Customs Special Procedures can help companies save or delay customs duty costs on imported goods, resulting in a positive impact on their economy. Our on-demand webinars will familiarise you with the Customs Warehousing process, a Customs Special Procedures available in both the EU and UK, the high-level requirements for using them, and how to take advantage of them without putting an undue burden on your customs organisation.
Frequently asked questions
All your questions answered by our speakers and C4T experts!
You don’t. In CAS, you can set up storage locations in your organisational structure, that are either physical and/or virtual locations to manage your stock. Based on these storage locations, you can identify the stock levels and define write off rules.
In the UK, HMRC has between 60 and 90 working days to approve the authorisation. In the EU, the customs authorities have 30 days to evaluate if the application that was submitted corresponds to the requirements and an additional 90 days to review and approve the application and do an on-site audit.
Indefinitely. There is no time limitation as to how long goods can be stored in a customs warehouse.
At import, the consignment will be put in your customs warehouse, and the stock will be maintained there until you discharge it from the customs warehouse procedure. You can discharge the full quantity of goods all at once, or in different smaller consignments over time. As stock administration is managed in CAS, you get an overview of the remaining stock levels at all times.
With CAS, you can transfer stock from one customs warehouse to the other by discharging the goods from the procedure in one EU country and entering them in the customs warehouse procedure in the other EU country.
You can outsource the management of your customs warehouse administration to brokers and other parties or choose to do it yourself and keep the control. Keep in mind to weigh off the advantages and disadvantages of both options.
It’s possible to have a sale in the warehouse and when there is a sale while the goods are still in the warehouse then another party with another EORI number can be putting the goods into free circulation. It would be the new owner of the goods who does that.
You are pretty limited to what you can do in your customs warehouse. If you are processing goods, you would need to have an IP authorisation alongside your customs warehouse authorisation. You need to do a removal from CWH, in IP and once that processing is completed, you could then get the goods back into your customs warehouse procedure under the appropriate CPC code and remove them from the IP procedure. CAS makes the removal from CWH and entry in IP, and vice versa very simple from a declaration perspective. Note that you will need both an IP authorisation and a CWH authorisation.
You will need a re-export declaration, which will discharge the customs warehouse procedure as well. There is no necessity to produce a T1 on top, since the goods can move from the customs warehouse location to the customs office of exit under the coverage of the 3171 declaration.
There are different types of public warehouses:
- In type 1 there is a shared responsibility between the warehousekeeper and the holder of the authorisation
- In type 2, the responsibility is with the authorisation holder and that’s the person who needs to take the stock differences in his records
Retail sales cannot happen within a customs warehousing authorisation in the UK. In the EU, the benefit would need to be investigated case by case and depends on the individual situation of the party applying for the customs warehouse authorisation.
In theory, you can apply simultaneously/in parallel for both. These are two different types of warehouses, so two different authorisations and customs regimes. We would advise to get the excise warehouse authorisation first and then apply for a customs warehouse authorisation. If goods come under customs control, the customs warehousing procedure takes priority over the excise warehouse procedure.
CAS has the possibility to do both. It can manage both bonded and free stock but can also only manage bonded stock if required. The logic behind is the following: if in your declaration there are goods that CAS cannot find in his bonded stock, CAS assumes it’s free stock and will treat it as such. Instead of using procedure 3171, it will be a 1000 declaration.
Temporary storage is not a customs Special Procedure under the UCC. All goods are in temporary storage before they are presented to customs. You can store goods for a maximum of 90 days in a temporary storage location, for which also a licence is needed.