Guidance

Apply for approval to use premises as an excise warehouse

Find out how to apply to operate premises as an excise warehouse, how to renew or make changes to your approval and what happens if HMRC cancel your approval.

There are 3 types of excise warehouse premises approval that HMRC will consider:

  • general storage and distributions warehouses
  • trade facility warehouses for alcohol and tobacco
  • motor and heading fuels warehouses

You must be an authorised warehousekeeper to operate an excise warehouse.

What you’ll need

When you apply you must include:

  • 3 copies of drawings or plans showing details of the proposed approved area
  • a copy of your premises’ health and safety risk assessment - if this is not practical you can provide an executive summary
  • any other information we may ask for such as business plans

You must also provide a premises guarantee when you apply. Find out about premises guarantees.

How to apply

To apply for approval to operate premises as:

  • general storage and distribution warehousing use form EX68
  • a trade facility warehouse for alcohol and tobacco use form EX69
  • a motor and heating fuels warehouse use form EX70

You’ll need to fill in the forms fully before you can print them. You cannot save a partly completed form, so we suggest you gather all your information together before you begin to fill it in.

Completed forms should be sent to:

HMRC
Excise Processing Teams
BX9 1GL

After you apply

An HMRC officer will visit the premises before approval is given, to check that:

  • the premises are secure and suitable
  • risks to the revenue are managed
  • the environment is healthy and safe to work in

If you’re applying for trade facility warehouse approval, you must provide full details of what you intend to do in the warehouse and be able to demonstrate why operations should be completed in duty-suspension.

Once we’re satisfied that the premises meet our requirements and that there is an authorised warehousekeeper in place for the premises, you’ll receive an approval letter. The letter will set out the conditions of your approval.

If we give approval

We’ll grant new premises approvals for an initial maximum period of 12 months. During this time we’ll carry out checks to make sure your business meets the required throughput levels and trade facility need. We’ll also check that you’re complying with all of the conditions outlined in your approval letter.

If you do not comply with all of the conditions, we may add to, or vary, those conditions, withdraw your approval and consider imposing financial penalties.

You premises approval will only be extended beyond 12 months if we’re satisfied with the way you’re operating your excise warehouse.

If we have any doubt over the validity of the business or you have not fully complied with the terms and conditions set out on your premises approval or excise warehousekeeper authorisation we may either:

  • immediately cancel the approval
  • renew your approval for a further limited period

If we renew your approval for a further limited period, we’ll review your activities again afterwards.

What premises approval covers

Premises approval only covers the premises named in the approval. If you want to open another excise warehouse to hold duty-suspended goods, you must write to HMRC, quoting your excise warehousekeeper authorisation number.

If you want to occupy premises which are currently approved under another approval, you must also hold the endorsement of the current excise warehousekeeper to transfer their premises to you. We consider this a request for approval of a new excise warehouse.

You’ll need to supply the same level of information presented for any new premises application. You will also need to check your level of premises security and, if necessary, arrange for a higher level of security.

We will not grant any new approval until we’re satisfied that you can provide adequate security.

If approval is not given

HMRC may not grant approval if:

  • the warehousekeeper for the premises fails to meet any of the fit and proper criteria
  • there are significant health and safety or security risks identified within the premises
  • the business cannot demonstrate a genuine need for an excise warehouse
  • for general storage and distributions warehouses, either:
    • the warehouse will not meet the throughput or stockholding criteria
    • the premises are too small to justify claimed potential throughput
  • for trade facility warehouses:
    • the premises do not fulfil a particular trade need
    • the premises are not suitable for the intended operations
    • it has not been demonstrated that the trade facilitation must be completed within the duty suspension regime
  • for motor and heating fuels warehouses, either:
    • the applicant cannot provide a minimum one million litres bulk storage capacity
    • the warehouse is for the exclusive use of the applicant or an associated company

These are not the only reasons approval may not be granted. There may be others.

If we cannot approve your application we’ll let you know in writing and tell you why. We’ll offer you a review of our decision.

If you want to renew your approval

If you need your excise warehouse approval to continue past its specified date, you must apply to HMRC for renewal at least 2 months before your approval expires.

We will not renew your approval when:

  • your levels of trade do not meet the required levels of throughput or month-end stockholding
  • you’re not meeting the trade facility you were granted approval for
  • you’ve failed to comply with any of the conditions of your approval

If we cannot renew your approval, we’ll let you know in writing and give our reasons. We’ll offer a review of our decision or you can appeal if you disagree.

If we cancel your approval

We can cancel warehouse premises approval at any time if there’s a reasonable cause.

We’ll usually give you 3 months notice of cancelling, but this period can be reduced if we feel it’s necessary.

If a premises guarantee is withdrawn

We’ll cancel an approval if a premises guarantor has advised us that they’re withdrawing from their guarantee, and you’re not able to provide a replacement premises guarantor.

If you do not comply with rules and conditions

We may cancel or vary your approval if you do not comply with any:

In these circumstances we’ll also cancel your authorisation as an excise warehousekeeper. Excise duty will become due on all excise warehouse goods unless another authorised warehousekeeper takes over responsibility for the premises immediately.

If your approval is cancelled

You must remove all duty-suspended goods from your excise warehouse by doing one of the following:

  • pay the duty
  • move the goods to another approved excise warehouse
  • remove the goods for a purpose which does not attract duty

You must comply with any conditions we impose whilst waiting for the result of a review or appeal of the cancellation.

Changes you must report to HMRC

If you want HMRC to vary the terms of your warehouse approval for a short time or permanently, you must complete either form EX68, EX69 or EX70 again, as soon as possible. You should state what you need and why you need it. An example may be if you want to:

  • include or exclude types of excise goods
  • increase or decrease the approved area

Structural additions or alterations to approved areas, other than routine repairs, would be treated as a change to your existing approval.

You should make sure you have our written consent before you start any work because a failure to advise HMRC of any alterations may result in your approval being withdrawn.

If you currently provide premises security, you must check the level of your guarantee and, if necessary, arrange for a higher level of security. We will not grant any new approval until you can demonstrate that you’re able to provide adequate security.

We’ll let you know of our decision in writing.

Annex warehouses

You may need additional storage space, for example due to seasonal demand. So long as you can provide evidence that you need it, we’ll consider allowing you to use those premises under the terms of your main excise warehouse approval. This is known as an ‘annex warehouse’.

We do not specify the distance between the main excise warehouse and additional premises but you must comply with all of the conditions of the main excise warehouse approval (additional conditions may be added to this approval to specify what operations (if any) may be carried out on the stored goods whilst they are in the annex). If you cannot do this you’ll have to get separate approval for the additional premises.

All the conditions contained in your main excise warehouse approval will apply to any annex excise warehouse we permit you to use.

When premises are transferred to another excise warehousekeeper

Approval does not automatically continue if an authorised excise warehousekeeper sells or transfers their warehouse premises.

The new excise warehousekeeper must apply for a new warehouse approval.

If you disagree with a decision

Find out more about how to appeal if you disagree with our decision.

Published 23 October 2014