It’s been a busy start to 2026 for businesses in the world of international trade. Firms moving goods cross-border and organisations supporting them have a number of systems and regulatory changes to keep up with.
This includes updating processes for declaring proof of origin following the latest iteration of the Customs Declaration Service (CDS) and information about both the UK and EU’s Carbon Border Adjustment Mechanism (CBAM).
In this blog I’ll cover the recent changes and offer advice on how businesses can sidestep common issues.
CDS 5.1.0 release
It’s been almost one month (28 March) since the release of CDS version 5.1.0 and the update has caused widespread problems for goods movements.
There has been significant disruption where pre-lodged export declarations had been used to move goods across the UK border.
The major change creating problems for many businesses relates to new validations for declaring origin. Previously, businesses could complete data element (DE) 5/16 to indicate preferential origin – if goods were being moved between the UK and a trading partner with a free trade agreement in place – and leave DE 5/15, which indicates non-preferential origin, blank.
As of 28 March, this is no longer the case. Both data elements must be completed, even if they’re the same.
The rationale for the change was to make sure imports eligible for preferential origin under trade agreements weren’t being overlooked if they were still subject to duties under other trade measures, like anti-dumping duties. This could be missed if DE 5/15 was left blank.
However, in trying to secure potentially lost revenue, the system change has caused wide-ranging disruption.
Many businesses have standardised procedures for creating their declarations which now include old instructions for leaving DE 5/15 blank.
Those vulnerable to delays include businesses engaging in repetitive flows of trade – regularly importing the same goods from overseas suppliers – that are likely to use CSV templates to draft declarations. Businesses that outsource their customs requirements to intermediaries may also have automations set up using the old instructions.
Traders should review their existing processes for declarations, but also pay closer attention to the origin of their goods – including verifying the non-preferential origin and checking if any additional measures should apply.
Post Clearance Amendment changes
Another recent change to import declarations is an update to the Post Clearance Amendment (PCA) process.
HMRC has announced an update to the process for submitting PCAs, which will now require evidence to accompany the changes. This includes:
- Movement Reference Number (MRN) or entry number
- Name of the new importer Address of the new importer
- Economic Operator Registration and Identification (EORI) number of the new importer
- Evidence of empowerment for the creation of the original declaration
- Explanation for the error made and the reason
- Commercial invoice
In a notice to traders, HMRC wrote that PCAs can only be used to “correct genuine errors”, they can’t be used to “change the facts of a movement after the event”.
“Incorrect submissions or deliberate non-compliance will result in amendments being rejected and could lead to further compliance action.”
Online Trade Tariff update
Another recent HMRC update includes changes to the Online Trade Tariff, which will enable businesses to receive customised notices about changes specific to them.
The new feature is a subscription service, which allows customs professionals to set up alerts for commodity codes and chapters relevant to their business. That can be accessed here.
For commodity code updates, it’s possible to upload a spreadsheet of commodity codes that your business regularly uses to receive relevant email alerts with a spreadsheet which can then be downloaded. You can also update the spreadsheet you upload to the service at any time in response to changes in the commodity codes you use.
HMRC said the change has been made in response to user feedback, in order to “reduce the time businesses spend monitoring tariff updates”.
In addition to reducing the administrative burden of manual checking, the service is designed to provide “faster visibility” of changes and support improved compliance.
New HS correlation tables ahead of 2028 update
In another update bringing businesses greater access to trade data, the World Customs Organization (WCO) has announced new correlation tables for 2022-28.
Two tables are now available for review on the WCO website. One covers correlations between the 2028 and 2022 HS editions, while the second covers correlations between the 2022 and 2028 editions.
This second table includes an additional column “with brief descriptions of the types or categories of goods transferred from each HS 2022 subheading to the corresponding HS 2028 subheading(s)”, the WCO said in a LinkedIn post.
The HS system is typically reviewed and updated in five-year cycles, during which the Harmonized System Committee and Harmonized System Review Sub-committee will evaluate changes needed to improve the system’s function, typically in relation to technological advances and changing patterns in international trade.
The upcoming 2028 changes include 299 sets of amendments, resulting in the Nomenclature of 1,229 headings and 5,852 subheadings, the WCO announced. Additionally, six new headings and 428 new subheadings have been created, while five headings and 172 subheadings have been deleted.
The changes centre on public health, with many designed to “enhance the visibility of essential supplies used in health emergencies, including ambulances, personal protective equipment, medical ventilators, diagnostic and monitoring devices”.
Some goods may now sit under an entirely different Heading or Subheading, so importers and exporters will need to plan ahead to monitor any regulatory changes, such as duty rates or non-tariff measures, attached to the classification of their goods.
CBAM updates
Many businesses could soon be grappling with two sets of CBAM compliance.
The UK’s border tax will become operational on 1 January 2027, while the EU’s CBAM already entered its definitive phase this year. This means EU businesses importing goods within the scope of CBAM are now liable for charges aligned with the emissions generated to produce them.
EU CBAM
Payment must be made via the surrender of certificates purchased to cover the cost of emissions. However, these will only become available to purchase next year.
This means that businesses are now liable for charges, but cannot pay those charges until 1 February 2027.
The first announcement of certificate prices came earlier this month, covering CBAM goods imported in Q1 2026.
That’s the first part of the costing CBAM, the second involves establishing the emissions generated by the production of the imports, or the values to which you apply those certificate prices.
Currently businesses can use default data provided by the EU, which the majority of businesses are likely to be doing. However, this will be more expensive than determining your own emissions values, which must be verified by approved verifiers.
Despite not being able to calculate the costs yet, businesses will be expected to hold enough CBAM certificates to cover 50% of their CBAM liability at any time. For this reason, it’s worth staying engaged this year as more certificate pricing is released and investigating what your business’ true CBAM costs are.
UK CBAM
The UK’s CBAM payments will work differently. There are no certificates and CBAM won’t be present on UK customs declarations for imports.
While this may sound good there is an important caveat.
While UK CBAM will be applied to goods based on their commodity code, but won’t be included in declarations, the changes will not appear in the UK Trade Tariff. Instead, the Government will maintain a list of codes subject to UK CBAM in a separate guidance document.
This would challenge ongoing government efforts to streamline information-finding relating to customs data. Previously the Trade Tariff has been seen as “a single source of truth” for businesses understanding the commodity codes, duty and VAT rates applicable to their goods.