One of the most important aspects of Kukla’s services to our customers is provided by Kukla Customs Division (KCD). In the photo, part of the team, from left to right: Graeme Denman, Kylie Bassett, Hayley Boyd, Olivia King, Martin Jacobs, Owen Wilson, Steve Wilson and Dan Haddon.
The challenges posed by the transition into a brave new post-Brexit world saw Kukla invest further in KCD in 2020 with additional staff resources and systems. Key to this was the opening of a second Kukla UK office, based in Folkestone, which now houses the 12 team members of the KCD operation. The entire team includes Blanka Dzurjova, Dan Haddon, Graeme Denman, Hayley Boyd, Kylie Bassett, Maddie Byrne, Martin Jacobs, Olivia King, Owen Wilson, Ruby Featherbe-Nejad, Steve Wilson and Stevie Todd.
The Folkestone office not only serves to manage the administration and clearance of Kukla clients in-transit orders into the UK but also offers a full customs brokerage service for ‘stand-alone’ clearances, for importers seeking a clearing agent. This makes up a significant part of the KCD business.
Our commitment to partnership with our clients, helping them understand and work through the new and complex administrative processes, was key in our development as a business and consolidating our position as trusted service providers.
It’s easy to define service providers as being limited to the carriage of freight, getting orders from A to B, and the physical aspect of the freight forwarder’s job.
What often goes unnoticed, perhaps until there is an underlying issue warranting further detail and explanation, is the role of the customs agent. With KCD we have our own ‘in house’ customs team, with direct access to HMRC. This gives us and our clients a clear understanding of the current rules and the ability to resolve any issue upon import quickly and efficiently.
Such a direct relationship with HMRC is not just for the ‘here and now’ clearances, but it enables Kukla to get a head start on what is in plan for the short-term future.
It is an area of critical importance to our business. The role of ‘customs clearance’ often goes unnoticed since most orders are cleared and delivered onward to the final UK destination without issue.
At the risk of stating the obvious, however, there is an administration behind every single shipment we make on behalf of our clients. The numbers and codes on the documents must be 100% correct. Each piece of information and paperwork required by HMRC and the warehouse of receipt must be provided accurately, on time, and every time.
We spoke with Kukla Customs Division Director Martin Jacobs and KCD Manager Steve Wilson about the post-Brexit changes, the key moments where HMRC introduced significant changes in the last few years and what we can expect going into 2025.
Whilst perhaps not ‘bedtime reading’, the following Q&A is something of which we should all be aware and why KCD are so important to the success of the Kukla operation.
Q&A with Kukla Customs Division Director Martin Jacobs and KCD Manager Steve Wilson
Q: Martin and Steve, thank you for taking the time to talk to Kukla News. Can we first ask about the Brexit effect and how things have had to adjust as a result?
A: Since 01 January 2021, it has been a massive learning curve for all those involved within the supply chain. Customs was and is a critical part of transport and customs formalities, having to work alongside each other, not one without the other. EU exporters are now required to complete new Export documents as well as their invoices to contain Preference statements to allow zero UK customs duty when importing. Customs brokers scale up staff, train them in time for the implementation date and hire more new staff as volumes increase and confidence grows.
Customs is a critical part of transport and customs formalities, having to work alongside each other, not one without the other.
Learning a completely new customs system (Customs Declaration Services) for 1 October 2022, I’m glad to say that as we’re now in our 4th year, things are running very smoothly. All parties involved know what is required and when, but there are occasions, as always, when new enquiries come across your desk that require expertise (investigating/checking) to ensure before transportation, everything is in place. Customs certainly keep us on our toes with new legislation and trade deals coming into play on a regular basis over the past three years.
We at KCD were fully operational in advance of the CDS and SPS cutoff dates.
Q: Tell us more about the introduction of CDS (Customs Declaration Service) & SPS (Sanitary and Phytosanitary) and the new systems and controls.
A: CDS Import was implemented on 1 October 2022, and Export on 04 June 2024. We at KCD were fully operational in advance of the cutoff dates. The legacy system CHIEF is now unavailable. All import and export declarations are via CDS.
A: SPS from 30 April 2024, physical, documentary and identity checks at the border are required for medium-risk animal products, plants and plant products imported to Great Britain from the EU, as well as high-risk food and feed of non-animal origin from the EU, further controls for West Coast ports, Ex-Ireland, to follow in October 2024. At KCD, we were prepared again in advance of the new controls and have not had any challenges relating to the new notifications.
Q: What about the Excise Rate changes from 01 August 2023?
A: New UK Excise rates were introduced from 01 August 2023 to 31 January 2025, and as a result, in June and July 2023, we saw a big increase in Still wine declarations and a reduction in Sparkling wine declarations prior to the new rate introduction in August. Revised Excise tax codes were also introduced, as well as the CDS declaration requiring the actual ABV% on each line of product; however, there is still an easement in place until 25 February. Still and sparking wines between 11.5% to 14.5% are being calculated as 12.5%. The formula for excise amounts is now on the Litres of alcohol (LOA) rather than the hectolitre (hl) of products.
Q: How is the implementation of NCTS 5 (New Computerised Transit System) going?
A: NCTS5 was recently implemented in a phased approach; again, we were ready when the initial switchover was implemented on 1 July. Although the UK is now on NCTS5, not all CTC signatory members are, so some functionality is still to be phased in over the next few months. All should be finalised in January 2025, and the full system is operational. Again, like the CDS implementation, this requires additional information to be declared on transit declarations.
In February 2025, when all organic products will require certification, we do not expect any implementation issues other than an increased workload for the team.
Q: With regard to certification on organic wines, many of our readers will be keen to know how the planned changes to this will affect imports of these wines from 1 February 2025.
A: Currently, there are no requirements for EU-approved organic goods to be re-certified on entry to the UK as ROW goods require. This will change in February 2025, when all organic products will require certification. As KCD already completes notifications from ROW countries, we do not expect any implementation issues other than an increased workload for the team.
Implementing the Single Trade Window later this year will hopefully negate the need to enter the same data multiple times for different declarations.
Q: Is it fair to say that the proposed Safety & Security Declarations coming in from 31 October 2024 will simplify the process and reduce workload?
A: For imports into GB from the EU, this will come into force on 31 October 2024, as set out in the original Border Target Operating Model. Implementing the Single Trade Window later this year will hopefully negate the need to enter the same data multiple times for different declarations; we expect to see the STW operational in Q4 2024. By reducing and simplifying duplicate processes and data requirements, the Single Trade Window will reduce administrative tasks and transform user experiences at the borders.
We started to prepare the Customs Division ahead of Brexit in 2019, researching customs operating systems, Deferment & Movement Guarantees, as well as AEO accreditation.
Q: What can you share with us about the past and present of the Kukla Customs Team?
A: We started to prepare the Customs Division ahead of Brexit in 2019, researching customs operating systems, Deferment & Movement Guarantees, as well as AEO accreditation. The first members of staff were employed in early 2020 so that we could be fully prepared for 01 January 2021.
The team is now made up of 11 staff members with two months to 30+ years of experience covering all aspects required for import, export, and transit procedures.
Martin and Steve, as always, you’re incredibly busy, so we’ll let you get back to this crucial work. Thank you both once again for this enlightening Q&A, which introduced us and our readers to the work of KCD and for taking the time to talk to Kukla News.
Thank You
Chris Porter
July 2024
If you have any questions in regard to this article or wish to enquire about Kukla’s stand-alone customs broker services for imports that do not yet have a UK customs clearing agent, please contact your Kukla operational contact or Chris Porter c.porter@kukla-spedition.com.
Timeline of recent/future changes:
31/01/2024 – Full customs controls from Ireland are introduced, GVMS in operation
31/01/2024 – 999L Removed from CDS Import document codes to allow correct document codes to be used for licensing, organics etc.
30/03/2024 – End of customs legacy declaration system CHIEF
30/04/2024 – SPS Checks implemented for imports from or via the EU
03/06/2024 – ICS2 Transition begins
01/07/2024 – NCTS5 Implementation in UK
30/09/2024 – Windsor Framework / UKIMS “Green Lane” implementation
31/10/2024 – S&S Declarations required for EU imports
04/12/2024 – ICS2 Filing for Maritime carriers
31/01/2025 – 999L Removed from CDS Export document codes to allow correct document codes to be used for licensing, organics, etc.
31/01/2025 – End of wine easement codes to 12.5%, wine to be charged at declared strength for 11.5% to 14.5%
01/09/2025 – ICS2 Filing for Rail and Road carriers
