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HMRC internal manual

Holding and Movements Assurance Guidance

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HM Revenue & Customs
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Registration and approval: issuing revocation notices to authorised warehousekeepers

This section should be read alongside HMAG31800 which covers revocation of warehouse premises.

There is no stipulated time limit for revocation of a warehousekeeper authorisation (WOWGR regulation 4). A notice period of one month should be provided to the warehousekeeper. The notice period for revocation of the premises approval remains at 3 months (to allow a reasonable time period for all duty-suspended goods to be removed), therefore the premises approval and warehousekeeper authorization will not expire together.

The warehousekeeper has one month in which to find another authorised warehousekeeper to take control of the approved warehouse. If he fails to do so, the warehouse can no longer receive or hold excise goods under duty suspension once the one-month notice period expires (WOWGR regulation 9).

Immediate revocation of the warehousekeeper authorisation should be avoided. Such action causes an immediate duty point under WOWGR regulation 20(2), for all goods held within the warehouse premises and would cause unreasonable disruption and logistical problems for the warehouse, their clients and officers. Risks posed by the continuing operation of a warehouse during its period of notice should be addressed by imposing conditions and restrictions on the premises approval.

The notice of revocation must be provided in writing and where possible hand delivered to the warehousekeeper. It should be delivered in conjunction with the notice of revocation for the premises approval.

The notice must include:

  • the period of notice and the date on which the warehousekeeper’s authorisation expires;
  • provide a clear statement as to the reason(s) for revocation (e.g. incidents and level of non- compliance);
  • state the warehousekeeper’s right of appeal and how to do so.

The notice must explain the effects of revocation and should include:

  • that if the occupier of an approved excise warehouse ceases to be authorized under WOWGR, excise goods cannot be stored under duty suspension in that particular warehouse unless another authorized warehousekeeper applies for transfer of the warehouse approval;
  • that goods can only be removed from the warehouse duty paid, unless revocation conditions stipulate differently, prior to the end of the notice period;
  • where necessary clarify the effect of the revocation notice on other regimes (i.e. customs warehouse approval as appropriate);
  • no further receipts of duty-suspended goods into the warehouse;
  • no removals from warehouse without the knowledge of the officer dealing with the revocation.