Entry in the Declarant's Records: removal from Customs Warehousing using EIDR
Entry in the records
Type A warehousing
In order to operate EIDR removals from Customs Warehousing, specific criteria and conditions will have to be met. Additionally, the actual warehousing authorisation must be amended to incorporate these types of removals.
Information on how to approve traders for EIDR removals from warehousing is provided in CFSP17200. Please note that any EIDR authorisation regarding private warehouses may only be granted to the warehouse-keeper.
For guidance on the operation of Customs Warehouses please refer to Guidance R5-3. The guidance provided here purely relates to the operation of CFSP procedures.
As with all other forms of EIDR the release of the goods is affected by making an entry in the EIDR records followed by a SD. In the case of warehouse removals this is a Supplementary Declaration Warehouse (SDW). This SDW, in some cases, requires different boxes to be completed than a normal SD and the statistical processing of the declaration by Customs also differs. For details of the SDW box completion requirements please see CFSP06350.
When goods are being removed from a Customs Warehouse using EIDR, the details of the removal must be entered in the warehousing stock record. The warehouse-keeper must note in the stock account the details of the goods to be removed including the date/time of removals, the DUCR and details of the CFSP authorisation to which they are being released.
Any requirements for prior notification (and dwell time if appropriate) must be adhered to before the goods are removed from the warehouse. See CFSP04500 for details.
Where the warehouse-keeper is not the CFSP EIDR trader the warehouse-keeper must hold a ‘request to remove goods’ from the owner/depositor of the goods. This ‘request to remove goods’ must include a declaration by the owner/depositor of the goods stating that all customs formalities will be adhered to and that the goods are being released under the terms of their CFSP authorisation. The ‘request’ should also include:
- physical location of the goods (if the trader has more than one set of premises)
- date and time of entry into the EIDR record
- stock rotation number/commercial reference
- details of the CFSP authorisation under which they are to be declared
- full details of the goods (quantity, weight, description, Commodity Code (as appropriate), value etc)
- the date and time the removal is to occur
- any requirements for a prior notification of removal as noted in the CFSP authorisation, (including any standing/dwell time - see CFSP04700) to be made to the customs authorities
- DUCR, and
- details of any supporting documents.
The warehouse-keeper should then cross-refer this ‘request’ to the warehouse’s stock records. This ‘request’ and its declaration of intent discharge the warehouse-keeper’s liability for the customs debt. If the warehouse-keeper is not in possession of the above ‘request to remove goods’ before allowing the release of the goods then, under the terms of their warehousing authorisation, they will remain jointly and severally liable with the depositor for any customs debt arising from the release of the goods.
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Entry in the records
The CFSP trader must enter the details of the goods in their EIDR records and include details of the warehousing stock account references to allow a full audit trail of the removal to be established. The entry in the EIDR records and subsequent SDW must also be cross-referenced to the ‘request to remove goods’. The creation of the tax point/base date and the entry in the EIDR records also establishes the date for the submission of the SDW and the tax point (as applicable).
In instances where the EIDR records and the warehousing stock records are combined, the joint records must satisfy the full requirements of both the Customs Warehousing regulations and the CFSP EIDR conditions of authorisation. For details of the Customs Warehousing requirements for the stock accounts please see Guidance R5-3. The CFSP requirements are detailed in CFSP04750.
If the records are separate or where an EIDR depositor uses a public warehouse, the Customs Warehousing stock records must show the name of the EIDR trader and the date of entry in the EIDR records (for receipts where goods are entered into warehouse following Transit, TS and EIDR) and removals as well as any other relevant customs declaration details (see CFSP04750 and Guidance R5-3).
Warehouse-keepers who operate warehousing/ EIDR facilities in several locations may wish to centralise the EIDR/ warehousing stock records in one place. Centralisation of the Customs Warehouse stock account is only allowed if it is a multi sited Type A, C or D warehouse or a Type E warehouse. Otherwise the Customs Warehouse stock account should be maintained at each set of premises where each site holds a separate approval number. Responsibility for the control of such traders will need to be considered in the light of individual circumstances and it may be appropriate to consider the appointment of a head office control team.
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Type A warehousing
When a trader applies to use EIDR to remove goods from a Type A warehouse, there must be a letter from the warehouse-keeper agreeing to the proposal attached to the CFSP application form. It should also confirm that EIDR is indicated in box 14 of the Customs Warehousing authorisation applicable to the Customs Warehouse designated on the CFSP application.
A condition of the EIDR authorisation will be that the authorised trader is to notify the warehouse-keeper of all details of entries in the EIDR records when removing the goods from the warehouse. The letter attached to the CFSP application should outline the procedures that will be used to provide these notifications and the warehouse-keepers acceptance of those procedures.