CFSP14450 - Processing the
application: services of a Direct Representative
Traders may employ a representative to act as a DR. If the
authorised trader is completing their own declarations and the
representative is purely acting as a third party service provider
(eg simply translating their declarations and forwarding them to
Customs) then they are deemed to be acting as a DR. The DR’s
TID appears on the declarations in box 14 and the traders TID
appears on the declarations in box 8. The authorised CFSP trader is
solely liable for the customs debt. If the trader intends to use
such a service the local officer must ensure the points outlined
below (1. and 2.) are actioned in addition to the standard
authorisation procedures.
1. Action by the applicant’s local officer
On receipt of the application, contact the local officer
controlling the third party (DR) to obtain/ discuss the
following:
- Is the DR known to be currently providing
a similar service for any other companies, and if so what is their
compliance record?
- If this is a new DR, is anything known
about them by the department?
- Agree a testing procedure for the
applicant.
- Agree if the officer for the DR should
visit to review their system and procedures.
- Agree the intended date of commencement
for 'live' transmissions for the applicant.
- When/ if ready, issue the legal entity/
applicant (not the DR) with the appropriate authorisation letters.
Copy to the officer for the DR for information and retention.
2. Action by the DR’s local officer
- Upon receiving notification from another
office that a DR in their area will be representing a CFSP
applicant, they must liaise with the officer for the applicant as
per above.
- Following consultation and risk assessment
based on individual circumstances, officers must arrange a visit to
assess the suitability of the system, retention of data and control
procedures including the communication links between the trader and
the DR.
- Communicate any findings to the officer
for the CFSP trader and agree any ‘remedial’ action
required.
