Pre- and post-clearance work: roles and responsibilities
When a trader is first authorised for CFSP, they are assigned to a virtual CFSP EPU which will identify the area in which the trader is authorised.
While the majority of post-clearance functions for CFSP traders are carried out by the CNAT in Leeds, there are functions and controls that are still carried out in the appropriate Business areas. These include control of NCTS movements, Notification of arrival and the processing of ‘prior notification of removal’ from warehouses/designated premises for EIDR traders.
The CNAT work exclusively on CFSP issues and were set up to carry out a range of centralised functions that had previously taken place in the Business areas. The team is responsible for controlling CFSP traders, including those within LB, and any work carried out by them will be with the full knowledge of the CRM and /or trader control team.
This work includes:
- Processing C79 VAT Certificate Adjustments, where an incorrect VAT number has been declared on the SD.
- Cancelling un-cleared entries where revenue has been incorrectly declared. Traders should notify the CNAT who will then action the request if appropriate.
- Dealing with queries regarding CMAs (Current Month Adjustment) - deferment adjustments where revenue has been incorrectly over or under declared. Requests themselves will be processed by NDRC.
- Receipt and notation of Voluntary Declarations where an under-payment has been made. Details are recorded and sent to the Central Processing Unit in Salford for action.
- Actioning substitute/amended SD entries. These are checked and authorised before being sent to the Central Processing Unit in Salford for processing.
- Checking timely and complete submission of supplementary declarations including the FSD. Trader compliance is monitored through MSS and any errors are queried.
- Verifying the arrival of goods under NCTs.
- MCD control and accounting action. MCDs are monitored and any monies are brought to account.
- Receipt and scrutiny of un-cleared entry prints. Reasons for un-cleared entries are investigated and resolved, either through bringing money to account, or by clearing the entry.
- SFD amendments/deletions. Requests are recorded locally and notifications sent to trader folder via CRM/LB tax specialist or CFO.
- Verifying that traders are not exceeding the allowed 20 days Temporary storage period.(90 days where UCC conditions apply)
- Initiating and carrying out any special projects at the request of Policy sections to monitor levels of compliance eg electronic licence over usage, controlled goods checks, route 3 checks.
- Querying electronic licences eg incorrect use, over-usage etc CHIEF can be adjusted to correct any licensing errors.
- Checking ADD registration through MSS. Database of relevant Commodity Codes and Countries of Origin is maintained, and MSS is scrutinised for any hits against certain Commodity Codes.
- Prior notification of late Supplementary Declarations (see CFSP06150).
National Duty Repayment Centre
The National Duty Repayment Centre (NDRC) is responsible for almost all repayments of Customs duties and, in some cases, VAT to the trade when an error has occurred with an importation of goods. Their main duties include:
- Processing of belated claims to preference, where the original GSP certificate or EUR1 certificate was not available at the time of shipment.
- Processing of belated claims to quota, where the quota number was not entered at the time of import.
- Processing of incorrect value claims, duplicate entry claims and other occasional claims.
- Checking duty repayment claims that were originally entered to the incorrect commodity code at the time of import or following a classification review.
- Dealing with amended entries that were made out to an incorrect CPC at the time of importation. Any trader requiring amendment to full OPR, IP, Warehousing or PCC must seek approval from their supervising office before the claim is submitted.
- Current Month Adjustments (CMAs) to entries where duty and/or VAT is paid on the importer’s and/or third party’s deferment account.
Central Processing Unit (CPU)
The CPU, based in Salford, consists of various teams carrying out specific functions as outlined below:
C18 Team - roles and responsibilities
- Processing of voluntary declarations where a substitute entry is necessary to correct errors, both monetary and non-monetary, made on a SD.
- Issuing C18 post-clearance demand notes.
- Issuing Customs Civil Penalty warning letter references and maintaining records of any Civil Penalties issued.
- Adjustment of Miscellaneous Cash Deposits (MCDs).
- Release of guarantees secured against potential revenue after goods have gained Customs clearance.
National Temporary Admissions Centre
- Recording of details onto a National database.
- Bringing to account all simplified TAs which are either cash deposits or guarantees.
- The supervising office for all simplified TA authorisation holders
- Controlling the goods whilst they are in the UK ensuring they are disposed of in an eligible way and within the required time limits
- Discharging TA security
- Identifying areas of non-compliance
National Clearance Hub (NCH)
All entries should be processed in accordance with the procedures set out in Guidance INCHP - Import and National Clearance Hub Procedures. This should include:
- that declarations have been signed and all necessary boxes required by the CPC have been completed
- ensure the requirement to provide security where indicated by the CPC has not be overridden
- liaising with UKBA to perform selected pre-clearance/post clearance checks triggered by CHIEF Profiles or CPCs
NCH will process declarations as above but more detailed post clearance checks should be carried out by the supervising office to ensure accuracy and validity of the entries made.
When NCH receive a CFSP substitute entry agreed by a supervising office and noted by the CNAT, the NCH should input the entry to CHIEF ensuring box 40 of the entry includes reference to the previous entry that is:
- cancelled because the previous entry is being invalidated or annulled, or
- amended to correct details on the previous C88 entry
When the entry has been input to CHIEF, NCH should send a stamped copy of the substitute entry to the authorisation holder, the Stats Office and to the supervising office.
Post clearance Amendments section (PCA)
PCA are responsible for CIE input to CHIEF of substitute C88 entries to amend details on an entry made where the details to be amended do not result in any monetary change. If there is a monetary change the NCH are responsible for the CIE input to CHIEF.
When PCA receive a CFSP substitute entry agreed by a supervising office and noted by the CNAT, PCA should:
- input the C88 entry to CHIEF ensuring box 40 of the entry includes reference to the C88 entry that is being amended; and
- send a stamped copy of the substitute C88 entry to the authorisation holder, the Stats Office and to the supervising office
Note: PCA will deal with trader queries relating to entries and where necessary consult with supervising offices but they are not responsible for:
- pre-acceptance checks of substitute entries
- checking the accuracy of declarations made, or
- investigating irregularities.
These points must be considered by the supervising office.