Status simplified manifest procedures

These include:

non-Domestic (or for NI only non-Union) goods arriving at the (air)port of departure not declared on the airline/shipping line manifest as non-Domestic (or T1)
incorrect or irregular attribution of status of; for example, T1, ex warehouse or IPR goods
transhipment goods not ‘exported’
transhipped goods entering system as ‘C’ or Domestic status
third country goods declared as ‘C’ or Domestic status
un-manifested non-Domestic goods
corruption of data on the manifest
crossings out on the manifest
computer systems defaulting to ‘C’ or Domestic status
how information on status is made available to the airline by regular exporters/agents
type of goods and routing of traffic
amount of revenue at risk
goods arriving at destination - information not transferred to appropriate documentation and identified to customs so that controls can be maintained such as not entered to another customs regime or free circulation
airline/shipping line’s system flawed (computer or manual)
degree of automation/manual involvement, including procedures for transferring data from airline/shipping line’s system to CSPs

5.6.5 Controls at departure – air / (and for NI only sea) manifests

Copies of the simplified procedure manifest must be made available by the airline/shipping line on request.

Customs may examine the goods or ask to see the air waybills/bills of lading relating the consignments listed on the manifest.

Request for post-clearance verification of manifests sent to Customs at the airport of departure

As stated in the Transit Manual Part VI, Sections 3.6.2.3, using the paper based common/union transit procedure for goods by air and section 3.9.4.2 for an electronic transport document as a transit declaration. The customs authorities at the port/airport of destination can, if necessary, send details of simplified procedure manifests to the customs authorities at the port/airport of departure for verification (for example, that the manifest at departure contained the same information as the manifest presented at destination). In the UK it will, in practice, be HMRC control officers who will select manifests for verification during assurance activities, rather than Border Force officers at the port/airport. Where HMRC officers consider it appropriate to request a verification this can be done by sending a copy or an extract of the simplified procedure manifest to the CCTO together with the post clearance request form TC21A. A specimen of this form can be found in the Transit Manual Part VII 8.6.

Request for post-clearance verification of manifests received from Customs at the airport of destination

Where customs at the port/airport of destination in an EU Member State or common Transit country request post-clearance verification of simplified procedure manifest details for movements commencing at a port/airport in the UK, they will send a request on Form TC21A to the CCTO at Salford. The CCTO will forward the request to the relevant HMRC control office for the airline/shipping company concerned for action and return of the completed TC21A (via the CCTO) within the required deadline.

The control office will verify the manifest details mainly by reference to the commercial records held by the authorised airline/shipping company and selectively by verification at the office of the agent/exporter.

Irregularities notified by airport of destination

Where the CCTO is notified by the airport of destination of any irregularities/discrepancies identified they will initiate the enquiry procedure described in part VII of the Transit Manual, discharge of the transit procedure and the enquiry procedure.

5.6.6 Controls at airport of destination – air (and, for NI only maritime) simplifications

The airline/shipping company must present the goods and make the electronic manifest available to customs at the (air)port of destination in order to end the Transit procedure. Customs may examine the goods or ask to see the associated air waybills/goods manifests/bill of lading for the goods listed on the manifest. Customs will also need to be satisfied that any T1 or T2 (non-domestic) status goods have been entered to another customs approved treatment or use and any T2F (special territory) status goods have had the import VAT correctly accounted for before allowing the goods to be removed.

The airline /shipping company must also inform customs as soon as possible of any offences or irregularities. In the UK the airline/shipping company has to notify these offences or irregularities to the CCTO at Salford who will inform customs at the (air)port of departure and the authority which issued the simplified procedure authorisation. The CCTO will also initiate appropriate action, including recovery of any customs debts, for offences or irregularities established as having taking place in the UK.

Actions by Customs at destination: post clearance verification of simplified procedure manifests sent to Customs at the airport/port of departure

The customs authorities at the port/airport of destination can, if necessary, send details of simplified procedure manifests to the customs authorities at the port/airport of departure for verification (for example, that the manifest at departure contained the same information as the manifest presented at destination).

In the UK it will, in practice, be HMRC control officers who will select manifests for verification during assurance activities, rather than Border Force officers at the airport. Where HMRC officers consider it appropriate to request a verification this can be done by sending a copy or an extract of the simplified procedure manifest to the CCTO together with Form TC21A (specimen of post clearance request found in Annex 8.6 Part VII of the Transit Manual).

Introduction of digital manifests: transitional requirements

The Air and Sea level 1 (paper based) simplification will cease once the airline/shipping company has IT systems in place.

Current authorisations can continue to be used until the airline/shipping line is re-assessed.

An airline/shipping company currently using a mix of electronic and paper simplifications should migrate to an electronic system as soon as possible. (This will trigger a re-authorisation which will include AEO criteria). The electronic system already in use must be continued to be used.

Where an electronic system is currently being used, if the data elements for the electronic transport document differ, businesses have until or re-assessment to add these to their systems.

5.7 The Reduced Data Set Simplified Procedure

For information only:

The European Commission intends to introduce a reduced data set simplification. This is built into the updated version of NCTS. This will apply in all CTC countries. This is an electronic procedure, based on reduced data requirements for NCTS declarations.

The procedure is intended to be used for rail, sea and air traffic. It will replace the existing paper-based rail, air or maritime simplified procedures. The procedure will allow declarants to submit NCTS declarations with a reduced data set and is less burdensome than the paper-based procedures. However, the maritime simplified procedure only applies in NI and cannot be used for routes that call at British ports.

The approved operators will have to be approved as authorised consignors and consignees.

Further information will be provided when it becomes available.

5.8 The simplified procedure for goods carried by rail

5.8.1 Introduction

The CTC Transit procedure using NCTS can be used for rail traffic. The main difference is that trains do not need to stop at offices of Transit upon entry to UK.

This section explains how the CTC Transit procedures can be simplified for goods moved by rail. This procedure makes use of the railways’ own commercial system for the control of movement of consignments carried by rail and accounting for carriage charges.

Further information about the carriage of goods by rail can be obtained from the rail operator in any common Transit country.

5.8.2 COTIF and SMGS International Conventions

The railways’ system is established by the International Convention concerning the Carriage of Goods by Rail (COTIF) and known as the ‘COTIF Convention’. This is supervised by the OTIF Intergovernmental Organisation. There are currently 47 member states of OTIF, including all the EU member states except for Cyprus and Malta and all the common Transit countries except for Iceland - see the OTIF website’s full list of members.

The SMGS Convention is a similar agreement for Eastern Europe and Western Asia.

The rail simplified procedure can only be used by two or more national rail operators sending goods to each other as part of an interconnecting chain. Individual rail operators sending goods across international frontiers cannot use the simplified Transit procedures. An operator who wishes to use the simplified procedure for a consignment has to expressly apply for it by completing the CIM and entering their identifying code.

5.8.3 Conditions for use of the simplified procedure for rail traffic

The general procedure for authorisation described in section 5.2 is extended to the rail simplified procedure. In addition, traders using the simplified procedure must:

use the CIM consignment note
cooperate with the other railway undertakings concerned; the goods are successively taken over and carried by different railway undertakings which are jointly liable to customs
establish a procedure for separate settlement of costs based on information to be held available per connection and per month
use a commonly agreed system to check and investigate irregularities of consignments which have been settled/not settled in the prescribed period by the central accounting offices of the railway undertakings
allow access by the customs authorities to its central accounting office

Rail operators who wish to use the rail simplified procedure must submit a declaration to the Community of European Railway and Infrastructure Companies (CER), who will inform the European Commission.

5.8.4 Key features of the rail simplified procedure

If the rail operator is sending goods outside the CTC area, they must use the Consignment Note (CIM) or the combined consignment note CIM/SMGS in place of a standard NCTS declaration.
The rail operator, in the sending EU member state or common Transit country acts as the holder of the procedure and becomes responsible for the goods.
A CTC Transit guarantee is not required (the UCC Transitional arrangements provide an exemption for rail traffic).
The appropriate customs administration seeks recovery of revenue from its own railway operator in the case of irregularity.
Rail operators are required to make the records held at their accounting offices available for customs control purposes.

5.8.5 Cross referencing between standard CTC Transit declarations and the consignment note CIM

Where the standard (NCTS or business continuity) procedure is used for goods carried by rail, the declarant must indicate the NCTS MRN or business continuity declaration number, office of issue, date and status on the associated consignment note CIM in the box reserved for particulars of accompanying documents.

In addition, the railway operator responsible for the last railway station involved in the CTC Transit operation must authenticate the consignment note CIM after ascertaining that the transport of the goods is covered by the Transit declaration referred to on the Consignment Note CIM.

5.8.6 Rail Transit operations beginning and/or ending outside the EU/common Transit countries

The rail simplified procedure is operative for that part of the journey which takes place within the EU and/or common Transit countries. The customs office for the frontier station at the point where the goods enter or leave the EU/common Transit country will act as the Office of Departure/destination. For movements starting outside the EU/common Transit countries no formalities are required to be carried out at the Office of Departure. For movements ending outside the EU/common Transit countries no formalities are required to be carried out at the Office of Destination.

All operations starting outside the EU moving under the CTC Transit procedure are regarded as external (T1) status goods unless proof of the Union status of the goods is provided.

5.8.7 Rail operator’s responsibility

As holder of the Transit procedure, the railway operator accepts responsibility for the proper completion of the Transit operation and for any customs duty and other charges which may become payable in the event of any irregularity. Contact with the rail operator should be made through the appropriate Customer Relationship Manager (CRM).

The railway operator must ensure that consignments carried under a CTC Transit procedure are identified by a label or stamp (in green ink) bearing a pictogram, an example of which is shown in Annex VIII to appendix III of the Common Transit Convention. The label or stamp must be attached to both the Consignment Note CIM and to the relevant rail wagon (in the case of a full load) or, in other cases, to the package or packages.

The rail operator ‘applies’ to use the rail simplified procedure by ticking the ‘yes’ box and entering the code for the holder of the procedure in box 58b of the CIM (or box 66b of the combined CIM/SMGS consignment note).

Where the railway undertaking has received a waiver from the obligation to present the CIM consignment note and the goods at the customs Office of Departure, they shall clearly enter in the box reserved for customs on sheets 1, 2, and 3 of the CIM consignment note the codes ‘T1’, ‘T2’, or ‘T2F’, as appropriate.

5.8.8 Force of Law

The relevant Force of Law comes from these Customs Statutory Instruments.

5.8.9 Goods moving under cover of TIR or ATA carnets or NATO form 302 procedures

Transit operations under cover of these documents are suspended during any part of the journey for which the rail simplified procedure is used.

5.8.10 Procedures at the Office of Departure

For movements starting within the EU or common Transit countries the goods and Consignment Note CIM must be produced at the Office of Departure prior to the start of the movement. Any special endorsements prescribed by EU provisions must be inserted on the Consignment Note CIM or declaration.

Checks carried out by the customs Office of Departure will include confirming that the pictogram label or stamp has been applied to the Consignment Note CIM and rail wagon or packages.

The rail operator applies seals which are accepted for customs purposes.

Where the rail operator has ‘applied’ to use the rail simplified procedure by ticking the ‘yes’ box in box 58b of the CIM, all the goods are assumed to be of T1 status. If any of the goods are of T2 status, the rail operator must note the CIM accordingly and ask customs at the Office of Departure to annotate the document.

5.8.11 Changing the destination of the goods after handing them to the rail operator: modifications to contract of carriage

A consignor or consignee may, while the goods are en route, request diversion to a new destination. The rail operator will get permission from customs at the Office of Departure if it is needed.

Where the rail operator notifies a UK Office of Departure, customs will normally allow modifications provided all conditions relevant to the new destination (for example, export licenses are produced) have been complied with and exportation of the goods to the country requested is not prohibited.

5.8.12 T2 goods accepted by a rail operator for shipment to an EU country

The freight operator can, upon presentation of suitable evidence, ask a customs officer to sign a proof of Union Status.

No formalities are required to be carried out at the Office of Destination but the railway company in the member state of destination must make all the NCTS declarations or Consignment Note CIMs available for control purposes, if required.

5.8.13 Despatch of Agricultural goods under the simplified procedures

For further information, see Importing certain agricultural goods and food from outside the UK.

5.8.14 Measures to be taken where railway wagons are detached or the train is split up

The railway operator must report the details to the customs office responsible for the location where the railway wagon is detached, or the train split up. The railway operator should also inform customs of its intentions regarding the goods so that customs may take appropriate action.

5.8.15 Scope of the standard CTC Transit procedure and the simplified procedure

Where the standard (NCTS) CTC Transit is used for goods carried by rail, the label or stamp displaying the pictogram must be applied to the rail wagon or packages and to the Consignment Note CIM. The declarant must indicate the MRN, office of issue, date and status on the associated Consignment Note CIM in the box reserved for particulars of accompanying documents. The railway operator responsible for the last railway station involved in the CTC Transit operation must authenticate the Consignment Note CTC Transit. The railway company is also required to make its records available to customs for control purposes.

5.8.16 Procedures at the Office of Destination

The customs office for the station of destination acts as the Office of Destination.

Except for those cases where formalities are not required at the Office of Destination the railway operator must present the NCTS declaration or Consignment Note CIM to customs at the Office of Destination. If satisfied, customs will end the Transit movement.

Where goods are cleared at an intermediate station, the office for that station acts as the Office of Destination. This procedure cannot be used for goods subject to excise duty.

5.8.17 Combined road-rail transport

The regular (NCTS) procedure may be used for the carriage of goods where at the same time the conditions of the simplified rail Transit procedure are met. This applies in the main for the combined road-rail transport. Further information can be found in Article 106 Scope of the standard procedures for combined road/rail transport.

5.8.18 Resolution of irregularities

Customs will take appropriate action to resolve any irregularities notified by the railway operator or identified during control checks, including recovery of any customs debts due.

5.8.19 Authorised Consignors and Consignees

Where the CIM is completed by an authorised consignor, they shall ensure that the form bears the appropriate ‘T1’, ‘T2’ or ‘T2F’ codes, as applicable.

Where goods are intended for an authorised consignee, the railway operator may deliver sheets 2 and 3 of the CIM direct to the Office of Destination.

5.8.20 Temporary storage premises

Goods traveling by rail must be delivered to premises that have been approved for temporary storage.

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