United Kingdom — Import Procedures & Duties

Legal foundation. The United Kingdom's customs regime for imports operates under the Taxation (Cross-border Trade) Act 2018 (c. 22), which received Royal Assent on 13 September 2018. The Act established a standalone UK duty of customs "by reference to the importation of goods into the United Kingdom," replacing the directly applicable EU Union Customs Code framework that had governed UK customs before Brexit. Part 1 of the Act covers import duty, including the charge to duty, tariff establishment, valuation rules, origin and preference frameworks, reliefs, and administrative provisions for notification and payment.

Declaration obligation. When bringing goods into the UK, importers must make a full customs declaration unless authorised to use simplified declaration procedures. The Taxation (Cross-border Trade) Act 2018 provides that HMRC Commissioners may make regulations imposing obligations on importers for the notification and payment of import duty; Schedule 6 of the Act sets out the framework for how liability to pay import duty is to be notified, how duty is to be paid, when guarantees may be required, and how duty is to be repaid. A customs declaration notifies HMRC of the liability, provides the data necessary for tariff classification (commodity code), customs valuation, country of origin determination, and ensures compliance with import prohibitions, restrictions, and licensing requirements.

Customs Declaration Service (CDS). The Customs Declaration Service is the UK's electronic customs platform for submitting import and export declarations, administered by HMRC. CDS became the UK's single customs platform effective 31 March 2023, when HMRC closed the legacy CHIEF (Customs Handling of Import and Export Freight) system for all declarations. Importers must submit declarations through CDS either by using compatible commercial software that interfaces with the Customs Declarations API or by engaging a customs agent, freight forwarder, or customs intermediary to submit on their behalf.

EORI number requirement. To import goods into England, Scotland, or Wales (Great Britain), an importer needs an EORI (Economic Operators Registration and Identification) number that starts with GB. Businesses apply for a GB EORI number separately, and then subscribe their EORI to the Customs Declaration Service to gain the ability to submit declarations and access postponed import VAT statements and import VAT certificates. The subscription links the EORI to the importer's Government Gateway account and enables use of HMRC's declaration systems.

Core declaration data elements. A full import declaration submitted through CDS must include the commodity code (based on the UK Global Tariff, which uses the Harmonised System and UK-specific subdivisions), the customs value of the goods, the country of origin, the customs procedure code indicating the intended customs treatment (for example, release to free circulation under procedure code 40 00, or entry to a special procedure such as customs warehousing under procedure code 71 00), and supporting documents such as import licences, certificates of origin for preferential tariff treatment, or sanitary and phytosanitary certificates. HMRC publishes detailed declaration completion requirements in the UK Trade Tariff Volume 3 supplement for Great Britain, which specifies how to populate each data element, which procedure codes and additional procedure codes to use, and which document codes correspond to specific authorisations or certificates.

Timing and submission. For standard commercial imports, the declaration must be submitted and receive customs clearance before the goods are released from HMRC control. Pre-lodgement is permitted; importers may submit declarations before the goods arrive at the UK border. The timing for submission depends on the mode of transport and whether the goods require inspection, but the core requirement is that HMRC must clear the declaration before physical release of the goods occurs.

Administering authority. HM Revenue and Customs (HMRC) administers the UK customs regime, processes declarations through the Customs Declaration Service, assesses and collects import duty, and enforces customs law. HMRC is responsible for tariff classification rulings, origin determinations, granting authorisations for special procedures (including simplified declaration procedures, duty deferment, customs warehousing, and Authorised Economic Operator status), and conducting post-clearance compliance audits.

Source: Taxation (Cross-border Trade) Act 2018 Source: Customs Declaration Service to become UK's single customs platform – GOV.UK Source: Get UK customs clearance when importing goods into the UK – GOV.UK Source: Subscribe to the Customs Declaration Service – GOV.UK Source: Customs declaration completion requirements for Great Britain – GOV.UK

Statutory framework. The Taxation (Cross-border Trade) Act 2018 Schedule 6, paragraph 7 requires that HMRC regulations provide for deferment of import-duty liability when a guarantee is given in accordance with specified conditions. For goods declared for the free-circulation procedure, the liability is deferred until a specified time rather than being payable immediately at entry. This deferment mechanism allows importers to delay paying most customs duty, excise duty, and import VAT on a consolidated monthly basis rather than paying transaction-by-transaction at the border.

Application and eligibility. Any importer or representative of an importer may apply for a duty deferment account (DDA) to use in Great Britain (England, Scotland, and Wales). An active GB EORI number is a prerequisite. Processing typically takes 30 days from submission, although if a financial guarantee is required the turnaround may be longer depending on the guarantor's responsiveness. Applicants are not required to be established in the UK to obtain a duty deferment account, but UK establishment is a condition for qualifying for a guarantee waiver (discussed below).

Guarantee requirement and waiver. The standard rule is that the importer must provide a financial guarantee from a bank, building society, or insurance company established in the UK and regulated by the Prudential Regulation Authority. The guarantee covers the potential customs debt that may arise from the deferred duties. However, importers established in the UK may apply for a guarantee waiver when they apply for the DDA or by amending an existing account. HMRC grants a waiver if satisfied with the applicant's financial stability and compliance record. Authorised Economic Operators for Customs (AEOC) benefit from reduced guarantee requirements and do not need to upload a PFS1 financial-information form with the application.

Deferment limit and monthly cap. Each duty deferment account has a monthly deferment limit—the maximum cumulative amount of duty and import VAT that the account holder may defer during a calendar month. The limit is set by reference to either the guarantee amount provided or the waiver amount granted by HMRC. If the account holder exceeds the guarantee level or deferment limit in any calendar month, HMRC will refuse further deferments for the remainder of that month, and all subsequent import duties and import VAT must be paid immediately by an alternative method until either the guarantee or limit is increased or the next calendar month begins. Exceeding the limit causes clearance delays, so importers must monitor balances and plan for peak periods or large single shipments. An importer may "top up" available capacity mid-month by paying off already-deferred amounts before the scheduled debit date.

Accounting period and payment dates. Duties and import VAT deferred during a calendar month constitute a single accounting period and are paid as a lump sum. Under the Customs Declaration Service, the accounting period runs from the 15th of one month to the 14th of the following month. Payment is due by Direct Debit on the 29th of the latter month (or 28 February in non-leap years); if that date is not a working day, payment is taken on the working day immediately before. This structure provides an average of 30 days' credit between the date of import and the date funds leave the importer's account—between two and six weeks depending on when in the accounting period the declaration is made. For excise duty deferred by registered consignees, the same average 30-day credit applies even if postponed VAT accounting is used for the import VAT element.

Direct Debit mandate. Importers must provide a Direct Debit Instruction to activate the duty deferment account, even if they do not intend to use the account immediately. The mandate authorizes HMRC to collect the monthly consolidated liability on the scheduled debit date. Missed Direct Debits or persistent payment failures may result in HMRC suspending or revoking the deferment facility.

Integration with postponed VAT accounting. VAT-registered importers in the UK may use postponed VAT accounting (PVA) to account for import VAT on their VAT return rather than paying it upfront at customs or deferring it through a DDA. PVA is an automatic opt-in scheme introduced in January 2021; no separate application is required. When PVA is used, the importer still needs a duty deferment account if deferring customs duty or excise duty, but the import VAT is reported on boxes 1, 4, and 7 of the VAT return rather than appearing on the deferment statement. The two mechanisms are complementary: PVA handles import VAT, and the DDA handles customs duty and excise duty.

Statements and compliance. HMRC issues duty deferment statements monthly, accessible through the Customs Declaration Service by logging in with a Government Gateway ID. The statement lists all entries declared using the importer's deferment approval number during the accounting period and shows the total liability debited. Importers also receive a C79 VAT certificate for import VAT (if not using PVA) and postponed VAT accounting statements (if using PVA). Adjustments for over- or under-declared amounts on individual entries are normally applied to the deferment account before the debit is taken; where timing does not permit, the importer must pay additional duty immediately or will receive a refund on or soon after the debit date. HMRC does not normally refund over-declared VAT to VAT-registered traders via the deferment account; instead, importers recover the over-declaration on their next VAT return as input tax, subject to the normal deduction rules.

Amendment, suspension, and cancellation. An account holder may request amendment of the guarantee level, deferment limit, or Direct Debit details at any time using HMRC's online service. HMRC may suspend or revoke a duty deferment facility if the guarantee level is persistently exceeded or if the account holder fails to meet compliance obligations; written notice is given before such action. To cancel an account or terminate a guarantee, the account holder or the guarantor must follow the procedures set out in HMRC guidance, including submission of form C1201A for cancellation of a standard guarantee or notification to the Customs Comprehensive Guarantee team if a comprehensive guarantee is in place.

Source: Taxation (Cross-border Trade) Act 2018, Schedule 6, paragraph 7 Source: How to use your duty deferment account – GOV.UK Source: Apply for an account to defer duty payments when you import or release goods into Great Britain – GOV.UK

Statutory charge to import duty. Import duty is charged on goods imported into the United Kingdom under section 1 of the Taxation (Cross-border Trade) Act 2018. The rate of import duty applicable to goods in a standard case is the rate set out in the customs tariff established by HM Treasury under section 8 of the Act. Section 8(5) requires the Treasury, in considering the rate of import duty that ought to apply to any goods, to have regard to: (a) the interests of consumers in the United Kingdom, (b) the interests of producers in the United Kingdom of the goods concerned, (c) the desirability of maintaining and promoting the external trade of the United Kingdom, (d) the desirability of maintaining and promoting productivity in the United Kingdom, and (e) the extent to which the goods concerned are subject to competition. The Treasury must also have regard to any recommendation about the rate made by the Secretary of State.

UK Global Tariff establishment. The UK's Most Favoured Nation (MFN) import duty rates are set out in the UK Global Tariff (UKGT). The UKGT entered into force on 1 January 2021, replacing the EU Common External Tariff that had applied while the UK was a member of the European Union. The legal instrument establishing the tariff is The Customs Tariff (Establishment) (EU Exit) Regulations 2020 (S.I. 2020/1430), made under sections 8 and 32 of the Taxation (Cross-border Trade) Act 2018. These Regulations incorporate by reference a document titled "The Tariff of the United Kingdom," which sets out the UK's commodity code structure and the applicable duty rate for each commodity code. The reference document is periodically updated by amendment regulations; importers must verify the version in force at the time goods are declared to HMRC.

Commodity code classification. To determine the applicable import duty rate, goods must be classified under a commodity code. The UK uses a 10-digit commodity code system based on the Harmonised System (HS) maintained by the World Customs Organization. The first six digits of the commodity code align with the international HS nomenclature, while digits 7 through 10 reflect UK-specific subdivisions. Commodity codes are organised hierarchically: chapters (2 digits), headings (4 digits), subheadings (6 digits), and declarable codes (typically 10 digits). Classification is determined by applying the General Rules for the Interpretation of the Harmonised System (GRIs), which provide a structured methodology for resolving classification disputes. The UK Trade Tariff online tool (www.trade-tariff.service.gov.uk) is the authoritative public platform for identifying commodity codes and duty rates; the tool allows importers to search by product description or navigate the tariff hierarchy.

Ad valorem, specific, and compound duties. UK import duties are expressed in one of three formats. Most tariffs are ad valorem rates—a percentage of the customs value of the goods determined under the WTO Valuation Agreement framework (implemented in Part 12 of the Customs (Import Duty) (EU Exit) Regulations 2018). For example, a 4.7% duty rate means the importer pays 4.7% of the transaction value (subject to valuation adjustments for assists, royalties, and other Article 8 additions). Some tariffs are specific duties, expressed as a fixed amount per unit of quantity (for example, £25 per 1,000 kilograms or £0.15 per litre). A smaller number of tariffs are compound duties, combining an ad valorem component and a specific component (for example, 8% + £15 per 100 kg). When a compound duty applies, the importer calculates and pays both components.

Zero-duty codes and tariff suspensions. Many commodity codes in the UK Global Tariff carry a 0% MFN duty rate. In addition, The Customs Tariff (Suspension of Import Duty Rates) (EU Exit) Regulations 2020 (S.I. 2020/1435) provide for autonomous tariff suspensions—temporary zero or reduced rates on specified goods. Regulation 4(1) of S.I. 2020/1435 provides that where goods meet the conditions for a suspension, the rate of import duty is the duty suspension rate specified in the reference document for those goods, rather than the standard MFN rate. Suspensions are identified in the online tariff tool as separate measures alongside the MFN rate.

Preferential rates under trade agreements and GSP. The UK Global Tariff MFN rate is the baseline duty, but importers may claim a lower preferential rate if the goods originate in a country or territory with which the UK has a free trade agreement, or if they qualify under the UK Generalised Scheme of Preferences (GSP) for developing countries. Preferential duty rates are implemented under The Customs Tariff (Preferential Trade Arrangements) (EU Exit) Regulations 2020 (S.I. 2020/1457) for FTA goods, and the Trade Preference Scheme (EU Exit) Regulations 2020 (S.I. 2020/1438) for GSP goods. To claim a preferential rate, the importer must declare the preference on the customs declaration and hold valid proof of origin in accordance with the origin rules for the relevant agreement. If the importer does not claim preference or cannot demonstrate origin compliance, the MFN rate applies.

Tariff-rate quotas. For certain products, the UK operates tariff-rate quotas (TRQs): a limited quantity may be imported at a zero or reduced in-quota duty rate, and once that quota volume is exhausted, a higher out-of-quota rate applies. Some TRQs are country-specific, while others are allocated on a first-come, first-served basis regardless of origin. TRQ administration is governed by The Customs (Tariff Quotas) (EU Exit) Regulations 2020 (S.I. 2020/1432). Regulation 6 of S.I. 2020/1432 sets out the conditions for applying a preferential quota rate: the goods must be of the commodity code specified in the relevant quota table, the quota must not be closed, and the importer must hold an import licence if one is required. When a TRQ applies to a commodity code, the UK Trade Tariff tool displays the in-quota rate, the out-of-quota rate, and information on quota balance and licensing requirements.

Trade remedies—additional duties. Certain goods are subject to additional import duties beyond the MFN or preferential rate, imposed under the UK's trade remedies framework. The UK applies anti-dumping duties on goods sold into the UK market below normal value from specified countries, countervailing duties on subsidised imports, and safeguard measures when a surge of imports threatens UK industry. The Trade Remedies Authority (TRA) investigates and recommends remedies; the Secretary of State for Business and Trade makes the final decision on whether to apply, vary, or revoke measures. When trade-remedy duties are in force, they appear as separate additional-duty measures in the UK Trade Tariff tool and are added to the standard customs duty on the same goods. Importers must pay both the customs duty and any applicable remedy duty unless the goods are specifically excluded from the measure's scope.

Looking up applicable rates. HMRC publishes the UK Integrated Online Tariff at www.trade-tariff.service.gov.uk. For each commodity code, the tool displays the MFN duty rate under the UK Global Tariff, any preferential rates available under UK trade agreements or GSP, any tariff suspensions, tariff-rate quota information if applicable, trade-remedy duties, import licensing or restriction requirements, and the applicable import VAT rate. Importers should verify the rates and commodity codes applicable on the date goods are declared to HMRC, as codes and rates are subject to periodic amendment. For complex or high-value goods, importers may apply to HMRC for an Advance Tariff Ruling, which provides a binding decision on the correct commodity code.

Source: Taxation (Cross-border Trade) Act 2018, sections 1, 8 Source: The Customs Tariff (Establishment) (EU Exit) Regulations 2020 (S.I. 2020/1430) Source: Tariffs on goods imported into the UK – GOV.UK guidance Source: Reference Document for The Customs Tariff (Establishment) (EU Exit) Regulations 2020 – GOV.UK Source: UK Integrated Online Tariff tool – GOV.UK Source: The Customs Tariff (Suspension of Import Duty Rates) (EU Exit) Regulations 2020 (S.I. 2020/1435) Source: The Customs Tariff (Preferential Trade Arrangements) (EU Exit) Regulations 2020 (S.I. 2020/1457) Source: The Customs (Tariff Quotas) (EU Exit) Regulations 2020 (S.I. 2020/1432) Source: Trade Preference Scheme (EU Exit) Regulations 2020 (S.I. 2020/1438)

When errors occur after clearance. An importer who discovers after customs clearance that import duty or import VAT was overpaid—because of a classification error, valuation mistake, failure to claim a preferential tariff rate, incorrect origin declaration, or any other reason—may apply for repayment or remission under Part 7 of the Customs (Import Duty) (EU Exit) Regulations 2018, made under Schedule 6 to the Taxation (Cross-border Trade) Act 2018. HMRC may repay an amount of import duty or VAT already paid (repayment), or remit (waive) a liability that exists but has not yet been paid (remission). Both are processed through the same claim procedure.

Eligible claims and minimum threshold. An importer, customs agent, or freight forwarder acting on behalf of the importer may apply for repayment of overpaid duty and VAT. Each claim must exceed a minimum threshold: for goods imported after 31 December 2020, the claim must be more than £9 in value per full import declaration; for goods imported on or before 31 December 2020, the threshold is more than €10 (approximately £8.86). Claims below this de minimis are not processed. VAT-registered importers cannot use the C285 procedure to claim repayment of overpaid import VAT; instead, they must reduce output tax due in Box 1 of their VAT return to correct the overpayment. VAT-registered importers may use C285 to claim repayment of overpaid customs duty or excise duty.

Time limits for submission. The time limit for submitting a claim depends on the nature of the claim. For overpayments of import duty or import VAT, the claim must be submitted within three years of the date the liability was notified to HMRC or the date the duty was paid, whichever is later. For rejected imports—goods returned or destroyed because they were damaged, defective, or did not meet the contract conditions—the claim must be submitted within one year. For withdrawal of a customs declaration (requesting HMRC to invalidate a declaration, for example for mail-order goods that were not delivered), the claim must be submitted within 90 days. HMRC may extend these time limits if exceptional circumstances apply—for example, when a fire or flood destroyed the importer's records, or other circumstances outside the claimant's control prevented timely submission. Importers must contact HMRC to request an extension before the time limit expires.

Application procedure: online through CDS. For declarations made in the Customs Declaration Service (CDS), importers with an EORI number submit claims online through the CDS portal. The importer logs in with the Government Gateway user ID and password used to subscribe to CDS, which is linked to the importer's EORI number. The online C285 form is used for overpayment claims; a separate online C&E1179 form is used for rejected-import claims. Before starting the online application, the importer must gather supporting documents ready to upload, including: a commercial invoice showing the value of imported goods, a packing list, transport documents (air waybill or bill of lading), the Movement Reference Number (MRN) for each declaration, and evidence supporting the claim (for example, the correct tariff classification, proof of origin for a preferential claim, or photographs of damaged goods for a rejected-import claim). The file size limit for uploaded documents is typically 6 MB. Once submitted, the importer receives an email from HMRC confirming the claim and providing a reference number. To view the status of a claim, the importer signs in with the Government Gateway ID to access the claims dashboard.

Application procedure: paper form C285. Private individuals importing goods for personal use (except goods delivered by Parcelforce or Royal Mail, who must use form BOR286) and any claimant who cannot use the online service may complete the paper C285 form. The C285 form is filled in online but cannot be saved mid-progress; the applicant must complete it in one session, print it, and post it to HMRC with all relevant supporting documents at the postal address shown on the form. Individuals claiming for goods delivered by Parcelforce or Royal Mail must use form BOR286 instead and mail it to Border Force, Coventry International Hub, Siskin Parkway West, Coventry, CV3 4HX, enclosing the customs black-and-white charge label, customs declaration form, invoice or receipt, and evidence of value.

Current month amendment for deferment users. Importers who use a duty deferment account and discover an overpayment in the same calendar month as the original declaration may request a current month amendment (CMA) by submitting a C285 claim to the National Duty Repayment Centre before the last day of the month in which the error occurred. If approved, HMRC adjusts the deferment account balance before the accounting period closes and the Direct Debit is taken, avoiding the need for a later refund. CMA is available only for claims made within the same month as the original declaration; once the accounting period closes and the debit is taken, the importer must follow the standard repayment procedure and receive a separate refund.

HMRC decision and refund timing. HMRC aims to decide claims within 30 days of receipt. HMRC may contact the claimant to request additional information or evidence. If the claim is approved, HMRC sends details about when to expect the refund; payment is made by bank transfer to the account details provided in the claim. If the claim is rejected, HMRC issues a written decision explaining the reasons. The claimant may appeal the rejection to the National Reviews and Appeals Team within the applicable appeal period. The appeals process follows the same statutory review and tribunal framework as other customs disputes.

Separate procedure for rejected imports. Goods rejected because they were damaged, defective, or did not meet contract conditions are claimed using form C&E1179 (online or paper), not the standard C285. The time limit for rejected-import claims is one year from the date of acceptance of the customs declaration. The claimant must provide evidence of the defect or damage (for example, an insurance report showing the damage occurred before customs clearance, a surveyor's certificate, or correspondence with the supplier rejecting the goods). If the claim is approved before disposal of the goods, the goods are treated as removed from free circulation; the claimant must then re-export the goods or destroy them under customs supervision. HMRC may attend to witness packing for export or destruction; attendance is free during normal office hours but chargeable for delays, abortive visits, or visits outside 9:00–17:00 or on Sundays and public holidays.

Underpayments: voluntary disclosure (C2001). If an importer discovers that too little duty or VAT was paid—because of a classification or valuation error that understated the liability—the importer must voluntarily disclose the underpayment to HMRC using form C2001 (Voluntary Clearance Amendment). The C2001 online service is available for declarations made in CDS; a paper C2001-CDS form may be used if the importer cannot access the online service. HMRC issues a C18 post-clearance demand (PCD) for the additional duty and VAT due, plus interest from the date the liability should have been paid. Voluntary disclosure made before an HMRC compliance audit may result in reduced penalties or no penalty, depending on the importer's compliance history and the nature of the error. Importers who used postponed VAT accounting (method of payment type 'G') on the original declaration must account for underpaid import VAT on their VAT return, not via C2001.

Regulatory framework and scope. The substantive rules for repayment and remission in Great Britain (England, Scotland, and Wales) are set out in Part 7 of the Customs (Import Duty) (EU Exit) Regulations 2018 (S.I. 2018/1248), made under Schedule 6 to the Taxation (Cross-border Trade) Act 2018. Regulation 56 specifies the conditions under which HMRC may grant repayment or remission; the decision is discretionary and HMRC assesses each claim against the regulatory criteria. Regulations 53, 53A, and 53B identify specific cases where repayment is available, including withdrawal of a declaration (regulation 53), trade-remedy repayment investigations (regulation 53A), and repayment following a Trade Remedies Authority review that reduces the applicable anti-dumping or countervailing duty (regulation 53B). Northern Ireland follows a different framework for goods "at risk" under the Windsor Framework; importers of at-risk goods brought into Northern Ireland must follow the Union Customs Code procedures (EU Regulation 952/2013) and claim under the separate Northern Ireland regime. The C285 and C&E1179 procedures described in this section apply only to Great Britain.

Source: Taxation (Cross-border Trade) Act 2018, Schedule 6 Source: The Customs (Import Duty) (EU Exit) Regulations 2018 (S.I. 2018/1248), Part 7 Source: How to claim a repayment of import duty and VAT if you've overpaid (C285) – GOV.UK Source: Refunds and waivers on customs debt – GOV.UK Source: Apply for a voluntary clearance amendment (underpayment) (C2001) – GOV.UK

What customs warehousing is. Customs warehousing is a special customs procedure that allows importers to store non-UK goods (goods not in free circulation in the United Kingdom) in an HMRC-approved warehouse facility while suspending payment of import duty, excise duty, and import VAT. The procedure is governed by Schedule 2 to the Taxation (Cross-border Trade) Act 2018, which provides for the charge to import duty and the framework for special procedures, and by The Customs (Special Procedures and Outward Processing) (EU Exit) Regulations 2018 (S.I. 2018/1249), which sets out the detailed requirements for operating and using a customs warehouse in Great Britain (England, Scotland, and Wales).

Duty and VAT suspension — the cash-flow benefit. Goods declared to the customs warehousing procedure using procedure code 71 in data element 1/10 of the customs declaration enter a duty- and VAT-suspended state. Import duty and import VAT remain suspended while the goods are stored in the warehouse and are not payable unless and until the goods are released to free circulation (removed from the warehouse for domestic use or sale in the UK). If the goods are re-exported directly from the customs warehouse, or transferred to another special procedure such as inward processing, no duty or import VAT becomes payable at all. This suspension provides importers with significant cash-flow relief, particularly for large volumes of stock held for extended periods before release to the market or for goods awaiting onward export or re-export.

When to use customs warehousing. Importers commonly use customs warehousing to store goods where payment of duty and VAT is not yet due, including: goods imported in bulk for gradual release to the UK market over time; goods awaiting onward re-export to third countries; goods awaiting import licences or other documentation required for release to free circulation (such as sanitary or phytosanitary certificates); and goods imported for processing or assembly before export. Customs warehousing is distinct from duty deferment accounts: a duty deferment account defers payment of duty and VAT already due at the time of import clearance, whereas customs warehousing suspends the charge to duty and VAT until the goods are actually released to free circulation.

Types of customs warehouse — public and private. There are two types of customs warehouse. A public customs warehouse is operated by a warehousekeeper authorised by HMRC to store goods belonging to other persons (depositors). Any person established in the UK may deposit goods in a public customs warehouse without needing their own HMRC authorisation, although they become liable for any duty and import VAT that subsequently becomes due on the goods. A private customs warehouse is operated by a warehousekeeper who stores only their own goods; the warehousekeeper and the depositor are the same person. In both cases, the warehousekeeper must hold an HMRC authorisation to operate the customs warehouse, and HMRC may impose conditions on the types of goods that may be stored, the facilities required (for example, cold storage for frozen goods or secure facilities for chemicals), and the record-keeping and stock-control systems that must be maintained.

Authorisation to operate a customs warehouse (warehousekeeper). To operate a customs warehouse, a business must apply to HMRC for a customs warehousing authorisation. The application must demonstrate that the applicant has appropriate premises with adequate security, suitable storage facilities for the types of goods to be warehoused, and robust inventory and duty-management systems to track goods entering and leaving the warehouse and to calculate duty and VAT liability when goods are discharged from the procedure. For public warehouses, the applicant must also demonstrate economic need by providing letters of intent from prospective customers showing the anticipated annual duty and VAT suspension figures. The applicant must provide a financial guarantee covering the potential customs debt unless the applicant is established in the UK and qualifies for a guarantee waiver, or holds Authorised Economic Operator for Customs (AEOC) status. HMRC may conduct a site visit before granting the authorisation. The authorisation specifies the approved warehouse premises, the supervising customs office code, and any conditions or restrictions on the types of goods or activities permitted.

Declaring goods into customs warehousing. Goods are entered to the customs warehousing procedure by making a full or simplified customs declaration to HMRC using procedure code 71 00 (or a 71-series code reflecting any previous procedure, for example 71 21 if re-importing goods). The declaration must identify the specific customs warehouse by its authorisation code in data element 2/7 (Identification of Warehouse) and the supervising office code in data element 5/27. All items on a single declaration must be destined for the same warehouse. The declaration may be submitted before the goods arrive at the UK border (pre-lodgement) or after arrival, but the goods must normally arrive at the approved warehouse premises within five working days of the declaration being cleared by HMRC. The movement of the goods from the port or place of importation to the warehouse is covered by the import declaration entering the goods to customs warehousing; this is known as "moving under the arrangements." For goods arriving under a customs transit procedure, the warehouse premises must also hold a temporary storage approval to discharge the transit.

Eligible goods and prohibited goods. Most non-UK goods liable to import duty or import VAT may be entered to the customs warehousing procedure, including goods subject to import restrictions provided that the necessary licences or certificates are presented at the frontier when the goods are imported. For example, carcasses and animal products require the relevant import licence or health certificate at importation; goods subject to CITES (Convention on International Trade in Endangered Species) require the appropriate permits. Prohibited goods — for example, counterfeit or pirated goods — are ineligible for entry to customs warehousing. Domestic goods (goods already in free circulation in the UK) may be physically stored in a customs warehouse premises but are not entered to the customs warehousing procedure and remain subject to domestic rules.

Storage duration and permitted handling. There is normally no time limit for how long goods may remain in customs warehousing, except for perishable goods with a limited shelf life. HMRC may require goods to be removed if they pose a threat to human health, animal health, plant health, or the environment. Importers may carry out "usual forms of handling" on goods in the warehouse without discharging the customs warehousing procedure, provided HMRC has authorised those activities. Usual forms of handling includes operations such as marking, labeling, repacking, sorting, lotting, or minor assembly necessary to preserve the goods, improve their presentation, or prepare them for distribution or onward sale. More substantial processing operations require a separate inward processing authorisation and entry to the inward processing procedure.

Discharging goods from customs warehousing — release to free circulation and other outcomes. Goods are discharged from the customs warehousing procedure when they are removed from the warehouse and declared to another customs procedure or directly re-exported. The most common discharge route is release to free circulation for home use in the UK, declared using procedure code 40 71 (requested procedure 40, previous procedure 71). At that point, the importer must pay the import duty and import VAT due on the goods, calculated on the basis of the tariff classification, customs value, and origin applicable at the date of the discharge declaration. The duty and VAT may be paid immediately or deferred using a duty deferment account. Alternatively, goods may be discharged by re-export from the warehouse (procedure code 31 71), in which case no duty or import VAT is payable. Goods may also be transferred from customs warehousing to another special procedure such as inward processing (procedure code 51 71) or temporary admission (procedure code 53 71) by making a single declaration that discharges the warehousing procedure and enters the goods to the new procedure. In each case, a full or simplified declaration is required unless HMRC has authorised the use of entry in declarant's records (EIDR) for removals to free circulation.

Depositor liability and UK establishment requirement. The depositor is the person who declares goods into the customs warehouse (in a public warehouse) or the warehousekeeper themselves (in a private warehouse). The depositor does not need to own the goods but must be established in the United Kingdom and is liable for any import duty and import VAT that becomes due on the goods. An owner of goods who is not established in the UK and wishes to warehouse goods in Great Britain must either appoint a UK-established private warehousekeeper to import and declare the goods into the warehousekeeper's own private customs warehouse (in which case the warehousekeeper is fully liable), or appoint a UK-established indirect customs representative to deposit the goods into a public customs warehouse on the owner's behalf. An indirect representative is jointly and severally liable with the owner of the goods for any duty and import VAT that becomes due, and must indicate their role as an indirect representative on the customs declaration.

Record-keeping and stock control. The warehousekeeper must maintain detailed inventory records showing all goods entering and leaving the warehouse, the commodity code and customs value of each consignment, the date goods were received and the date removed, the identity of the depositor, and the customs procedure to which the goods were discharged. HMRC may audit these records at any time. Importers using simplified declaration procedures (EIDR or simplified declarations) must also maintain entry-in-declarant's-records showing the date and time of entry to the customs warehouse arrangements, the Declaration Unique Consignment Reference (DUCR), and the commodity details. The warehousekeeper must not permit goods to be physically removed from the warehouse unless notified that the discharge declaration has been accepted by HMRC or the importer holds a valid EIDR authorisation permitting removal on the basis of the entry in records; unlawful removal of goods from customs supervision creates an immediate customs debt for which the warehousekeeper is liable.

Common storage and equivalence. HMRC may authorise "common storage" arrangements where it is impossible to identify at all times the customs duty status of individual units of goods — for example, bulk goods such as grain or oil stored in a silo or tank where non-UK goods and domestic goods of the same commodity code, commercial quality, and technical characteristics are commingled. Common storage is permitted only where the goods are functionally interchangeable and the warehousekeeper's records enable HMRC to verify the duty status and quantity of goods on a risk-assessment basis. Goods subject to excise duty are excluded from common storage arrangements. The use of common storage may affect entitlement to preferential tariff treatment unless the goods are of the same origin and from the same exporter.

Regulatory framework for Great Britain. The substantive rules for customs warehousing in Great Britain are set out in Part 4, Chapter 1 of The Customs (Special Procedures and Outward Processing) (EU Exit) Regulations 2018 (S.I. 2018/1249), made under Schedule 2 to the Taxation (Cross-border Trade) Act 2018. Regulation 17 of S.I. 2018/1249 governs removal of goods from a customs warehouse and specifies that declared goods may not be removed unless HMRC has approved the removal (for permanent removal) or the removal is for temporary purposes such as usual forms of handling. Any person removing declared goods from a customs warehouse in contravention of regulation 17 is liable to import duty on those goods. Northern Ireland follows a separate framework under the Windsor Framework; goods "at risk" of remaining in the EU customs territory are subject to the Union Customs Code (EU Regulation 952/2013) and its implementing and delegated regulations. The customs warehousing procedures and guidance described in this section apply to Great Britain only.

Source: Taxation (Cross-border Trade) Act 2018, Schedule 2 Source: The Customs (Special Procedures and Outward Processing) (EU Exit) Regulations 2018 (S.I. 2018/1249), regulation 17 Source: How to use a customs warehouse – GOV.UK Source: Apply to operate a customs warehouse – GOV.UK Source: Special procedure: customs warehousing – GOV.UK