Apply for approval as a registered consignor of excise goods
Find out how to apply to operate as a registered consignor of excise goods.
A registered consignor is a person approved by HMRC who dispatches excise goods under excise duty-suspension arrangements on their release to free circulation. This means that all customs duties have been paid or accounted for.
Non-UK goods can be imported into Great Britain through a UK port or airport, non-UK or non-EU goods can be imported into Northern Ireland. They can only be moved in excise duty-suspension to allowable destinations when a registered consignor has started the movement, using the Excise Movement and Control System, following the release of the goods to free circulation.
What you’ll need
HMRC will consider approving you as a registered consignor if you’re:
- an import agent who makes the import declaration on behalf of the importer, using the Customs Handling of Import and Export Freight (CHIEF) system to declare the goods to free circulation (using one of the customs procedure codes listed in the 07 or 68 series of the Tariff)
- an authorised warehousekeeper for the approved UK tax warehouse the goods will arrive at, who receives goods from the place of release to free circulation (for example, from a UK port, airport or inland clearance depot)
- authorised to despatch goods from Northern Ireland to the EU
We’ll also consider approving businesses that can demonstrate a business need to consign their own goods under excise duty suspension arrangements, following their release from Customs control to free circulation.
How to apply
To apply for registration, complete form EX72.
If you’re a partnership, you must also complete form EXCISE102.
The application form must be completed and signed by a responsible person within the business, such as:
- the sole proprietor
- one of the partners if the business is a partnership
- a director
- the company secretary or an authorised signatory if the business is a corporate body
If you’re not an import agent, authorised warehouse keeper or other authorised person (authorised to despatch goods from Northern Ireland to the EU), you must also provide the following information with your application:
- a business plan demonstrating a genuine business need for the approval
- an explanation on how the approval will be used in practice
- what checks you’ll put in place to make sure the imported goods consigned in excise duty suspension are moved in free circulation
Send completed forms and (if needed) your business plan and additional details to the Excise Processing Teams at:
HMRC
Excise Processing Teams
BX9 1GL
You must apply at least 45 working days before the date you want your authorisation to begin. This will give us time to carry out the necessary verification and pre-approval checks, including a visit to your business.
After you’ve applied
All registered consignors must comply with the conditions and restrictions that apply. We may also apply specific conditions which will be listed on your certificate of registration.
Your application will be vetted and we will carry out background checks. We may ask for more information if our checks do not provide us with sufficient assurance that your business is suitable for authorisation. Your application will be put on hold until this additional information is received.
You will receive a pre-approval visit so that we can gather information to help process your application.
During the visit we’ll examine all your business’s activities and may ask about your:
- suppliers
- customers
- business plans
- accounting systems
- premises
- financial viability
Only applicants who can demonstrate that they are fit and proper to carry on an excise business will be granted approval.
We must be satisfied that:
- the business is a genuine enterprise which is commercially viable
- the business has a genuine need for approval
- all persons with an important role or interest in the business are law abiding, responsible and do not pose any significant threat in terms of potential revenue non-compliance or fraud
We’ll assess all applicants, not just the legal entity of the business, but all partners, directors and other key persons.
Key persons are those who play a key role in the operation of the business. For example, they have authority and responsibility for directing and controlling the activities of the business, or day to day management. Significant beneficiaries of the business (who are not directors, partners or similar) are also key persons. They will be assessed against our ‘fit and proper’ criteria to establish that:
- there’s no evidence that the legal entity or key persons involved in the business have been previously involved in revenue non-compliance or fraud, either within excise or any other regime – examples of evidence we would consider are:
- that there have been penalties given for wrongdoing or other civil penalties which suggest a business does not have a responsible outlook on its tax obligations
- there were previous occasions where approvals have been revoked or refused for this or other regimes
- there were previous confiscation orders and recovery proceedings under the Proceeds of Crime Act
- that key persons have been disqualified as a director under company law
- there are no connections between the business, or key persons involved in the business, and other known non-compliant or fraudulent businesses
- key persons involved in the business have no criminal convictions which are relevant, for example, offences involving any dishonesty or links to organised criminal activity
- the application is accurate and complete and there’s been no attempt to deceive
- there have not been failures to comply with any HMRC record-keeping requirements – for example, poor record keeping despite previous warnings, or absence of key business records
- the applicant, or key persons in the business, have not previously attempted to avoid being approved and have traded whilst unapproved
- the business has provided sufficient evidence of its commercial viability and credibility – we’ll not approve applicants where we find that they cannot substantiate that there’s a genuine plan to legitimately trade from the proposed date of approval
- there are no outstanding, unmanaged HMRC debts or a history of poor payment
- the business has satisfactory due diligence procedures in place relating to its dealings with prospective customers and suppliers to protect it from trading in illicit supply-chains
Before approval can be granted, you must demonstrate you have:
- adequate financial security for your warehouse premises
- an accounting system that satisfies HMRC requirements
- adequate IT infrastructure in place which is sufficient to support the business and HMRC systems such as the Excise Movement and Control System
These lists are not exhaustive. If we’re not satisfied with the information you provide to us, we may refuse to authorise you. In addition, if you fail to provide us with the information requested, we’ll place your application on hold until the information is received. We’ll notify you of the reason or reasons for the refusal.
Guarantees
HMRC will only allow an import agent, the receiving warehousekeeper or other authorised person (authorised to despatch goods from Northern Ireland to the EU) to be a registered consignor. The movement, from the place of release to free circulation to the warehouse, must be covered by a guarantee and this may be provided by the:
- registered consignor
- owner of the goods
- consignee (importer) of the goods
- transporter of the goods
If you do not currently have a movement guarantee, you can find out how to apply for one in Notice 197 Receipt into and removal from an excise warehouse of excise goods.
After your application is approved or refused
Application approved
If we accept your application, we’ll issue you with a certificate of registration. The certificate will show:
- your unique registration reference number
- your name and, if different, your trading name
- your address
- any conditions or restrictions that apply to your registration
You should quote the unique registration reference number on all correspondence with HMRC about your approval and any other time you contact us.
If you are approved you must also register for access to the Excise Movement and Control System which will allow you to dispatch goods using this system.
Application refused
If we refuse your application, we’ll inform you in writing and give you our reasons. We’ll offer you a review of our decision. You can request a review by HMRC or appeal direct to an independent tax tribunal. Find out more about what you can do if you disagree with our decision.
When HMRC cancel approval
We may cancel your approval at any time if there’s reasonable cause. If we do, we’ll tell you in writing and give our reasons for the cancellation.
We’ll offer you a review of our decision or you can appeal if you disagree. If your approval is cancelled, you must immediately destroy your certificate of registration.
If you want to cancel your approval
You must write to the Excise Processing Teams at least 30 working days before the date you want to cancel your approval from.
If we agree to cancel your approval, we’ll tell you in writing.
On the date of cancellation you must destroy your certificate of registration.
Changes you need to report
If any information contained on your certificate of authorisation changes, you must tell the Excise Processing Teams in writing within 7 days. When you receive a replacement certificate, you must destroy the previous certificate, or we may impose a financial penalty.
If the status of your business or company changes, for example, a sole proprietor becomes a partnership, the new legal entity must apply to become a registered consignor. We will not automatically approve the new applicant.
Also, if there are any change to the directors or key personnel of the company, HMRC retain the right to review the approval. Following this review, your approval may be withdrawn or have conditions added.
Last updated 24 May 2021 + show all updates
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Guidance updated to explain that you may be considered for approval to be a registered consignor if you're authorised to despatch goods from Northern Ireland to the EU.
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First published.