Key Takeaways
- DE 1/11 is where you add Additional Procedure Codes to tailor the treatment of goods on a CDS import declaration.
- GOV.UK Appendix 2 is supplementary guidance, but its DE 1/11 completion notes take precedence where they differ from the main declaration guide.
- A goods item can have only one 4-digit DE 1/10 Procedure Code, but it can carry more than one DE 1/11 Additional Procedure Code.
- HMRC made several 2026 Appendix 2 updates affecting C15, PVA01, 2MO, C and F series codes, Freeport-related procedures, and other APC combinations.
- Import teams should recheck declaration templates whenever the commodity code, requested procedure, relief, preference claim, or EORI data changes.
What DE 1/11 Does on a CDS Import Declaration
DE 1/11 is the field that lets you refine the customs treatment of an import goods item after you have chosen the main Procedure Code in DE 1/10. The main Procedure Code describes the broad movement or requested treatment within a wider CDS import declaration. The Additional Procedure Code then adds the relief, simplification, accounting treatment, preference condition, Freeport treatment, or other special instruction that applies to that item.
HMRC’s Appendix 2 says it contains the completion rules for each 3-digit Union and National Additional Procedure Code that can be used in DE 1/11 for imports. That makes it operationally important: the wrong APC can change the validation route, trigger a rejection, or place the declaration outside the conditions for the treatment you intended to claim.
The first control is that DE 1/10 and DE 1/11 must work as a pair. You cannot choose an Additional Procedure Code in isolation because it must be permitted with the 4-digit Procedure Code declared against the same goods item. GOV.UK’s import correlation matrix exists for that reason: it maps Procedure Codes to the Additional Procedure Code combinations that can be used on CDS import declarations.
The second control is that DE 1/11 is item-level logic. If different goods in the same consignment need different reliefs, preferences, Freeport treatments, or VAT treatments, they need to be split into separate goods items with the correct procedure-code combination on each line. Treating DE 1/11 as a header-level shortcut is a common source of avoidable CDS rejections.
DE 1/10 vs DE 1/11: The Practical Difference
DE 1/10 answers the broad procedural question: what customs procedure are you requesting for this goods item? Examples include release to free circulation, customs warehousing, inward processing, temporary admission, or release to a Free Zone or Freeport where the procedure is available. It is a 4-digit Procedure Code, and HMRC’s Appendix 2 introduction confirms that only one such code can be declared against each goods item.
DE 1/11 answers the narrower treatment question: what additional condition, relief, simplification, or national treatment modifies that procedure? This is why multiple Additional Procedure Codes can be used on one item where the rules allow it. A single item might need a Union APC and a National APC because two separate pieces of logic apply to the same imported goods.
The order matters. HMRC’s Appendix 2 introduction says that if a goods item requires both Union and National Additional Procedure Codes, Union Codes from Appendix 2A should be declared first. That ordering rule sounds small, but it matters for declaration build, template design, and software validation because many errors come from correct codes placed in the wrong sequence.
The relationship also affects how you investigate an error. If CDS rejects the declaration after a procedure-code edit, do not check only the 3-digit APC. Recheck the 4-digit DE 1/10 Procedure Code, the correlation matrix, the Appendix 2 notes for every APC used, and any dependent data elements such as document codes, authorisation references, preference codes, AI statement codes, and location fields.
What Changed in the 2026 Appendix 2 Updates
The 2026 changes show why import teams should treat Appendix 2 as a live operating document, not a static code list. GOV.UK records that the main Appendix 2 page was last updated on 19 August 2026, with amendments throughout Additional Procedure Code C15. That is the most recent signal that APC completion instructions are still being refined during live CDS operation.
HMRC also recorded a 30 July 2026 update covering PVA01, the removal of the PVA01 workaround, and changes to Additional Procedure Code 2MO. The research notes show the 2MO change is tied to cases where preference code 140 is not permitted by the commodity code, with the update pointing users towards preference code 100 where non-preferential customs duty relief is being claimed. For a broker, that is not merely a textual update; it changes how a preference and relief scenario should be built on the declaration.
Another 2026 update affects EORI usage. GOV.UK records a 1 July 2026 update to Import C and F series Additional Procedure Codes to reflect that, from 4 July 2026, EU EORIs can be declared in certain data elements. That matters for template review because an older rule embedded in brokerage software or work instructions may reject an EORI value that the current Appendix 2 position now allows.
Freeport-related procedure combinations also changed. GOV.UK records a 12 June 2026 Appendix 2 update to Additional Procedure Codes A04, F15, F44, 000, 1VW, 2CD, and 2CG to reflect Requested Procedure 78: Release to a Free Zone or Freeport being added to the CDS Declaration Completion Instructions for Imports. The import correlation matrix page says its 12 June 2026 update added Procedure Codes 7800, 7851, 7853, 7871, and 7878 and their APC combinations.
The Workflow to Choose the Right APC
Start with the declaration category and data set, not the APC list. GOV.UK’s import navigation page recommends using the relevant Appendix 21 declaration category data set before choosing the procedure-code structure. That step tells you which data elements are required, optional, or conditional for the declaration type you are filing.
Next, identify the commodity code and measures in the UK or Northern Ireland Online Tariff. Even though DE 1/11 is not itself a classification field, the commodity code can determine whether a preference, relief, licence condition, or prohibition is available. A procedure-code combination that is technically permitted can still fail if the commodity-code measures do not support the claim being made.
Then choose the 4-digit DE 1/10 Procedure Code from Appendix 1 and use the DE 1/10 to DE 1/11 correlation matrix to identify permitted Additional Procedure Codes. This is the stage where many errors should be caught before submission. If the APC is not permitted with the chosen Procedure Code, the declaration build is wrong even if both codes exist individually.
Finally, read the Appendix 2 completion notes for each APC you intend to use. The Appendix 2 introduction says the appendix is supplementary and does not constitute full guidance on completing a declaration, but it also says Appendix 2 completion instructions take precedence where DE 1/11 completion notes differ from the main Declaration Completion Guide or other appendices. That precedence rule is critical when an older internal guide conflicts with the current APC note.
Control Points for Brokers and Import Teams
The first control point is template ownership. If your brokerage platform stores default procedure-code combinations, assign an owner to each template and record when it was last checked against GOV.UK. APC changes such as the July and August 2026 updates can make a previously accepted template risky, especially where the template is used across clients with different commodity codes or relief conditions.
The second control point is item splitting. Mixed consignments should not be forced into a single goods item for speed if the goods require different treatments. Separate the goods by commodity code, origin, procedure, relief, VAT treatment, and licensing requirement before assigning DE 1/10 and DE 1/11 values. The extra declaration lines are usually cheaper than a rejected entry, a post-clearance correction, or a compliance query.
The third control point is evidence. If an APC claims a relief, simplification, or special treatment, keep the supporting authority, approval, certificate, preference evidence, or internal decision record with the entry file. CDS may accept a declaration that is syntactically correct, but acceptance is not proof that the business met every condition attached to the APC.
The fourth control point is sequence. Where both Union and National APCs apply, put the Union codes first, as HMRC instructs. Build this into software validation where possible because manual ordering checks are easy to miss under cut-off pressure, particularly for import teams handling high-volume e-commerce, warehouse removals, or Freeport movements.
When to Recheck Existing Declaration Templates
Recheck a template whenever the commodity code changes. A revised classification can affect preference eligibility, licensing measures, relief availability, document requirements, and whether a specific APC remains appropriate. Even a small classification change within the same product family can alter the measure set that sits behind the declaration.
Recheck a template whenever a client starts using a relief or accounting treatment that was not part of the original setup. Postponed VAT accounting, customs warehousing, inward processing, returned goods relief, temporary admission, and Freeport movements all require care because the procedure-code combination must match the actual treatment being claimed. Do not copy a previous entry simply because the supplier, carrier, or route looks familiar.
Recheck a template when HMRC publishes an Appendix 2 or correlation-matrix update that touches the code family you use. According to GOV.UK’s 2026 update history, changes were made across C series, F series, PVA-related, preference-related, and Freeport-related APCs. A monthly review is usually enough for low-volume importers, but brokers filing daily entries should watch update notes more frequently.
Recheck a template after a CDS rejection that appears unrelated to procedure codes. APCs can drive document requirements, statement codes, AI codes, authorisation checks, and data-element conditions elsewhere on the entry. Fixing only the visible error message may leave the underlying DE 1/10 and DE 1/11 mismatch in place for the next shipment.
Common Errors to Avoid
Do not use DE 1/11 as a note field. Additional Procedure Codes are controlled codes with specific completion rules, not a place to signal a general commercial fact about the shipment. If the treatment is not permitted by the Procedure Code and supported by the relevant Appendix 2 note, it should not be declared.
Do not assume an APC is valid because it worked on CHIEF or on an earlier CDS entry. CDS is built around structured data elements, and HMRC continues to update the completion instructions. The safer approach is to validate the Procedure Code, APC, commodity code, and supporting data as a current combination every time a new template is created.
Do not ignore National APCs when a Union APC is already present. Some declarations need both, and HMRC’s ordering rule exists because the system distinguishes between them. Leaving out the National APC can mean the declaration no longer reflects the intended UK-specific treatment.
Do not treat PVA and preference logic as interchangeable. The 30 July 2026 update shows that PVA01, preference codes, and APC 2MO can intersect in ways that affect the declaration build. If the business is claiming postponed VAT accounting, non-preferential customs duty relief, or a preferential rate, the evidence and coding should be checked as a joined-up entry rather than as separate tick-boxes.
A Practical Pre-Submission Check
Before filing, confirm that the declaration category is correct and that the Appendix 21 data set supports the entry you are building. Then confirm the commodity code and measures in the Online Tariff, including any licensing, preference, quota, relief, or control measures. This prevents the APC choice from being made on an incomplete view of the goods.
Next, check the DE 1/10 Procedure Code in Appendix 1 and verify the permitted DE 1/11 combinations in the import correlation matrix. If more than one APC is needed, confirm the order and whether Union codes must appear before National codes. Where the matrix or Appendix 2 has recently changed, record the date of the check in the job file or template note.
Then read the Appendix 2 notes for each APC, including any specific completion instructions for related data elements. This is where you catch conditions that are not obvious from the code title alone. If the APC refers to authorisations, documents, AI statement codes, preference codes, or location details, check those fields before submission rather than waiting for CDS to reject the entry.
Finally, compare the declaration against the commercial file. The invoice, packing list, licence, authorisation, transport document, valuation evidence, and origin evidence should support the Procedure Code and every APC declared. If the file does not evidence the treatment, pause the entry and resolve the gap before the goods reach the clearance deadline.
FAQ
Can one import goods item have more than one DE 1/11 Additional Procedure Code?
Yes. HMRC’s Appendix 2 introduction says only one 4-digit Procedure Code can be declared against each goods item in DE 1/10, but multiple Additional Procedure Codes may be used in DE 1/11 where they are permitted and needed. If both Union and National APCs are required, Union Codes from Appendix 2A should be declared first. You still need to check the correlation matrix and the Appendix 2 notes because not every APC can be paired with every Procedure Code.
Does Appendix 2 replace the main CDS declaration guidance?
No. Appendix 2 is supplementary and does not constitute full guidance on completing a declaration. However, HMRC says Appendix 2 completion instructions take precedence where DE 1/11 completion notes differ from the main Declaration Completion Guide or other appendices. In practice, you should use the main guide for the full declaration build and Appendix 2 for the specific conditions attached to the APC.
Should old CDS templates be updated after the 2026 APC changes?
Yes, if the template uses a code family affected by the updates or if it supports relief, preference, PVA, Freeport, C series, or F series scenarios. GOV.UK recorded several 2026 changes, including the 19 August update to C15, the 30 July update around PVA01 and 2MO, the 1 July update around EU EORIs in C and F series APCs, and the 12 June update connected to Requested Procedure 78. Templates that are not reviewed can keep producing entries that appear familiar but no longer match current completion instructions.
Is DE 1/11 the same as a commodity code?
No. The commodity code classifies the goods and drives tariff measures, licensing controls, duty rates, restrictions, and some eligibility checks. DE 1/11 declares the Additional Procedure Code that modifies the customs treatment of a goods item. The two interact because a commodity code can affect whether a relief, preference, or procedure-code combination is available, but they are separate data points on the declaration.