Designated Export Place overview

Provides information on what a Designated Export Place is.

What a Designated Export Place is

A Designated Export Place (DEP) is a Customs approval that approves a business’s premises to meet the Presentation requirement of the common export procedure. DEPs are an export only approval and is not used for import declarations.  

A DEP approval can be used to export goods in free-circulation or currently under a UK customs procedure. DEP premises are permitted to be used with all customs procedures and all export simplifications, except the exclusions listed below, and allows any goods, including goods subject to licence at export, to be presented to HMRC at the DEP operator’s approved premises.  

The following exclusions apply to DEP approved locations and may not be presented for export at a DEP approved location: 

  • goods currently under the Customs Warehouse procedure
  • goods declared for export using Entry Into Declarant’s Records (EIDR)

The common export procedure is a 4-step process which requires a declaration to be: 

  1. lodged with HMRC
  2. presented to HMRC 
  3. granted clearance for export by HMRC 
  4. notified as exported to HMRC

The second step, presentation to HMRC, which is the act of legally making an export declaration to HMRC, usually includes both a Notification of Export, advising HMRC that the export declaration is being presented for export, and a requirement to make the goods available for physical examination at a Place of Presentation approved by HMRC, which is usually an approved border location. 

A Notification of Export will prompt HMRC to issue a decision on whether the goods can be exported from the UK or not. HMRC’s decision will take the form of either clearance being granted to export the goods, also referred to as permission to progress (P2P), or the goods being held for a customs check, sometimes referred to as a Customs hold or NonP2P. The goods will need to remain at the Place of Presentation, regardless of whether a physical examination is required, until HMRC issue clearance to export. 

At border locations approved for the Standard Export Model, presentation to HMRC always occurs at the approved border location. At border locations approved for the Arrived Export Model, presentation to HMRC will occur when the declaration is lodged with HMRC, and the goods do not physically have to be at a Place of Presentation. However, the goods must be presented to HMRC for physical examination if required and this will need to be an approved Place of Presentation. In most cases this will not be the approved border location, and the goods will need to be presented to HMRC at another approved Place of Presentation such as an Inland Border Facility or a DEP.

A DEP approval allows the business to make the Notification of Export and the goods available for physical examination at the business’s approved premises rather than at an approved border location, Inland Border Facility or Customs Supervised Export location. 

A DEP approval meets the presentation requirement of the common export procedure via the DEP operator submitting the Notification of Export in the form of an electronic arrival message (EAL) to HMRC. With the Notification of Export indicating that goods are being presented to HMRC at the DEP operator’s approved premises. 

Once HMRC receive the Notification of Export they will issue a decision to the DEP operator on whether the goods are cleared for export or held for a customs check. The DEP operator will be required to act on that decision, by either facilitating their immediate export from the UK or holding them at the DEP operator’s approved premises for HMRC or Border Force to complete any Customs checks. 

When a DEP approval is used for export presentation, all initial customs checks including both documentary and physical examination, will be conducted whilst the goods are held in Customs Control at the DEP operator’s approved premises, rather than at an approved border location.  

The Notification of Export to HMRC can be submitted for electronic export declarations the DEP operator lodged with HMRC themselves, such as being the exporter or acting as a representative on behalf of the exporter, but usually the DEP operator will be submitting the Notification of Export to HMRC for electronic export declarations made by other parties. 

When used for an export, a DEP approval completes the second and third step of the common export procedure at the DEP operator’s approved premises, with a second presentation (known as re-arrival) and Notification of Export being made to HMRC at the approved border location where the goods will exit the UK, excluding locations operating the arrived export model via GVMS. All goods presented to HMRC at a DEP operator’s approved premises can be subject to a second customs check at the border, sometimes referred to as a counter-substitution check, to ensure the goods remain as presented to HMRC at the DEP operator’s approved premises. 

As DEP operator’s approved premises will not be at the UK border, they are not permitted to submit the Notification of Exit to HMRC to confirm the goods have been exported from the UK. Notification of Exit can only be submitted from an approved border location once an approved party at that location has confirmed the goods have physically exited the UK.

DEP used with a Standard Export Model border location

  1. lodgement of declaration
  2. presentation at DEP location
  3. customs check completed at DEP location
  4. re-arrived at border location
  5. possibility of secondary check
  6. notification of exit

DEP used with an Arrived Export Model border location (Goods Vehicle Movement System (GVMS) only)

  1. lodgement of declaration
  2. presentation at DEP location
  3. customs check completed at DEP location
  4. declaration added to Goods Movement Reference (GMR)
  5. P2P reconfirmed
  6. possibility of secondary check
  7. notification of exit

What a Designated Export Place doesn’t provide

A DEP approval is not: 

  • a simplification of the requirements of the common export procedure, as in all circumstances its use at export increases the number of steps an exporter or declarant has to make to export goods from the UK
  • an approval to lodge export declarations with HMRC. The ability of a UK established business to make export declarations is not authorised by HMRC and the only barrier to making an export declaration is usually holding a valid UK EORI number and having access to appropriate export declaration software
  • an approval to speed up Customs clearance or remove checks at export, instead a DEP approval allows most documentary checks and physical examinations to be conducted at the DEP operator’s approved premises. For DEP operators, this provides certainty in most cases that there will be no further delays at the border due to customs checks. However, as a counter-substitution check may occasionally also occur at an approved border location prior to exit from the UK, DEP movements are potentially subject to more checks than standard movements
  • an approval to allow the consolidation of goods prior to export, although a DEP approved premises can be used for both physical consolidation and consolidation to a Master Unique Consignment Reference (MUCR), HMRC doesn’t authorise businesses for export consolidation meaning the premises would usually be permitted to undertake consolidation, prior to presentation to HMRC, even if a DEP approval was not held by the business
  • an approval of a border location - Border locations are approved by the National Frontier Approvals Unit in Border Force

DEP requirements

To use a DEP approval at export the DEP operator must act as the party making the Notification of Export to HMRC. This is because presentation to HMRC occurs when the DEP operator submits   a Notification of Export in the form of an electronic arrival message (EAL) when the goods are available at the DEP operator’s approved premises for physical examination. As the DEP operator is the party making the Notification of Export, they are legally responsible for acting on any instruction issued in response to the Notification of Export by HMRC, especially preventing any onward movement of the goods if required. 

As a DEP operator will be presenting both the electronic export declaration and the goods to HMRC to gain clearance for export, they must have physical control of the goods at the location they are presenting them, meaning the DEP operator must own or have the legal right of access to the premises approved as a DEP, such as a rental or lease agreement. As Border Force or HMRC officers may need to routinely attend the premises the DEP operator must have the legal right to grant them access to both the premises and any goods presented to HMRC there. 

As the DEP operator is required to submit the Notification of Export to HMRC, they will require suitable software to submit an arrival message (EAL). This software can take the form of either the free HMRC service or suitable commercial software. Goods can be presented to HMRC at the DEP operator’s approved premises via a an EAL message using either a Declaration Unique Consignment Reference (DUCR) or a Master Unique Consignment Reference (MUCR) where goods and export declarations have been consolidated.

The difference between a DEP approval and a CSE approval

CSE and DEP approvals both allow a Notification of Export to be made at a business’ approved premises. However, at a CSE premises this is achieved via a declaration being submitted to CDS in an ‘arrived’ state. CSE approval holders must therefore always act as the declarant for goods presented at a CSE premises. CSE declarations should not be re-presented at a DEP location or vice versa.

UK legislation applicable to DEP for exports from Great Britain

DEP Approvals are covered by the following UK Legislation: 

Customs (Import Duty) (EU Exit) Regulations 2018 – CIDEER:

Customs (Export) (EU Exit) Regulations 2019 – CEEER:

A business’s premises will be approved by HMRC under Regulation 59 of CEEER as an appropriate place for the examination of goods declared for export, for the purposes of CEEER Regulation 40(6A). The business will notify HMRC that the goods are available for examination by making a Notification of Export as per CEEER Regulation 51. The business will use their DEP approval to present goods to customs supervision and potential customs controls at their premises, as per CEEER Regulation 41, before they can be released for export, as per CEEER Regulation 49.

UCC legislation applicable to DEP for exports from Northern Ireland

DEP Approvals are covered by the following Union Customs Code (UCC) Articles: 

  • Article 5(3) – customs controls
  • Article 5(27) – customs supervision
  • Article 5(33) – presentation to customs
  • Article 158(3) – customs supervision of Union goods on export
  • Articles 170 and 172 – presentation of goods following customs declaration (including export declarations)
  • Article 194 – release of the goods (including for export)

A business’s premises will be approved as a place at which goods may be presented to HMRC when an export declaration is lodged, as per UCC Articles 170 and 5(33). The business will use their DEP approval to present goods at their premises, where they will be subject to customs supervision and available for customs controls  from the time that the export declaration is accepted, as per UCC Article 158(3), before they can be released for export, as per UCC Article 194.