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HMRC internal manual

Customs Authorisation and Approval

HM Revenue & Customs
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Overview of customs regimes and procedures requiring prior authorisation or approval: Storage

Economic operators may be permitted to store non-Union goods in premises or any other location approved for that procedure by the customs authority and which is under their supervision.

The Storage procedure under the Code (as specified in article 210) comprises of Customs Warehousing and Free Zones.

Any person may use a customs warehouse for the customs warehousing of goods (public customs warehouse) or for the storage of goods by the holder of an authorisation for customs warehousing (private customs warehouse).

Where goods present a danger or are likely to spoil or require special facilities for other reasons, the authorisation may require them to be stored in specially approved storage facilities.

Free zones are enclosed areas with restrictions on the entry and exit of goods and persons.  The construction of any buildings within a free zone is subject to prior approval from the customs authorities. 

Commercial, industrial and service activities are permitted within a free zone however restrictions may be placed on operations for specific types of goods or for safety and security purposes

Non-Union goods are deemed to be under the free zone procedures when:

·        They are brought directly into the free zone from outside the territory of the Union

·        A customs procedure is discharged or ended by placing the goods under the free zone arrangements

·        They are placed under the free zone procedure in order to benefit from a remission or repayment of duty

·        Where legislation other than customs legislation provides for such formalities

The following benefits are available to economic operators authorised for storage:

·        Goods under the customs warehousing or free zone procedures are stored in duty suspense arrangements, duties do not become due on the goods until they are released to a customs procedure involving the payment of duties and other charges (i.e., free circulation)

·        Goods may be temporarily removed from a customs warehouse providing prior authorisation is granted

·        Goods may be moved between locations using the storage arrangements

·        Union and non-Union goods may be stored in a free zone or customs warehouse.

·        Equivalence may be authorised for customs warehousing. Equivalent goods consist of Union goods which are used, stored or processed instead of the goods originally placed under a customs procedure.  The amount of equivalent goods used, processed or stored must not exceed the amount originally entered to the procedure.  Equivalence cannot be authorised for goods subject to Anti-Dumping Duty.

The introduction of the Code has resulted in the following changes for storage:

·        Introduction of the ability to make retail sales remotely for goods within the customs warehousing procedure

·        The ability, subject to prior authorisation, to process goods under inward processing or end-use within the confines of the customs warehouse

·        Any sales (retail or trade) taking place whilst the goods are still within the customs warehousing procedure (i.e., prior to their release to free circulation) will affect the customs valuation.  The sale price must be used as the customs value on their release.

·        Approval to operate storage is dependent upon the provision of a guarantee to secure the potential debt

·        Removal of type D arrangements.  Please see sections CAA04100 and CAA04110 for details of the transition arrangements for type D warehousing authorisations.

·        Previous type E warehouses (based on a records only system) has been removed.  All locations or premises where goods are stored must be named on the customs warehouse authorisation

·        The ability to enter goods to a customs warehouse using SDP or EDIR without submitting a supplementary declaration.

Type D warehousing authorisations may be used, to import goods to customs private warehousing arrangements during the transition period until the warehousing authorisation is reassessed or 30 April 2019, whichever is earliest.  Type D warehousing authorisation holders will be issued with an amended authorisation with a prefix of:

·        C (if it is currently only a type D authorisation) or

·        E (if it is currently a type E with D rules of assessment). 

All entries to the warehouse made after 30 April 2016 must be made in accordance with the Code rules for a Private Warehouse, using the normal customs debt rules of assessment.