I 've had loads of conversations on the phone with various bits of bureaucracy in SEERAD, Perth and I've had conflicting information over the past 2 years. They've never said what you've suggested, though I'd have thought that was the right way to do things. i did once report a movement on under my keeper's CPH and got a call from the animal movement centre saying I'd used an incorrect CPH. The CPH is 89 709 7002. I do think that I should just maybe keep on using it?