Supplementary Declarations (SDs): aggregation of SDs
CFSP traders can generate thousands of individual SDs per day resulting in a huge burden on both trade and departmental systems. It also causes difficulties for officers when auditing the trader. In order to reduce the number of SDs created, CFSP traders may use aggregation with both SDP and EIDR. Authorisation to use daily aggregation is not required.
Cell level (daily) aggregation
Traders may combine SDs, which contain exactly the same header and item level data into a single customs declaration. In essence, 20 separate removals from a Customs Warehouse of T-shirts imported from the same third country supplier for delivery to the same customer may be aggregated into a single SD. This removes the need for the trader to submit 20 identical declarations. Each removal must still be assigned a DUCR and be entered separately in the EIDR records. These DUCRs should be quoted in box 44 of the declaration as usual.
Aggregation across the tax point
Aggregation across a reporting period/the tax point is a further optional, facilitative measure for the trade that has been introduced to meet their operational/business needs.
Any traders wishing to operate aggregation across the tax point will need authorisation to do so from their authorising office/r. In order to operate aggregation across the tax point, additional criteria and conditions will need to be met.
As an example, where removals between the first of January and the tenth of January have been aggregated, the tax point shown on the declaration must be the tenth. Although the tax point under aggregation is shown as the last day of the period, traders must ensure that they have the valid supporting documentation (licences, Preference Certificates etc) available at the time the goods enter free circulation.
Any relevant licences should be valid when the tax point is created. CHIEF will accept the licences providing they are valid on this tax point date.
Where there are a large number of DUCRs being aggregated within one message the procedures detailed in CFSP06200 should be followed. Specific rules apply to the aggregation of data, these may be found in CFSP06450.
Conditions applicable to using aggregation across the reporting period/tax point
To allow aggregation across the tax point for both SDP and EIDR the traders must meet the following conditions:
- Traders must be able to demonstrate a robust audit trail to their authorising officers’ satisfaction prior to commencing aggregation across the tax point. This audit trail must be sufficient to show both the accumulation of declarations into the aggregated message and be able to break down an aggregated declaration for audit purposes.
- Traders must demonstrate their control/management procedures to the officers’ satisfaction for monitoring of duty rate/preference changes, rates of exchange discrepancies, ADD etc prior to commencing aggregation.
- The audit trail and monitoring procedures must be detailed in the applicants documented procedures prior to authorisation.
- Aggregated messages must not exceed 10 days worth of data and 3 Mb in size.
- Aggregated messages across the tax point must fulfil the SAD completion rules as detailed in CFSP06450.
- The tax point date shown on the aggregated message must be the last day in the aggregation period (but also see paragraph below).
- If any of the information changes (ie ADD, rates of exchange, duty rates) then a new message must be generated eg the aggregation period is from the first - tenth January. On the fifth January Anti Dumping Duty (ADD) is introduced to one of the commodity codes included in the message. The trader must then close down the period and submit the aggregated declaration for all releases from the first – fourth January. They will then need to start a new aggregated declaration from the fifth January.
If the officer is not satisfied that these conditions will be met then the trader must not be authorised to use aggregation across the tax point.
Applying a fixed rate of exchange to an aggregated declaration
Where a trader is authorised to aggregate their supplementary declarations across the tax point and has software that is capable of converting the invoice value of the goods into sterling, they may also apply under CCCIP Art. 172 to use a single (fixed) rate of exchange for the whole aggregation period.
A new declaration will not be required each time the rate of exchange for the period changes; however the following conditions will apply:
- A single rate of exchange must be used to convert all elements forming the customs value of the aggregated declaration into sterling.
- The exchange rate to be used will be the customs rate applicable on the first day of each aggregation period eg the 1st, 11th and 21st of each month.
- The single rate may not be varied during the aggregation period.
- The single rate must be used continuously unless there is a significant change to the traders business.
- The trader must contact the authorising office/officer before reverting to a flexible rate of exchange.
Further information can be found in CFSP Information paper 64 on the CFSP UoE webpage