Temporary removals
How to temporarily remove goods from a customs warehouse.
Applications to remove goods temporarily from a customs warehouse must be made in writing to the supervising office on a case-by-case basis. Details of the supervising office can be found in the customs warehousing authorisation letter. Applications must contain sufficient information to allow the supervising office to make a decision.
The information must include the:
- trade tariff description, manufacturers marks, serial numbers and illustrations or technical description as appropriate
- quantity
- details of the usual forms of handling (UFH) being undertaken, if required
- details of the premises the goods are being temporarily removed to
- intended date of removal and expected date of return
- reason for the temporary removal
- stock rotation or reference number
Failure to obtain authorisation, except in the case of force majeure where goods are temporarily removed without prior approval, results in the goods being considered unlawfully removed from customs supervision and a customs debt is incurred.
The goods must normally be returned to the same customs warehouse from which they were temporarily removed. Exceptionally, where prior authority has been given, the goods may be placed in another customs warehouse on the condition that the appropriate transfer formalities are used.
All warehousekeepers are required to notify the supervising office of the return of temporarily removed goods within 7 days of their receipt back at the customs warehouse. Details of the supervising office can be found in the customs warehousing authorisation letter.
The maximum period that goods can be temporarily removed from the customs warehouse is three months. However, where the circumstances can be justified, this period can be extended.
There is no upper time limit for this extension, but extensions exceeding two months are exceptional.
If the goods are not returned to the customs warehouse within the approved time limit, a customs debt is incurred.
However, if the goods are returned within a period that would have been allowed had an extension request been submitted to the supervising office (details of the supervising office can be found in the customs warehousing authorisation letter), no customs debt will be considered to have been incurred. This is on the condition that:
- there was no attempt to unlawfully remove the goods from customs supervision
- there was no obvious negligence on the part of the person concerned
- the necessary formalities to rectify the situation in relation to the goods can be carried out
Where temporary removal is to be a regular part of the warehousekeeper’s activities, for example, vehicles requiring Single Vehicle Approval (SVA) tests, general permission may be granted within the authorisation. The general permission removes the requirement to submit a separate notification for each removal and return — instead, the required information is entered in the stock records. A general permission is a simplification and as such, the warehousekeeper must have a compliant history. Any contraventions of these conditions can result in the removal of the general permission and return to individual notification.
Temporary removal of goods for the sole purpose of viewing is permitted. However, viewing in this context cannot be applied to items temporarily removed for display at a venue which allows public access, such as, fairs, galleries, or exhibitions.
Retail sales not permitted whilst goods are temporarily removed from the customs warehouse.
Goods should not be temporarily removed from the customs warehousing procedure to fairs, gallery displays or exhibition in the UK. In such cases, the trader must choose one of the following options:
- make a declaration for the goods to be released for free circulation with Customs Duty and import VAT paid — once the declaration is made, the goods can be moved using commercial documentation
- make a declaration for the Temporary Admission (TA) procedure if the goods will be put to a specific use in the UK — to do this, the trader must hold a full TA authorisation
If the goods are incidentally sold (other than by retail sale), they must still be returned to the customs warehouse to discharge the customs warehousing procedure before they can be released for free circulation, provided that the appropriate duties and import VAT are paid. HMRC expects this to be the exception rather than the norm.
Temporary removal of goods is not permitted if they are being taken from the customs warehouse to private premises for any purpose, such as auction. This is because the auction’s objective is to facilitate a sale.
The warehousekeeper may require a temporary removal authorisation to undertake a specific UFH. While the goods are outside of the warehouse they may undergo UFH subject to it being one of those listed on check if you can carry out simple repairs or process your goods in a customs warehouse.
More information can be found at usual forms of handling (UFH).