HMRC: CDS Data Element 2/3 Updates Revise Import/Export Codes

• HMRC has released significant updates to Data Element 2/3 of the Customs Declaration Service (CDS), affecting document codes for import and export licenses.
• Appendix 5C has seen numerous new codes added for both imports and exports, including specific codes for Export Health Certificates.
• Key changes include new codes for Northern Ireland to Ukraine exports and a restructuring of codes related to ammonium nitrate declarations.
• Several old document codes, such as 9005, C638, and C639, have been removed from use.
• The updates also reflect the establishment of the Department for Business, Innovation, Science and Trade (BIST).

Compliance officers and lawyers advising clients on UK import/export must thoroughly review these updated HMRC Customs Declaration Service (CDS) document codes, particularly for Appendix 5C, to ensure accurate declarations and avoid potential delays or penalties.

HMRC has issued significant updates to the Customs Declaration Service (CDS), specifically impacting Data Element 2/3, which governs document and other reference codes for government department licenses. These revisions are critical for businesses engaged in UK import and export activities, as they dictate the precise codes required for accurate declarations. The extensive changes to Appendix 5C, which lists these essential import and export codes, reflect ongoing adjustments to trade regulations.

Notably, the terminology used throughout the official documentation has been revised to acknowledge the establishment of the Department for Business and Trade (DBT), which was subsequently renamed in July 2026 to the Department for Business, Innovation, Science and Trade (BIST). This change signifies an evolving departmental oversight for various trade measures and underscores the dynamic nature of UK trade licence types changes.

The latest revisions introduce a substantial number of new Customs Declaration Service document codes across both import and export categories within Appendix 5C. For imports, new codes include L159, 9L51, L128, L129, L157, 9063, 9L49, L154, L149, L150, L151, L152, L153, L148, L146, L144, L838, and L143. On the export side, numerous codes have been added, such as X900, X803, X828, C105, X809, X867, X868, X866, X865, X844, X845, X847, X848, X849, X850, X851, X854, X855, X856, X857, X858, X843, X852, X853, X841, X842, X808, X805, X806, X807, X993, X838, X824, X832, X837, X840, X817, X819, X823, X830, X831, X834, X835, X836, X990, and X992.

A significant addition applicable to both imports and exports is code C809, while 9EHC has been specifically introduced for declaring Export Health Certificates, streamlining the process for certain goods. Conversely, some codes have been retired; document code 9005 is no longer utilized for declaring licenses and has been removed, alongside export codes C638 and C639. Furthermore, existing codes have undergone amendments, with 9112 seeing a change in its associated licence type for both import and export declarations, and X841 also being amended for exports.

Beyond general additions, specific regulatory areas have received targeted updates impacting UK trade licence types changes. A notable adjustment concerns the declaration of ammonium nitrate. Previously, various tariff measures related to ammonium nitrate were consolidated under document code 9103. However, government departments overseeing these measures have requested their separation, leading to a more granular approach.

As a result, a new document code, 9046, has been introduced to specifically cover the HSE Certificate of Exemption. While 9046 will eventually be distinct from 9103, which will then exclusively apply to the Detonation Resistance Test Certificate, the HSE Certificate of Exemption can still be declared using 9103 in the interim. Additionally, the online tariff system is being updated to automatically provide a document waiver for qualifying consignments, thereby eliminating the requirement to declare either 9103 or 9046 in such instances. Another specialized update is the introduction of document code X802, which is exclusively applicable to exports originating from Northern Ireland and destined for Ukraine, reflecting specific trade agreements or conditions for this route.

These extensive HMRC CDS Data Element 2/3 updates underscore the critical need for meticulous attention to detail in trade operations. Compliance officers and lawyers advising clients on UK import/export must thoroughly review these updated HMRC Customs Declaration Service (CDS) document codes, particularly for Appendix 5C, to ensure accurate declarations and avoid potential delays or penalties.

Specific attention should be paid to new codes for Export Health Certificates, Northern Ireland to Ukraine exports, and changes related to ammonium nitrate, as these directly impact declaration requirements and could lead to significant compliance issues if overlooked. Maintaining up-to-date knowledge of these Appendix 5C import export codes is essential for businesses to navigate the complexities of international trade regulations effectively and ensure seamless HMRC import export declarations.

Compliance officers and lawyers advising clients on UK import/export must review these updated HMRC Customs Declaration Service (CDS) document codes, particularly for Appendix 5C, to ensure accurate declarations and avoid potential delays or penalties. Specific attention should be paid to new codes for Export Health Certificates, Northern Ireland to Ukraine exports, and changes related to ammonium nitrate, as these directly impact declaration requirements.

Source: Original reporting via GOV.UK guidance