Customs Process Updates from the UKCS
Following our recent guest blog from Graeme Rafferty of Offshore Energies UK (OEUK), there has been a further update on the future customs process for movements to and from the UK Continental Shelf (UKCS).
On 10 and 12 August, HMRC held engagement sessions with industry to share potential improvements to the current UKCS declaration process and, importantly, gather feedback from those actually managing these movements in practice.
What could change from the current customs process?
Two potential approaches were discussed.
- The first is an enhanced G Form, which could allow one submission to cover an entire vessel movement, including multiple importers, exporters and consignments. This would mean common vessel information only needs to be entered once rather than duplicated across multiple submissions.
- The second is greater use of vessel manifests and existing shipping documentation. HMRC recognises that much of the information currently required on the G Form already exists within industry systems, so the possibility of uploading existing manifests or shipping documents is being explored.
Interestingly, HMRC is also looking at whether AI could be used to extract the required customs information from uploaded documents, potentially reducing the need for standardised formats and further manual data entry. The AI element is particularly interesting - could technology finally remove some of the repetitive data entry rather than adding another system for industry to manage? It is still at an exploratory stage, but Bethan will definitely be watching this one closely!
What did the industry say?
Overall, the direction was welcomed. A single G Form supported by manifest information feels like it could be a much more practical way forward.
However, there are still some important questions to work through such as:
Who submits the declaration when multiple businesses are involved? Where does responsibility sit between operators, suppliers, freight forwarders and vessel operators? How will individual businesses obtain evidence that their goods have actually departed or returned? And how will amendments and cancellations be managed when offshore schedules inevitably change?
This all sounds positive - and anything that reduces duplication while still giving HMRC the information they need has to be worth exploring. But, as always, the important bit is how it actually works in practice.
Offshore supply chains are complex. There can be multiple suppliers, cross-hired equipment, last-minute cargo changes and returns that are often considerably more complicated than outbound movements. Any future solution needs to work with how offshore logistics actually operates, rather than creating another administrative process for industry to manage.
What happens now?
There are no immediate changes to the current declaration routes. Businesses can continue to use the existing options available to them, including the UKCS G Form and, where applicable, existing FAL and GAR processes.
HMRC will now consider the feedback received, continue technical testing around manifest uploads and explore the potential use of AI. Industry volunteers and examples of real or historic manifests are also being sought to support that testing.
For Bethan, the August sessions are encouraging! There is still work to be done, particularly around who is responsible for what, evidence of movement and audit trails, but it is positive to see HMRC listening to the practical challenges industry has been raising.
Bethan will continue to support the work through OEUK and industry engagement as the approach develops.
And, as always, we’ll keep you updated on what this actually means in practice and, importantly, as soon as there is anything businesses need to do differently. #CustomsIsCool
