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HMRC internal manual

Temporary Storage and Approved Depositories

Approvals: procedure for authorisation

Step Action
1. when an initial enquiry is received from a trader, respond by referring the trader to Public Notice 199A (Temporary Storage) and the National Frontiers Approval Unit (NFAU)
2. if the trader decides that he wishes to become approved as a Temporary Storage Operator, they are to be advised that all new approvals will be issued under the new UCC legislation,  must go on HMRC and complete an expression of interest form,  the NFAU if satisfied will issue  an application pack
3. the completed application for the TS approval must specify the types of goods which are to be stored and if any of the goods subject to additional checks at the place of importation proposed to be held in Temporary Storage, the NFAU will draw the applicant’s attention to the need to liaise with the local control agency responsible for those goods. For example Environmental Health Officer for food products
4. on receipt of the completed application, the NFAU will check that the application has been completed correctly. They will also check other departmental information sources to ascertain whether or not the trader has a good record of compliance with other regimes, for example contact the National Co-ordination Unit (NCU) following the instructions in the Enforcement Handbook, access the Customs Civil Penalty record for numbers of penalties issued and contact NCH Salford for a check on the number of C18s (Customs Debt) issued along with checks at Companies House. A check should be made to see if the Operator has an AEO authorisation, if yes notify the AEO central site
5. upon receipt of the results of the checks, the NFAU will refer the application to the Trader’s local BF supervising Officer who will review the information provided and arrange a visit to the trader to discuss: * the content of the application * that the electronic inventory linking requirements can be met by the operator and ensure the trader has the necessary IT software in place on site * whether or not the terms and conditions can be met * what level of training/advice would be appropriate * explain to the operator, the type of records required to be kept and the necessary information required for the Stock Account record * consider what physical security requirements need to be employed to prevent loss or damage to the goods, including a secure area for un-manifested goods, surveillance equipment for example * review the accuracy of the plan of the premises submitted, especially the outline of the Temporary Storage premises which should be marked in red and location and suitability of the customs examination area and the ullage cage agree a proposed starting date for the approval * whether the guarantee is adequate which may include movements
6. if the local BF Supervising Officer is satisfied that the operator will be able to meet the terms and conditions of approval, they should agree a proposed date with the operator as to when the temporary storage premises will commence operations and must submit a written report to the NFAU recommending approval (initially for a 12 month period) and as part of the visit process the local Supervising Officer/NFAU will ensure that the operator has been allocated a freight location code plus a shed code.
7. upon receipt of the written report containing the BF Supervising Officer’s recommendations to approve, the NFAU will review the officer’s report for any policy inconsistencies or operational problems
8. if everything is satisfactory the NFAU will then send a letter of approval containing a guarantee number (security for any potential Customs debt) and the plan which will be given a unique reference number to the temporary storage operator and the BF Supervising Officer and register the facility as an NCTS office of destination where required (ETSF only)The NFAU will also send an additional copy of the original approval letter to the Operator which must be signed by the operator and returned to the NFAU. The Temporary Storage operator can not commence operations until this is done. The documents will be retained by the NFAU in the trader’s local file
9. if the local Supervising Officer is not satisfied that the operator will be able to meet the conditions of approval, a written report should be submitted to the NFAU explaining that they are recommending rejection of the application and the reasons for the rejection of the application. The NFAU will notify the trader of the decision and their right to appeal accordingly
10. the NFAU will update the national database of temporary storage approvals and arrange for the inclusion of the Operator’s details in the Tariff for example, full name and address including post code, identify of local Customs Authority office approving and controlling the temporary storage premises with an alphanumeric freight location code, plus a three digit code shed
11. send details of the operator to Customs Directorate Tariff Team for inclusion in the Tariff for example, the full name and address including the post code, identity of the local transit office (which should also be the controlling customs office) approving and controlling the temporary storage premises for example alphanumeric freight location code plus shed code
12. before the interim 12 month period of approval has expired NFAU will contact the local Supervising Office to ask them if they are content with the trader’s compliance levels prior to a decision being taken regarding the issue of a temporary storage approval
13. any further routine compliance action should include checks on the accuracy of the approval for example has the approved area been moved/expanded/reduced, has the Operator changed his/her name, have they moved premises. In the event that changes are identified, the trader should be instructed to contact the NFAU immediately to arrange for the issue of a revised approval
14. all visiting officers for example both HMRC and BF officers are required to send the NFAU copies of all their visit reports and to notify the NFAU of any non compliance identified and the issue of any warning letters especially formal Civil Penalty action