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HMRC internal manual

Customs Authorisation and Approval

Criteria and Conditions of Authorisation or Approval: Matrix of criteria required for Temporary Storage and Approved Depositories

Generic Criteria, mapped against AEO standards UK Explanation of the criteria Required Y/N Legal Basis for criteria
Compliance History of Applicants      
The absence of any serious infringement or repeated infringements of customs legislation and taxation rules, including no record of serious criminal offences relating to the economic activity of the applicant by any of the following persons: Demonstrate a good compliance history in customs and other taxation areas including the absence of serious or repeated irregularities or criminal offences (including the legal entity and any company officials).  YOther taxes - new A.148(2) Code
The criterion referred to above shall be considered as fulfilled where the decision-taking customs authority considers any infringement to be of negligible importance, in relation to the number or size of the related operations, and not such as to create doubts concerning the good faith of the applicant. Customs may consider applications from companies with a past history of non-compliance where these are deemed to have a negligible impact on the procedure applied for. Y A.148(2) Code
Management of customs operations, including internal controls and record keeping      
The demonstration by the applicant of a high level of control of his or her operations and of the flow of goods, by means of a system of managing commercial and, where appropriate, transport records, which allows appropriate customs controls Effective internal controls to manage customs processes and regimes including the maintenance of appropriate documents and records. Y A.147(3)A.148(2)(b)CodeDA A. 116
Maintain an accounting system which is consistent with the generally accepted accounting principles applied in the Member State where the accounts are held and which will allow audit-based customs control. Records kept for customs purposes shall be integrated in the applicant’s accounting system or, at least allow the cross check of information with the accounting system and in such a way enabling all relevant information to be made available. The accounting system shall maintain a historical record of data that provides an audit trail from the moment the data enters the file Clear audit trails of the import, export, movement and transfer of goods within customs procedures.  Clearly documented audit trails between customs declarations, stock records and commercial documentation. Y A.145(2) CodeDA A.116
Allow the customs authority physical and/or, where required by law or depending on the form in which the records are kept, electronic access to its customs and, where appropriate, commercial and/or transport records Access provided at an agreed place of business to the commercial and customs records necessary to verify the use of the procedure.    
Where necessary, allow targeting teams remote electronic access to customs, commercial and transport record systems. Y A.145(2) Code  
Have a logistical system which identifies and distinguishes between Union and non-Union goods and, where appropriate, their location, except in the cases where the applicant applies for an AEOS; Clear audit trails to identify Union and non-Union goods and their locations (as appropriate) Y A.145(1) CodeA.148(6) Code
Have an administrative organisation which corresponds to the type and size of business and which is suitable for the management of the flow of goods, and have internal controls capable of preventing, detecting and correcting mistakes and of detecting illegal or irregular transactions; Appropriate internal management controls to verify the accuracy of customs declarations, ensure the correct operation of procedures and to identify and correct irregularities/ mistakes Y A.148(3) Code
Where applicable, have satisfactory procedures in place for the handling of licences and authorisations connected to commercial policy measures or to trade in agricultural products; Procedures for administering licences, health certificates, preferential origin documentation and other official documentation relating to the import and/or export of  goods N  
Have satisfactory procedures in place for the archiving of the company’s records and information and for protection against the loss of information; Have appropriate retention procedures in place to manage the archiving of all documentation relating to the import, movement, transfer, transit and export of non-Union goods as required by customs legislation Y A.148(4) Code
Ensure that relevant employees are made aware of the need to inform the customs authorities whenever compliance difficulties are discovered and establish suitable contacts to inform the customs authorities of such occurrences; Procedures in place to inform employees, agents and third parties of the requirements of the customs procedure and ensure mechanisms are in place for any irregularities/ mistakes to be notified to the customs authorities Y A.148(3) Code
Have appropriate information technology security measures in place to protect the applicant’s computer system from unauthorised intrusion and to secure the applicant’s documentation; Adequate IT security measures to protect systems and data, e.g., firewall, antivirus programme, password protection Y A.148(4) Code
Where applicable, have procedures in place for the handling of import and/or export licences connected to prohibitions and restrictions, including measures to distinguish these goods from other goods and to ensure compliance with these prohibitions and restrictions. Procedures in place to manage licences relating to prohibitions and restrictions and adequate management controls to ensure health and safety and compliance in this area. N  
Guarantees are mandatory for this type of application and therefore the Financial Solvency criteria do not apply      
Practical experience and competency in customs operations      
With regard to the authorisation referred to in point (a) of Article 38(2), practical standards of competence or professional qualifications directly related to the activity carried out; Demonstrate a good understanding of customs procedures and operational requirements Ynew A.148(2) Code
For the practical standards of competence: Have practical experience in the import, export, movement, transfer or transit of goods Ynew A.148(2) Code
A minimum of three years practical experience in customs matters has been ascertained; or For businesses with less than 3 years trading history:·        Understand the obligations of operating the customs regime and demonstrate how the terms and conditions will be adhered to·        Demonstrate a good understanding of the obligations involved in importing, exporting, using transit (as appropriate) Y A.148(2) Code




Generic Criteria, mapped against AEO standards UK Explanation of the criteria Required Y/N Legal Basis for criteria
Security and Safety of the supply chain and goods held within procedures      
Appropriate security and safety standards, which shall be considered as fulfilled where the applicant demonstrates that he or she maintains appropriate measures to ensure the security and safety of the international supply chain including in the areas of physical integrity and access controls, logistical processes and handling of specific types of goods, personnel and identification of his or her business partners. Have robust access security and inventory controls to prohibit the removal of goods from the premises prior to customs release being granted Y A.145(6) Code
A.147(3) Code        
  Buildings to be used in connection with the operations to be covered by the AEO authorisation are constructed of materials which resist unlawful entry and provide protection against unlawful intrusion; Demonstrate clear procedures for the control of access to storage premises Y A.147(3) Code
  Appropriate access control measures are in place to prevent unauthorised access to offices, shipping areas, loading docks, cargo areas and to other relevant places; Have agreed areas for the safe storage of goods ‘held’ by customs or items identified as P&R/ subject to admissibility controls Y A.147(3) Code
  Measures for the handling of goods include protection against the introduction, exchange or loss of any material and tampering with cargo units; Have robust procedures in place to prevent unauthorised access to, tampering with or removal of goods held within storage procedures Y A.147(3) Code



Bespoke Requirement applicable to TS    
Bespoke Requirements UK Explanation of the criteria Legal Basis for criteria
Phase II inventory system Appropriate electronic system for the management of goods in Temporary Storage which must enable customs authorities to supervise the operation of temporary storage facilities including identification, status and movement of goods. Access to the Operators chosen ITSF Stock Account Record and associated Anti-Smuggling Net, where separate must be provided to the assigned Border Force Parent Port responsible for the control of goods at the ITSF (as stated in the approval letter) and/or to any other UK Customs authority office requested (for example Local Compliance CITEX, Large Business, the National Clearance Hub Salford) where access to the system is required to maintain control of the goods at the ITSF by the UK Customs authorities. A.148(4) Code
IA A.192      
  ASN Anti-smuggling net is to be provided to enable customs authorities to exercise control of goods in temporary storage. A.148(3) Code
  Employee list (NICs) A record of all visitors, vehicles and staff working at, or visiting the premises must be maintained in the manner prescribed by the customs authorities. This record must be available for inspection by the customs authorities on request and assists with non-compliant activity A.148(2)(b)
  H&S Checks Provide safe working conditions for all customs authority staff attending the premises including safe means of access to containers and/or vehicles. The working conditions must meet the standards set by the competent safety authorities. A Health and Safety Risk Assessment specific to the temporary storage premises must be provided to the customs authorities on request. Health and Safety at Work Act 1974.
  90 days clearance reports Non Union goods in temporary storage shall be placed to a customs procedure or re-exported within 90 days A.149 Code
  Specially equipped storage facilities Customs authorities may specify that where goods require special facilities they may only be stored in temporary storage facilities specially equipped to receive them.  
  DA A.117    
  Period of validity Temporary Storage authorisations will not have a period of validity unless required  
  Handling of Temporary Storage goods
  Temporary Storage goods shall not in any manner be interfered with (including de-consolidation) altered, unpacked or otherwise interfered with nor removed from the facility without explicit permission from the UK Customs authorities. A.147(2) Code
  Ullage cage Within the approved temporary storage premises a secure, lockable compartment/area (generally referred to as the ‘ullage cage’) for storage of any un-manifested, prohibited or suspicious goods and/or detained or seized goods subject to customs authority investigation. The structure and condition of the cage must be maintained to a standard adjudged suitable by the customs authorities.
The required size of the ullage cage will be that as agreed by the customs authority at the time of the facilities pre-approval visit but it will need to be proportionate to the size and commercial operation of the facility. A.148(1) Code  
  Movement within temporary storage facilities Movements between temporary storage facilities in the UK- Goods will be able to move, subject to certain conditions between temporary storage facilities under cover of the authorisation.
Movements between member states – moving goods to an authorised holder in another member state may be carried out under cover of the authorisation provided that both parties are AEO(c) authorisation holders and with agreement between the customs authorities in both member states.  A.148(5) Code

DA A.118

IA A.193      
  Guarantee A Guarantee will be required to operate a temporary storage facility. A.148(2)(c)


Please refer to HMRC guidance Temporary Storage & Approved Depositories (TSAD Manual) for the complete list of requirements.