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HMRC internal manual

Holding and Movements Assurance Guidance

Registration and approval: Reasons for refusing excise warehouse approval applications

Reasons for refusing an application include:

  • applicant provides false information with the clear intention to deceive;
  • there are significant health & safety or security risks with the premises, or applicants with two or more employees fail to provide a satisfactory documented premises health & safety risk assessment;
  • applicant cannot demonstrate a genuine business need for the warehouse, or any trade facilitation application includes an element of storage that is outside the need for the trade facilitation.
  • the general storage and distribution warehouse will not or does not meet the throughput or stockholding criteria; for example, the premises are to small to justify claimed throughput;
  • premises do not meet a particular trade need or are unsuitable for intended operations;
  • trader is unable to provide a financial security for the premises or duty deferment account (where required);
  • the operation is not commercially viable given its lifespan to date and business plan - many businesses will expect to operate at a loss initially but this should be expected to be taken into consideration within their overall business plan (Departmental Accountants are available to support officers when considering the viability of a trader);
  • the proposed occupier of the warehouse, or other key persons involved in the management of the premises represent an unacceptable risk to the revenue as a result of a lack of suitability, probity or previous/current compliance issues associated with them;
  • the systems in place to receive, store and release goods do not meet our requirements;
  • proposed record and accounting systems are inadequate.

The list is not exhaustive.