From MSS to CDS - What the New Free Customs Data Means for Your Business

From MSS to CDS - What the New Free Customs Data Means for Your Business

HMRC has introduced a free data access service through the Customs Declaration Service (CDS), allowing businesses that move goods in and out of the UK to access detailed customs declaration data linked to their EORI number.

An Economic Operator Registration and Identification (EORI) number is a unique identifier issued by HMRC to businesses that import or export goods. It is used on customs declarations to identify the importer or exporter of record and to track goods moving across UK borders. Where your EORI number appears on a declaration, the associated data will be traceable to your business, even where a freight forwarder or customs agent submits the declaration on your behalf.

This new CDS data service replaces the former Management Support System (MSS) data, which was available on a paid subscription basis. HMRC has confirmed that all paid MSS subscriptions will automatically end on 31 March 2026.

While this development provides greater transparency over what has been declared in your name, it also increases the expectation that businesses review and understand that data. This guide explains what those expectations are likely to be, the compliance risks that may arise if CDS data is not reviewed, and the practical steps you can take to remain aligned with HMRC’s requirements.

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What information is included in CDS reports?

CDS reports include detailed declaration data such as:

  • Entry number
  • Commodity codes
  • Declared customs values
  • Import VAT and customs duty payable
  • Customs Procedure Code (CPC)
  • Additional Procedure Code
  • Origin of goods
  • Preference code

Each of these elements directly affects your customs duty liability and your import VAT position.

If the commodity code used on your declaration is incorrect, you may be underpaying or overpaying customs duty. If the customs value is wrong, both duty and import VAT can be miscalculated. If an incorrect CPC or Additional Procedure Code has been applied, a relief or special procedure you believe is in place may not be valid. If preference has been claimed without the appropriate origin evidence, you may face a retrospective duty demand.

This is not background data. It is the technical detail that determines how much tax you are liable to pay at the border. If you are not reviewing it, you may not be aware of errors until HMRC identifies them.

Why this matters - visibility brings responsibility

The availability of CDS data free of charge gives you direct access to the declarations submitted in your business’s name. You are no longer reliant solely on summaries from agents or internal reports. The underlying data is now accessible to you at any time.

With that visibility comes increased responsibility. It is reasonable to expect that HMRC will view this transparency as placing greater emphasis on businesses to monitor their own compliance. If errors exist and the relevant data was readily accessible, HMRC may take a firmer view when assessing whether reasonable care has been exercised.

If you do not review the declaration data available to you, inaccuracies may remain undetected until HMRC identifies them. Where the same error continues across multiple consignments or VAT periods, financial exposure can build quickly.

CDS data should therefore be incorporated into your compliance processes and reviewed periodically, rather than treated as background information that sits unused.

Common risk areas CDS data can highlight

Regular review of your CDS data can help you identify issues that may not be visible from invoice summaries or internal reports alone.

In particular, you may uncover:

  • Incorrect commodity classifications.
  • Errors in declared customs values.
  • Misuse of CPC or Additional Procedure Codes.
  • Incorrect importer or exporter of record details.
  • Preference claims that are not supported by appropriate origin evidence.
  • Import VAT amounts that do not reconcile with your VAT returns, including Postponed VAT Accounting (PVA) entries.

If you import goods regularly, the same coding or valuation error can be repeated across multiple entries. Even small discrepancies on individual consignments can, over time, result in material underpayments or overpayments. Reviewing CDS data allows you to identify and address these issues before they develop into larger compliance concerns.

Building CDS into your compliance processes

If your business imports or exports goods, you should consider incorporating CDS data review into your internal controls.

This may include periodic reconciliation of CDS reports to internal records, spot-checking agent declarations, reviewing high-value consignments and aligning import VAT data with VAT return entries.

Where special procedures or reliefs are used, additional scrutiny may be appropriate to confirm that conditions have been met and correctly declared.

Proactive review reduces the risk of retrospective assessments and demonstrates that reasonable care is being taken.

How The Customs People can assist

CDS data is detailed and technical, and interpreting it correctly requires a clear understanding of both customs processes and VAT treatment.

The Customs People has been advising UK businesses for 29 years on VAT and import-related compliance. Our senior advisers bring extensive HMRC and consultancy experience, enabling us to assess both the technical position and HMRC’s likely approach where issues arise.

We support businesses by:

  • Reviewing CDS data alongside VAT records to identify inconsistencies, risks, and missed recovery opportunities.
  • Assessing import VAT treatment, including the correct use of postponed VAT accounting and supporting documentation such as PVA statements and C79 certificates.
  • Reconciling CDS data with VAT returns, making sure import VAT is correctly declared and recovered in line with HMRC requirements.
  • Advising on input VAT recovery, particularly where supplies, exemptions, or partial exemption rules affect entitlement.
  • Identifying errors in historic reporting and supporting voluntary disclosures to HMRC where required.
  • Providing support during HMRC enquiries, audits, and assessments, including reviewing positions and managing correspondence.

For businesses importing goods, CDS data now forms a central part of VAT compliance. Errors in interpretation can lead to incorrect VAT recovery, assessments, and penalties.

To discuss your position, contact The Customs People on 0161 826 8926 to speak with a specialist adviser. Alternatively, complete an online enquiry form and a member of our team will get in touch.

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