Many traders choose to set up as warehousekeepers and operate their own private customs warehouse, either premises or systems based. A customs warehouse must be authorised by HM Revenue & Customs (HMRC) before it can accept goods for storage in duty suspension. To be authorised, your business must:
- be established in the European Union
- use the warehouse primarily to store goods
- prove there is a real economic need for a customs warehouse and that you will have enough clients or business to make the operation viable
- be able to comply with the conditions of authorisation
You may also have to provide a financial guarantee. HMRC will need to make additional checks on businesses who want to establish a Type E warehouse. For example, your accounting system must be authorised by HMRC and payment of duties under Customs Freight Simplified Procedures (CFSP) must be secured by the deferment arrangements.
To apply for UK authorisation or to use the arrangements in a type E warehouse, you must complete HMRC's form SP2.
Send the completed form to your local customs authorising office.
Traders may also wish to apply for CFSP to import goods under the customs warehousing procedure. Read more about the criteria and conditions for CFSP authorisation.
Warehousekeepers' responsibilities include:
complying with conditions contained in their authorisation
checking the goods on arrival to account for any shortages or surpluses of goods, allocating stock numbers, and keeping them secure and under supervision
maintaining stock records for at least four years
allowing HMRC officers access to the warehouse, the goods, and their records
maintain the premises safely and run the warehouse in a way that meets Health and Safety requirements
Type E warehousekeepers may require additional checks.
If you choose to use a public customs warehouse you are a depositor and take responsibility for the declaration which places the goods under the customs warehouse procedure. You have particular responsibilities to:
correctly declare the goods, including where an agent is used by giving clear written instructions
ensure that your goods are sent directly to the warehouse shown on the declaration (within five days of your customs declaration)
provide the warehousekeeper with details of the declarations and an explanation of any discrepancies that are identified
ensure the goods are correctly declared on removal from the customs warehouse
You are also responsible for customs debt. If you are using a type A warehouse you must give the warehousekeeper all the details of your customs declaration for their records and make sure that the warehousekeeper holds a valid customs warehouse authorisation for the type of goods you wish to deposit.
Authorising an agent to make declarations on your behalf
There are two types of representation:
direct representation - the agent enters goods in your name and on your behalf but you are still responsible for any customs debt that may arise from errors
indirect representation - the agent enters goods in their own name on your behalf and they are jointly liable with you for any customs debt that may arise from errors
Warehousekeepers and depositors must always give clear written instructions for the goods to be entered, and make sure they check details of their goods on any paperwork. If you are a depositor and have authorised an agent to enter goods to a public Type A warehouse, you are responsible for checking that the agent sends the correct paperwork to the warehousekeeper.
If HMRC officers make a decision that you disagree with, you can appeal within 30 days. HMRC will tell you what you need to do if you disagree and will offer you a review.