Union Customs Code ― customs warehousing

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Union Customs Code ― customs warehousing
  • Scope
  • Type of customs warehouse
  • Goods that can be stored in a customs warehouse
  • Authorisation to operate a customs warehouse
  • Handling goods in a customs warehouse
  • Retail sales
  • Common storage and co-storage
  • Removing goods from a customs warehouse (discharging the customs warehouse procedure)

This guidance note provides an overview of HMRC’s interpretation of the new customs warehousing rules that were introduced under the Union Customs Code with effect from 1 May 2016.

This note should be read in conjunction with the Union Customs Code ― imports, exports and specific reliefs and procedures, Union Customs Code ― Customs Special Procedures ― authorisation and Union Customs Code ― Customs Special Procedures ― discharge and customs debt guidance notes.

For more information on the procedure that operated before 1 May 2016, please see the Customs warehousing ― introduction guidance note.

More information on the UCC can also be found on the European Commission website via the UCC ― Guidance documents  .


Customs warehousing can benefit businesses that import goods into the EU as they can store goods in the facility without the requirement to pay any import duties (also known as customs duty) / import VAT until the goods leave the facility. If the goods leaving the warehouse enter into free circulation within the EU, import VAT and customs duties will become payable. However if the goods are exported or placed into another customs special procedure, then import duties / VAT may not be payable. Businesses can either choose to store their goods in an existing customs warehouse or request permission from HMRC to create a new warehouse on their own premises.

HMRC Customs Notice 3001 ; Regulation (EU) No 952/2013 (UCC) ; Commission Implementing Regulation (EC) 2015/2447 ; Commission Delegated Regulation (EU) 2015/2446 (DA) 

Businesses wishing to become a customs warehouse-keeper will need to be authorised by HMRC.

With the exception of CAP goods, there are normally no time limits imposed on goods stored in a customs warehouse.

Type of customs warehouse

There are currently two types of customs warehouse in the UK:

More on Union Customs Code: