Common storage: establishing eligibility
Before authorising common storage, the following criteria must be satisfied:
Are the goods the same?
That is, do the goods have the same 8-digit CN code, the same commercial quality, the same technical characteristics and the authorisation holder cannot, and does not, differentiate between the goods.
Is assurance affected?
You must ensure that the granting of common storage will not adversely affect assurance, for example CAP goods with examination/sampling requirements to be satisfied, or goods subject to anti-dumping duty.
Are the records capable of monitoring activities?
The authorisation holder records must be able to identify what goods are the same and be able to monitor them correctly. This includes ensuring that safeguards are in place to prevent removals to free circulation where restrictions apply, for example, that there is an appropriate valid licence available for goods subject to licensing.
You must be satisfied from the information provided in the records that you will be able to verify, on a risk assessment basis, that the goods are the same. Normally, criteria detailed in Notice 3001 should be sufficient; this will avoid costly and time-consuming analysis of goods.
However, trade or independent analysis will normally be required for agricultural goods or bulk goods such as oils and chemicals. If you have any doubts that the goods are the same, then you must take samples for laboratory analysis. Further samples may be required, on a risk basis and at periodic intervals, to ensure that the common storage criteria continue to be met.