Customs Supervised Export overview
Provides information on what a Customs Supervised Export is.
A Customs Supervised Export (CSE) is a Customs approval that approves a business’s premises to meet the Presentation requirement of the common export procedure. CSE is an export only approval and is not used for import declarations. CSE can be used to export goods in free-circulation or currently under a UK customs procedure.
The common export procedure is a four-step process which requires a declaration to be:
- lodged with HMRC
- presented to HMRC
- granted clearance for export by HMRC
- notified as exported to HMRC
The second step, presentation to HMRC, which is the act of legally making an export declaration to HMRC, usually includes both a Notification of Export, advising HMRC that the export declaration is being presented for export, and a requirement to make the goods available for physical examination at a Place of Presentation approved by HMRC, which is usually an approved border location.
A Notification of Export will prompt HMRC to issue a decision on whether the goods can be exported from the UK or not. HMRC’s decision will take the form of either clearance being granted to export the goods, also referred to as permission to progress (P2P), or the goods being held for a customs check, sometimes referred to as a Customs hold or NonP2P. The goods will need to remain at the Place of Presentation, regardless of whether a physical examination is required, until HMRC issue clearance to export.
At border locations approved for the Standard Export Model, presentation to HMRC always occurs at the approved border location. At border locations approved for the Arrived Export Model, presentation to HMRC will occur when the declaration is lodged with HMRC, and the goods do not physically have to be at a Place of Presentation. However, the goods must be presented to HMRC for physical examination if required and this will need to be an approved Place of Presentation. In most cases this will not be the approved border location, and the goods will need to be presented to HMRC at another approved Place of Presentation such as an Inland Border Facility or a Designated Export Place (DEP).
A CSE approval allows the business to make the Notification of Export and the goods available for physical examination at the business’s approved premises rather than at an approved border location, Inland Border Facility or DEP.
A CSE approval meets the presentation requirement of the common export procedure via the type of declaration lodged with HMRC. With the export declaration indicating that CSE is being used for the export and presenting the goods to HMRC at the CSE approval holders’ approved premises.
When CSE is used for an export, all initial customs check including both documentary and physical examination, will be conducted whilst the goods are held in Customs Control at the approved CSE premises, rather than at an approved border location.
When used for an export, CSE completes the first three steps of the common export procedure at the businesses approved premises, with a second presentation (known as re-arrival) and Notification of Export being made to HMRC at the approved border location where the goods will exit the UK. All goods presented to HMRC at a CSE premises can be subject to a second customs check at the border, sometimes referred to as a counter-substitution check, to ensure the goods remain as presented to HMRC at the CSE premises.
CSE used with a Standard Export Model border location
- lodgement of declaration
- presentation at CSE location
- customs check completed at CSE location
- re-arrived at border location
- possibility of secondary check
- notification of exit
CSE used with an Arrived Export Model border location (Goods Vehicle Movement System (GVMS) only)
- lodgement of declaration
- presentation at CSE location
- customs check completed at CSE location
- declaration added to Goods Movement Reference (GMR)
- P2P reconfirmed
- possibility of secondary check
- notification of exit
A CSE approval is not:
- a simplification of the requirements of the common export procedure, as in all circumstances its use at export increases the number of steps an exporter or declarant has to make to export goods from the UK
- an approval to lodge export declarations with HMRC - the ability of a UK established business to make export declarations is not authorised by HMRC and the only barrier to making an export declaration is usually holding a valid UK EORI number and having access to appropriate export declaration software
- an approval to lodge simplified or supplementary declarations with HMRC – although CSE can be used in conjunction with most of the export simplifications offered by HMRC under the Simplified Export Declaration Process (SEDP), the appropriate authorisation (where applicable) must also be held to use the simplification with CSE
- an approval to speed up Customs clearance or remove checks at export, instead CSE allows most documentary checks and physical examinations to be conducted at the CSE approved premises - for CSE approved businesses, this provides certainty in most cases that there will be no further delays at the border due to customs checks. However, as a counter-substitution check may also occur at an approved border location prior to exit from the UK, CSE movements are potentially subject to more checks than standard movements
- an approval to allow the consolidation of goods prior to export, although a CSE approved premises can be used for both physical consolidation and consolidation to a Master Unique Consignment Reference (MUCR), HMRC doesn’t authorise businesses for export consolidation meaning the premises would usually be permitted to undertake consolidation, prior to presentation to HMRC, even if a CSE approval was not held by the business
To use CSE at export the CSE approval holder must act as the declarant on the export declaration. This is because presentation to HMRC occurs when the declaration is lodged. Meaning the declarant is the party making the Notification of Export and therefore is legally responsible for acting on any instruction issued in response to the Notification of Export by HMRC, especially preventing any movement of the goods if required.
The CSE approval holder must own or have the legal right of access to the premises approved for CSE, such as a rental or lease agreement. As HMRC officers may need to routinely attend the premises the CSE approval holder must have the legal right to grant them access to both the premises and any goods presented to HMRC there.
CSE is permitted with all customs procedures and export simplifications, and allows any goods, including goods subject to licence at export, to be presented to HMRC at the approved CSE premises. However, the use of other customs procedures and simplifications with CSE, will require the relevant authorisation to be held either by the CSE approval holder or the exporter if they differ and hold the authorisation in their own name. The other authorisation or simplification must also state that it can be used in conjunction with CSE in the holder’s authorisation.
Goods cannot be presented to HMRC by a Master Unique Consignment Reference (MUCR) at a CSE premises as the Notification of Export is performed using individual export declarations (DUCRs). However, CSE declarations can be consolidated to a MUCR for re-presentation at non GVMS border locations. GVMS Goods Movement References (GMRs) are currently incompatible with MUCRs.
Goods presented at a CSE premises should not be re-presented at a DEP prior to a further re-presentation at an approved border location.
CSE and DEP approvals both allow a Notification of Export to be made at a business’ approved premises. However, at a CSE premises this is achieved via a declaration being submitted to CDS in an ‘arrived’ state. CSE approval holders must therefore always act as the declarant for goods presented at a CSE premises. CSE declarations should not be re-presented at a DEP location or vice versa.
CSE Approvals are covered by the following UK Legislation:
Customs (Import Duty) (EU Exit) Regulations 2018 – CIDEER
Regulation 85 – Application for Approval
Customs (Export) (EU Exit) Regulations 2019 – CEEER
- Regulation 40 – Obligation to make goods available for examination
- Regulation 41 – Control of goods
- Regulation 49 – Release to the common export procedure
- Regulation 51 – Notification of Export
- Regulation 59 – Application of Part 9 of CIDEER 2018
A business’s premises will be approved by HMRC under Regulation 59 of CEEER as an appropriate place for the examination of goods declared for export, for the purposes of CEEER Regulation 40(6A). The business will notify HMRC that the goods are available for examination by making a Notification of Export as per CEEER Regulation 51. The business will use their CSE approval to present goods to customs supervision and potential customs controls at their premises, as per CEEER Regulation 41, before they can be released for export, as per CEEER Regulation 49.
CSE Approvals are covered by the following Union Customs Code (UCC) Articles:
- Article 5(3) – customs controls
- Article 5(27) – customs supervision
- Article 5(33) – presentation to customs
- Article 158(3) – customs supervision of Union goods on export
- Articles 170 and 172 – presentation of goods following customs declaration (including export declarations)
- Article 194 – release of the goods (including for export)
A business’s premises will be approved as a place at which goods may be presented to HMRC when an export declaration is lodged, as per UCC Articles 170 and 5(33). The business will use their DEP approval to present goods at their premises, where they will be subject to customs supervision and available for customs controls from the time that the export declaration is accepted, as per UCC Article 158(3), before they can be released for export, as per UCC Article 194.