Business tax – guidance

Customs warehousing

How to set-up and use a customs warehouse to store goods with duty or import VAT suspended.

A customs warehouse allows traders to store goods with duty or import VAT payments suspended.

Once goods leave the warehouse duty must be paid, unless they’re re-exported or move to another customs procedure.

You must be authorised by HM Revenue and Customs (HMRC) to run a customs warehouse.

Goods you can store in a customs warehouse

You can store goods in a customs warehouse if they’re:

You can also put goods into a customs warehouse if:

  • you don’t know the final destination of your goods when they arrive in the UK
  • your import licences or paperwork have been delayed, or you’re waiting for a duty-relief quota to become available (for example, for agricultural goods)
  • you want to use another customs procedure (for example, Inward Processing for non-excise goods)

How to set up a customs warehouse

To run a customs warehouse you must be an authorised warehouse-keeper. Use form SP2 to apply to HMRC for authority.

To qualify as a warehouse-keeper, your business must:

  • be established in the EU
  • use the warehouse to mainly store goods
  • prove there’s a real economic need, and you’ll have enough clients or business to run the warehouse
  • be able to comply with the conditions of authorisation
  • provide a financial guarantee

You don’t need to own the premises to be a warehouse-keeper, but you must keep stock records and maintain and operate the warehouse to health and safety standards.

Warehouse-keeper responsibilities

If you’re a warehouse-keeper you must:

  • meet HMRC’s conditions for your authorisation
  • check goods when they arrive and record any shortages or surpluses
  • set up stock records for goods and keep them secure
  • keep stock records for at least 4 years
  • give HMRC officers access to the warehouse, goods and records
  • run the premises safely and make sure the warehouse meets Health and Safety standards

Depositor responsibilities

Traders who place goods into a warehouse are known as the depositor.

If you’re a depositor you have responsibility for the declaration used to put goods under customs warehouse procedures. You must:

  • accurately declare the goods entered into the warehouse
  • make sure your goods go straight to the warehouse shown on the declaration - within 5 days of your customs declaration being cleared
  • give the warehouse-keeper details of the declaration and explain any differences found between the goods deposited and the declaration
  • make sure the warehouse-keeper is authorised to store the type of goods you want to deposit
  • make sure you accurately declare goods when they’re removed from the warehouse

You’re also responsible for any customs debt from declaration errors.

Get an agent to make declarations on your behalf

There are 2 ways your agent can enter goods into a customs warehouse for you:

  • direct representation - where the agent enters goods on your behalf, in your name - you’re responsible for any customs debt due from errors
  • indirect representation - where the agent enters goods on your behalf, in their own name - you’re jointly liable for any customs debt due from errors

Make sure you give clear written instructions for the goods to be entered, and check any paperwork. If you’re a depositor and your agent is entering your goods into a public warehouse, you must check the paperwork your agent sends to the warehouse-keeper is correct.

Types of warehouse

There are 2 types of customs warehouse:

  • public warehouses (Type R) - operated by a warehouse-keeper to store goods deposited by other traders
  • private warehouses (Type U) - operated by an individual trader who acts as depositor and authorised warehouse-keeper for the storage facility - they don’t need to own the goods, but must be the depositor

How to enter goods into a customs warehouse

Traders can enter goods into a customs warehouse:

Traders can use CFSP to declare goods to customs warehousing. You can find detailed information on CFSP in Notice 760.

Once you’ve checked space at the warehouse of your choice, you or your agent must complete the Single Administrative Document (SAD) (form C88) and present it to the National Clearance Hub.

Errors made on this form could leave you liable to a customs debt.

Use volume 3 of the UK Trade Tariff to help you complete the SAD.

You can also see information on all the boxes that need to be completed in the guide on the Single Administrative Document for import and export.

You must move goods to the approved customs warehouse within 5 days of your declaration.

Extra checks or controls

There are extra controls for warehouses used to store excise goods.

Goods subject to prohibitions or restrictions must have had the appropriate documents shown when they arrived at the EU border.

Meat or meat products must also have been through veterinary checks at the EU border before they enter the customs warehousing procedure.

If you receive goods from another customs warehouse

You must declare goods received from another customs warehouse on the SAD (form C88).

How you can handle goods in storage

Customs warehouses are for the storage of goods, but some minor handling (known as ‘usual forms of handling’) is allowed to:

  • make sure goods are preserved
  • improve the presentation or marketable quality of goods
  • prepare goods for distribution or resale

These forms of handling must be authorised by HMRC before they take place. This is usually arranged at the same time as your authorisation to operate the customs warehouse.

Use form SP2 to get authorisation from HMRC if you need to:

  • temporarily remove goods to carry out a usual form of handling
  • remove samples of goods

You must receive authorisation from HMRC before your remove anything and keep full records for both situations.

You can find detailed information on handling customs warehousing goods in Notice 3001.

If you need remove goods from a customs warehouse to process them, you’ll need to transfer them to Inward Processing. You can only do this if you intend to re-export the goods afterwards.

Common storage

Common storage arrangements let you make best use of your warehouse space by storing goods of different customs status together.

You can also store Inward Processing goods as long as the status of your goods can be identified at all times. You must tell HMRC and keep full records.

If you don’t know the current customs status of all the goods you want to keep together in common storage (under customs warehousing or Inward Processing) you can still store them together, as long as the goods have the same:

  • eight-digit commodity code
  • commercial quality
  • technical characteristics

How to remove goods from a customs warehouse

Goods you release to free circulation

If you release goods to free circulation this means:

  • you remove goods from the customs warehouse procedure
  • all duties are paid
  • the goods enter the EU open market

Duties due on goods you release from the customs warehousing procedure

When you release your goods from the customs warehousing procedure, you may have duties and taxes to pay. You can work this out using:

If you move goods to another customs procedure

You won’t be liable to a customs debt if you move customs warehousing goods to another customs-approved treatment or use, for example re-export.

If you do this you must make a SAD (form C88) declaration and use the customs code for the procedure the goods are entering.

If you transfer goods to another customs warehouse

When you’re authorised to use a customs warehouse, HMRC will tell you which methods you can use to transfer goods. HMRC may also ask to examine your goods.

Use part 3 of the SAD (form C88) to move goods to another customs warehouse.

You must make sure the warehouse-keeper is authorised to receive the goods you’re transferring to them. You’ll also need to deal with any simplified transfer procedures.

You can move goods between:

  • the same authorisation
  • different authorisations
  • the same EU country
  • different EU countries

If you re-export goods from a customs warehouse

You can use the National Export System to re-export goods. The system is electronic, so reduces paperwork and approval times.

How to get help

You can find more information on imported goods, customs procedures and customs debt in Notice 199.