Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
Applicant's Name
EORI Number
Guidance
Notice 760 provides background information on the criteria and conditions for authorisation to use Customs Freight Simplified Procedures
(CFSP). The CFSP authorisation criteria, conditions and processes are in CFSP Guidance CFSP13000-CFSP17000.
Where the applicant is also applying for Single Authorisation Simplified Procedures (SASP) imports authorisation in the UK, the criteria
and conditions of authorisation will mirror those required for CFSP. Any questions on SASP authorisation should be directed to:
Nigel [email protected]
The validation, verification and testing of the applicant's compliance, documented procedures and financial standing is in the AEO Basic
Guidelines document in the AEO Public Folder in Outlook.
The notes at the back of the C&E48 application form advice the applicant of the completion requirements. The information contained in
Section 1 (General) and Section 2 (Imports) of the C&E48, together with information gathered on the visit, should provide the full details
required to complete the C&E58 authorisation letter.
The C&E48, the C&E58 and a training template of the C&E58 containing completion notes can be found on the CFSP UoE web page.
C&E 48 validation and completeness checks
When you receive the C&E48 it will have been validated by the authorisation team using a standard checklist template. There will also
have been a basic completeness check to ensure that all the necessary information has been provided. The template, which is reproduced
in CFSP guidance CFSP23000 will be forwarded to you electronically, highlighting any areas of concern such as the traders’ compliance,
financial standing etc, or where our records conflict with the information provided by the applicant. Further checks may be required to
clarify any anomalies prior to the pre-authorisation visit.
If your business area does not have an authorisation team, you will need to complete the validation and completeness checks yourself
and record the results in the checklist. If any information is missing or needs clarifying you must ask the applicant for further details
within 30 days of receipt of the C&E48.
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
Authorised Economic Operator (AEO)
A trader who wishes to become or already holds an AEO authorisation will still need to complete Sections 1 and 2 of the C&E48 if they
wish to also operate CFSP. The officer will use the information provided to confirm and verify the CFSP requirements. These sections of
the C&E48 almost mirror Parts 1-14 of the C&E58 authorisation letter, so will aid its completion.
If the applicant is already an AEO or has applied for authorisation and is new to CFSP, the processes specific to CFSP (such as the
computer system and software, the use of Direct Representatives, the provision of security via a deferment guarantee etc) will need to be
verified, included in the traders documented procedures, discussed with the trader and examined. The compliance and financial standing
of the applicant should already have/will be tested during the AEO visit.
If the applicant has applied for AEO but their application has been rejected, you will need to establish the reason for the rejection. If the
details are not in the trader’s folder the AEO authorisation team in Nottingham should be able to help. If the rejection is due to the safety
and security aspects of authorisation, the trader may still apply for CFSP authorisation. If the rejection is due to poor compliance or lack
of financial solvency the CFSP application should be rejected.
Timescales
You may have been given a deadline for completing the visit and returning the documentation. Please bear in mind that from the time
that all the necessary information is received, the authorisation process should be concluded within 30 days. Note: If a trader new to
CFSP is applying for SASP, a 90 day deadline applies. Once the visit is over you must complete and return an electronic version of this
report and the Supplementary Narrative Form For Caseflow to the issuing authorisation office asap. If you need to allow the applicant
more time to provide information to you please inform the authorisation team as they will be monitoring the return of the Supplementary
Narrative Form For Caseflow and the report.
Authorisation process
Depending on the circumstances, either before or during the visit you should discuss the CFSP processes and ensure that the applicant
fully understands their obligations regarding:

the other procedures to be operated with CFSP (such as warehousing, IPR) and the interaction between the procedures. Remind the
applicant that they must not use a simplified Customs Procedure with Economic Impact (CPEI) such as simplified IP with CFSP.
Guidance CFSP03000 (SDP) and CFSP04000 (LCP) refer.

the general authorisation requirements including the complete and timely submission of SFDs, SDs and FSDs, and provision of the
estimated duty and VAT for any late supplementary declarations. Guidance CFSP05000-CFSP07000 and CFSP16000 refer.
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)

the base date for entry of the supplementary declarations (SDI/SDW/FSD) and the tax point date. Guidance CFSP03150, 03250,
04250, 04400, 04700, 06150 etc refers.

the use of CPCs. These are listed in Volume 3 Annex E2 of the Tariff. Completion notes for the Simplified Frontier Declaration (SFD)
and the Final Supplementary Declaration (FSD) are detailed under the appropriate CFSP CPC. Guidance CFSP08000 refers.

the goods excluded from CFSP and the goods limited to the Simplified Declaration Procedure (SDP) - controlled goods; the use of
specific frontier CPCs for controlled goods and the additional box completion requirements. Also explain the procedures for the
presentation and/or retention of the supporting documents. Remind the applicant that all supporting documentation must be
retained for 4 years. CFSP10000, CFSP14400 and CFSP Information papers 43-46 and 55 refer.

whether any imported goods will be subject to preference, quota, ADD, CED, surveillance or licensing. If so, explain the processing
and retention of these documents and the importance of properly recording the details (including any serial numbers) in box 44 of
the declaration. Inform the applicant of the requirement to annotate each preference certificate with the DUCR number. Notice 760
14.6 refers. Annexes C9/10/11 of Volume 3 of the Tariff provides details of the correct document/statement codes to be used.
For an IR you will need to agree:
-

timescales for presenting any exhausted documents to Customs
timescales for presenting supporting documents to Customs for audit purposes
-
location of the supporting documents . Guidance CFSP11200 and CFSP14550 refer.
For an authorised trader employing a DR you will need to establish:
-
who will be maintaining the supporting records and documents?
-
where they will be made available for audit, at their own or the applicant's premises?
Remind the applicant that the maintenance and accuracy of all records will remain with them, not the DR. Guidance CFSP11250 and
CFSP14450 refer.

use of the Declaration Unique Consignment Reference (DUCR) and box 40 (previous document) for audit purposes. Guidance
CFSP06200 refers

classification requirements. A description of the goods is mandatory on all CFSP declarations apart from the Final Supplementary
Declaration (FSD). Generic terms such as ‘various’, ‘toys’, ‘gifts’, ‘textiles’ must not be used on a CFSP declaration

the options for aggregating like goods in the Supplementary Declaration. Authorisation is not required for daily aggregation;
however it is required for aggregation across the tax point (10 day). Guidance CFSP06300 and CFSP Information papers 37 and 64
refer.

the security and payment requirements including the use of a third party deferment account
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
For an IR:
-
will the security be adequate to cover their own and their clients liabilities?
-
does the IR have written approval to use a clients deferment account?
-
how will the IR monitor that their deferment level remains adequate? CFSP12200 refers.

the use of Direct Representatives (DRs) and software suppliers. Remind the applicant that they will be held accountable for the
actions of a DR. CFSP11250 and CFSP14450 refers

the requirement to notify the authorising officer/team where details of the business change. Notice 760 14.1 refers.

for LCP, the temporary storage and local clearance record requirements and tax point date. Guidance CFSP04100 and CFSP17150
refer. C&E58 lists the minimum data to be included in the TS/LCP record.

for LCP imports, the ‘national’ transit requirements which include:

-
authorisation as an Authorised Consignee,
-
authorisation to hold a transit guarantee and
-
the discharging of the transit movement via a monthly ‘end of transit notification’. Guidance CFSP04200, CFSP17150 and
CFSP22000 refer.
for LCP TS and CW/FZ removals to free circulation inland, the ‘prior notification of removal’ and ‘dwell time’ requirements. These are
mandatory for controlled goods or where the goods pose a higher revenue risk and may be necessary where the traders system
means that carrying out an unannounced visit to physically examined goods would be difficult i.e. goods are released infrequently or
released and dispatched immediately. Guidance CFSP04500 and CFSP04650 refers.
Computer system and software
You may wish to consider LBS Audit Specialist involvement with regard to the design, testing and implementation of the applicant’s CFSP
system and software prior to authorisation. In making this decision the following aspects should be considered:
-
revenue and other risks, eg BIS licences, and
-
complexity of the applicant’s system.
If the applicant will be routing their declarations through DTI they may need to obtain a ‘badge’ from their system operator. The badge
number will be required before you submit the PA1 to the CFSP Unit of Expertise in Leeds.
If the applicant will be using EDCS to enter their declaration the role and location details will be issued by CHIEF Ops on receipt of the
PA1. The EDCS EDIFACT Technical Interface Specification document is available on the HMRC website. Guidance CFSP15100 refers.
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
You will need to discuss and agree the applicant’s implementation plan and the date by which they wish to commence using the simplified
procedures. Once the system is ready, the UoE should be informed of the ‘go live’ date.
Multi-site authorisations
For multi-site authorisations you will need to determine whether these sites are to be managed separately or by their head office. Ensure
that the office address detailed in the application is where the records for the group will be maintained/produced. As there is now only
one Economic Operator Registration Identification (EORI) number (was TURN) issued per legal entity, we must be satisfied that all of the
sites and their relationship to each other are documented with roles and responsibilities of each clearly defined. CFSP14600 refers
The pre-authorisation visit.
During the pre-authorisation visit you will need to:

Verify and validate the information contained in the C&E48 application form. Pay close attention to any comments that the
authorisation team may have made about compliance or financial standing or any anomalies or recommendations that they have
noted in the checklist. Record the checks and results in the evaluation table at the end of this report.

Where the applicant will be importing more than 5 commodities, or will be using more than 5 CPCs, authorised locations etc. they
should provide you with the list(s) on the visit. A copy of each list will form part of the authorisation and should be sent to the
authorisation team. If the trader imports hundreds of commodities (such as a mail order company) they may exceptionally
produce a ‘product list’ which should be maintained locally. Any changes that involve controlled goods must be notified to the
authorisation team immediately and the list must be made available to HMRC on request.

All of the processes that you have discussed with the applicant should be included in their documented procedures. Walk through,
test and verify the procedures. Are they complete, auditable and easy to follow? If not, the applicant should be given additional
time to implement any necessary improvements but remind them that their application may not be progressed until the full
information is provided. Note: If the documentation is almost ready, you may consider progressing the application without the full
details.

Examine the full financial accounts of the applicant. If not available, examine the draft or management accounts. If the
authorisation team has raised concerns about the applicant’s financial standing, this must be fully investigated during the visit. If
necessary to prove solvency, a legal undertaking may be provided by the applicant. An example of a legal undertaking is included
in the AEO guidelines.
Your findings, concerns and any recommendations for further action must be noted in the Supplementary Narrative Form For Caseflow. If
after consultation you decide that certain conditions or standards are not met, discuss these shortcomings with the trader. Agree any
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
remedial action needed and allow the trader a reasonable amount of time to achieve improvements. Note this in the Supplementary
Narrative Form For Caseflow and confirm with the trader in writing. If the standards are not met within the agreed time span you may
allow additional time but remember to notify RIS/the authorisation team of any delay as they will be monitoring the return of the
documentation. Once the trader has evidenced the additional controls, update the Supplementary Narrative Form For Caseflow with the
results.
After the visit
After you have completed your visit you must ensure that the following are filed within the trader’s folder:





A copy of the checklist
A copy of this report and the Supplementary Narrative Form For Caseflow
A copy of the signed application form (C&E48)
any other documents provided by the trader in support of the authorisation eg lists of CN codes or product lists, designated
premises etc
a copy of the PA1 request to set up the applicant on CHIEF
Once the PA1 has been actioned and the trader is ‘live’ return the traders’ folder to the appropriate folder store.
An electronic version of this report and the Supplementary Narrative Form For Caseflow must be sent to the issuing officer of the
authorisation team so that the CFSP authorisation letter can be issued. Remember to forward any relevant hard copy documents provided
in support of the authorisation e.g. lists of CN codes, designated premises etc.
C&E48 ref
Evaluation
Observations/Recommendations
Section 1 Application for authorisation to use simplified procedures - General information
1
Applicants details
1d
Type of representation
2a
Local clearance procedures
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
2b
Simplified Declaration Procedures
3
Type of authorisation (code)
4a
AEO
4b
Other procedures to be used with
CFSP
5
Main commercial accounts, address
and type
6
Continuation forms (additional lists)
Section 2 Application for authorisation to use simplified procedures. Continuation form -Imports
7
Customs records for the procedure,
address and type
8
Type of goods
9
Customs Procedure Codes to be
entered on SDs
10
LCP - authorised location of the
goods (inland place of clearance)
and supervising office(s)
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
11
SDP – Customs office for
lodgement of SFDs
12
SASP – Companies included in the
authorisation
13
SASP – Applicants supervising
office
14
N/A
15
Imports only
15a
SIVA/EPSS approval
Authorised Consignee
Transit guarantee
15b
Security - deferment account
number and amount of guarantee
15c
Payment – deferment account
number of applicant or client. Client
address details
15d
Address and VAT details of any
Direct Representatives
16
SASP - consent for exchange of
information
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
Section 3 Application for authorisation to use simplified procedures. Continuation form – Additional requirements.
17 Compliance record
Compliance history
Intelligence information
18 Accounting and logistical system of the applicants business
Audit trail
Accounting and logistical system
Internal control systems
Making customs declarations and the use
of customs agents
Procedures for back up, recovery and
fallback and archiving
Information security – protection of
computer systems
Information security – documentation
security
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Visiting Officer Report for the authorisation of new CFSP traders (C&E48)
19 Financial solvency
Finalised accounts
Submission of accounts.
Additional Comments
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