HMRC has confirmed a new declaration process will go live by the end of November which all businesses must be compliant with by February 2025.
The ‘G-form’ for processing a Declaration by Conduct will supersede Entry in Declarant’s Records (EIDR) or Simplified Declaration Procedure (SDP). From 1st March all goods must either have a G-Form or Full Declaration completed to travel between the UK and the UK Continental Shelf.
Businesses must be aware that there is a need to submit separate G-Forms for shipments involving multiple Economic Operators Registration and Identification (EORI) numbers. Mixed cargoes—those involving both owned and rental goods—will also require separate forms to be submitted for each EORI involved.
Gordon Matson, Director of LS Customs outlines some areas of consideration:
Waste treatment and legislation
One significant challenge is the treatment of offshore-generated waste. Under current legislation, waste cannot be classified under Returned Goods Relief (RGR) meaning it requires a full customs declaration, including a customs invoice and clearance before being released from the quayside. Any change to this would require new legislation, which HMRC has indicated is not likely in the near future.
Quayside and storage considerations
Goods transported under Declaration by Conduct may be temporarily offloaded to quayside areas, provided there is a designated storage facility such as at Aberdeen. In locations without temporary storage, goods must be cleared before disembarkation. This is a key operational consideration for businesses depending on the specific port facilities they use.
Liability and compliance
Liability for declaration errors will fall to the EORI holder, much like in standard import and export practices. HMRC has stated it will adopt a pragmatic approach when errors are discovered, tracing responsibility through the chain of supply. However, it expects that any liability transfer will be managed through supply chain contracts, rather than HMRC-issued guidance.
Compliance expectations and record keeping
Previously established requirements remain in place, these are:
- Proof when claiming RGR, including a full audit trail, is essential.
- Businesses must maintain records including HS codes, country of origin, value, and other key details for goods handled via Declaration by Conduct.
- If there is no proof of RGR on import, a full declaration will be required with all standard customs information.
- Licensable and excisable goods, as well as goods released from Customs Warehouses or under Inward Processing Relief (IPR), will still need a full declaration.
- Exports under Authorised Use can be handled with Declaration by Conduct but will require a full Bill of Discharge.
Preparing for full compliance
With the new regulations set to be fully in place by February 2025, businesses must begin the process of mapping their customs processes and ensuring that all necessary records are in place as soon as possible. This is particularly important for those handling mixed cargoes or goods that may be subject to specific declarations, such as licensable goods, excisable items, or waste materials.
LS Customs offers industry-leading support and advice which will ensure you are fully compliant by the deadline. Contact us today for expert guidance on managing your customs obligations and optimising your UKCS operations.
