What changed on your CDS declaration now that steel waiver code 9Y16 is withdrawn?

By Saurabh Goyal, Founder & CEO of Phlo Systems. Published 18 October 2026.

If you file UK steel import declarations, or you move goods into Northern Ireland, two separate changes to the Customs Declaration Service now sit on your desk rather than on a release notes page. Document code 9Y16, the contractual waiver that kept certain steel imports out of quota and off the 50% out-of-quota duty rate, stopped being valid for goods imported after 30 September 2026. Separately, HMRC's Appendix 2 code list now states that Additional Procedure Code C07 must not be used on an H1 declaration for a movement into Northern Ireland, a change tied to how low value imports into Northern Ireland are now treated. Neither change is cosmetic, and neither is the kind of thing a declaration silently refuses over, so the practical risk is a declaration that goes out using an approach that was correct a few weeks ago and is not anymore.

The 30-second answer:

• What 9Y16 did: it let importers declare steel in scope of the UK's steel safeguard-style trade measure under a contractual waiver, using document code 9Y16 in Data Element 2/3 together with Preference Code 100 in Data Element 4/17, confirming the goods met the waiver's eligibility requirements without counting against quota.
• What changed: 9Y16 applied only to goods imported between 1 July 2026 and 30 September 2026. It is not valid on declarations for goods imported after that date. Out-of-quota steel imports from 1 October 2026 are liable to the full duty rate, 50%, with no waiver route left to claim against it.
• Who that affects: anyone declaring steel or steel-derivative products in scope of the UK steel measure who was using 9Y16 to stay out of quota, and the brokers and forwarders filing those declarations on their behalf.
• The separate Northern Ireland change: HMRC's current Appendix 2 guidance states that Additional Procedure Code C07 must no longer be used on an H1 declaration, the CDS dataset used for most standard import declarations, for a movement into Northern Ireland, as a consequence of changes to how low value imports are treated there. C07 can still be used for imports into Great Britain.
• Where tradePhlo stands: tradePhlo's Declarations module files CDS import and export declarations today and is kept current against HMRC's procedure and document code changes, including the withdrawal of 9Y16 and the updated Northern Ireland position on C07.

Why 9Y16 existed, and why it had an end date built in

Document code 9Y16 was added to CDS ahead of the UK's steel trade measure, which applies from 1 July 2026. It gave importers of steel in scope of the measure a way to claim a contractual waiver: declare 9Y16 in Data Element 2/3 alongside Preference Code 100 in Data Element 4/17, and the goods were treated as meeting the waiver's eligibility requirements rather than being counted against the measure's quota.

The code was never open-ended. It applied specifically to goods imported between 1 July 2026 and 30 September 2026, a transitional window rather than a standing feature of the steel measure. That window has now closed. For goods imported after 30 September 2026, 9Y16 is not a valid entry, and the waiver route it supported is gone with it.

What actually changes on a declaration without it

The mechanical effect is straightforward: a steel import that is out of quota under the measure, and that would previously have used 9Y16 to claim the contractual waiver, no longer has that option. Out-of-quota steel imports from 1 October 2026 onward are liable to the measure's full duty rate of 50%. There is no replacement waiver code to substitute in its place; the waiver period itself has ended.

This is the kind of change that is easy to miss precisely because it does not produce an error. A declaration built from a template that still carries 9Y16 and Preference Code 100 does not necessarily fail validation in an obvious way at the point of submission. The risk sits downstream, in whether the goods are correctly treated as out of quota and liable to duty, or incorrectly waved through on an eligibility basis that stopped applying on 1 October.

The separate change: C07 and Northern Ireland

The Northern Ireland change is unrelated to steel and worth treating as its own item rather than folding into the 9Y16 story. HMRC's Appendix 2 guidance for Additional Procedure Codes now states that C07 must not be used any longer on an H1 declaration for a movement into Northern Ireland, while it remains valid for imports into Great Britain. HMRC ties this restriction to changes in how low value imports are treated, rather than to the steel measure.

For anyone filing H1 declarations into Northern Ireland who has been using C07, this is a procedure code question, not a documentary one: the code itself is no longer the correct choice for that movement type, independent of what evidence or documents accompany the declaration. A GB import using C07 is unaffected.

Who is actually exposed

1. Steel importers and brokers who built declarations around 9Y16 during the July to September window. Any template, saved declaration pattern, or standard operating instruction that still references 9Y16 and Preference Code 100 needs to be retired for goods imported from 1 October 2026 onward, not just updated for the next shipment that happens to get checked.
2. Anyone filing H1 declarations for movements into Northern Ireland using Additional Procedure Code C07. This needs a different procedure code going forward; continuing to use C07 on an NI movement is filing against guidance HMRC has already changed.
3. Customs brokers running standard declaration templates across multiple clients. A template is only as current as the last time someone checked it against Appendix 2 and Appendix 5A, and both of these changes are the kind that do not announce themselves through a rejected declaration.

What to check this week

1. Search your declaration history and templates for document code 9Y16. Anything still generating it for goods imported after 30 September 2026 is using a waiver route that no longer exists, and the goods need to be assessed against the full 50% out-of-quota duty rate instead.
2. Confirm whether any of your declarations are H1 movements into Northern Ireland using Additional Procedure Code C07. If so, that procedure code needs to change; it is no longer the correct entry for that movement type, regardless of what has or has not been rejected so far.
3. Ask your declarations software provider directly whether it has already removed 9Y16 as a live option for post-30-September steel imports, and updated its Northern Ireland procedure code guidance for C07. A system that still lets a filer select either is leaving the judgement call to the person filing, at exactly the point where the correct answer has changed.

Frequently Asked Questions

What was document code 9Y16 used for?

It let importers of steel in scope of the UK's steel trade measure claim a contractual waiver, declared in Data Element 2/3 alongside Preference Code 100 in Data Element 4/17, so the goods were not counted against the measure's quota. It applied only to goods imported between 1 July 2026 and 30 September 2026.

Can I still use 9Y16 on a declaration today?

No. It is not valid for goods imported after 30 September 2026. There is no replacement waiver code; the transitional window it covered has ended.

What happens to out-of-quota steel imports now that 9Y16 is gone?

They are liable to the steel measure's full duty rate, 50%, with no waiver route available to claim against it.

Is the Northern Ireland C07 change related to the 9Y16 withdrawal?

No. They are separate changes that happen to land around the same time. The C07 restriction applies to H1 declarations for movements into Northern Ireland and is tied to changes in how low value imports are treated there, not to the steel measure. C07 remains valid for imports into Great Britain.

Does this affect imports into Great Britain?

The 9Y16 withdrawal affects steel imports in scope of the UK steel measure regardless of GB or NI destination, since the measure itself is a UK-wide trade measure. The C07 change specifically affects Northern Ireland movements; C07 can still be used for GB imports.

How Phlo Systems helps

tradePhlo's Declarations module files UK CDS import and export declarations today and is kept current against HMRC's procedure and document code changes as they are published, including the withdrawal of 9Y16 for steel imports and the updated Northern Ireland position on Additional Procedure Code C07. For brokers and forwarders running declaration templates across multiple clients, that means one less code list to track by hand before a declaration goes out. See how tradePhlo handles UK customs declarations.

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Related reading:

• Does the CDS Melt and Pour steel rule apply to imports into Great Britain?
• What does NCTS Phase 6 actually change for UK transit declarations?
• What is the UK Customs Declaration Service (CDS), and how do you submit an import declaration in 2026?

Saurabh Goyal is the Founder & CEO of Phlo Systems. He spent 12 years building CTRM and ERP systems for global commodity trading houses before founding Phlo in 2016.