Handling goods in a customs warehouse
In a customs warehouse, you are not allowed to handle goods in any way you like, but some common forms of handling are still permitted. Here you can read about the rules and see examples of what you can and cannot do with goods in a customs warehouse.
In some cases, you can handle goods stored in a customs warehouse. In these cases, you must carry out certain specific common types of handling.
Check the list of permitted handling operations
Permitted forms of handling are listed in Annex 71-03 of the UCC Delegated Regulation. The annex contains a 22-point list describing how goods in a customs warehouse may be handled.
The Annex to the UCC Delegated Regulation
Undue advantages in terms of import duties
Handling must not result in the holder of the authorisation gaining any unfair advantage in terms of import duties.
The goods must not obtain a different CN code
As a general rule, goods must not fall under a different 8-digit CN code after handling than they did before. There are some exceptions where the CN code may be changed, in which case it is clearly indicated in the list of authorised operations in Annex 71-03.
If the goods change CN code or origin during handling, they cannot be subject to provisional or definitive anti-dumping, countervailing, safeguard or additional duties at the start of the handling as a result of a suspension of concessions, if they have been declared for release for free circulation. This may lead to undue advantages in terms of import duties.
The nature or performance of the goods must not change
In most cases, an article must also not have changed its nature or had its performance improved after handling. Again, there are exceptions where Annex 71-03 states that this is allowed.
You do not need a separate authorisation
You do not need to apply for a separate authorisation to handle goods in a customs warehouse. However, you should apply for it as part of your customs warehouse authorisation. In your application, describe the handling operations you plan to carry out. You should also describe how you intend to keep records of any handling carried out in your customs warehouse.
Record-keeping requirements for customs warehouses
Examples of handling
Here you will find examples of needs that may arise and find answers to whether the handling is allowed or not.
If you are unsure whether the handling you are going to carry out is authorised, contact Swedish Customs and we will look into the matter and make an assessment.
I have a customs warehouse where I will receive my goods (clothes) in boxes. I would like to unpack the goods so they hang on hangers while I iron the clothes before we send them out to the shops. Can I do this in my customs warehouse?
Yes, you can handle goods in your customs warehouse in this manner.
You can unpack the goods according to point 18 of the Annex. And point 22 allows you to prepare the goods for distribution, which you do when ironing the clothes.
I store pleasure boats in my customs warehouse for the winter. While I have them there, I thought I would scrape their hulls clean so they're ready to sail in the spring. Can I do this in my customs warehouse? It is just a simple cleaning, right?
No, this kind of handling is not permitted.
This is because the boats’ performance changes when the hull is scraped. They become faster.
According to point 1 of the Annex, simple cleaning operations may be carried out in the customs warehouse, but hull scraping in particular is beyond what is allowed because it improves both handling and performance.
The background to Swedish Customs' interpretation is, among other things, the following information from the Swedish Transport Agency and the Swedish Agency for Marine and Water Management:
The Swedish Transport Agency
Clean hulls from the Swedish Transport Agency (in Swedish)
The Swedish Agency for Marine and Water Management
In the preface to the report Washing the bottom of recreational boats (2012:9) (available only in Swedish) it is stated that ‘Fouling on the bottom of boats increases fuel consumption and reduces manoeuvrability, which has a negative impact on the environment as well as safety.’
The Swedish Agency for Marine and Water Management’s report 2012:9 (in Swedish)
The introduction to ‘The Swedish Agency for Marine and Water Management's guidelines for cleaning the hulls of recreational boats’ (available only in Swedish) (report 2012:10, revised May 2015) states the following:
‘Minimising fouling on the boat bottom is important to preserve the boat's handling characteristics and to keep fuel consumption down.’
The Swedish Agency for Marine and Water Management's report of 2012:10 (in Swedish)
I am planning to store apples. I will dry some of them before selling them. Am I really allowed to do that, given that this would break the main rule that the CN code cannot be changed?
Yes, this handling is allowed in this case because point 10, indent 2 states that ‘dehydration of fruits even if this results in a different eight-digit CN code’ is permitted.
I store oil in tanks in my customs warehouse and would like to add a preservative to the oil to improve its shelf life. I assume that this will not be an issue, because point 12 states that additions can be made even if the CN code is changed?
No, you cannot handle the goods in a customs warehouse in this way because it improves the nature of the goods.
The shelf life of the oil will be improved. According to point 12, changing the CN code is allowed, but changing the nature of the goods is not.
We are planning to import alcohol and then turn it into technical spirits. Is it possible to do this in a customs warehouse so that we do not have to pay duties on the alcohol before we have turned it into technical spirits?
Yes, denaturation is allowed in a customs warehouse according to point 21 of Annex 71-03.
Union goods may be used as denaturing liquid for alcohol that is not Union goods. In this case, the Union goods do not need to be placed under the customs warehousing procedure.
However, denaturing with equivalent goods is not allowed unless both the alcohol and the denaturing liquid are non-Union goods. If one of the goods is an equivalent good, denaturation must be carried out by placing it under inward processing.
It is also important to know which additives you may use during denaturation. Per hectolitre of absolute ethanol you may use
- 1.0 litre of isopropyl alcohol
- 2.0 litres of methyl ethyl ketone
- 1.0 gram of denatonium benzoate
You should also check with the Public Health Agency if you need more authorisations than just a customs warehouse authorisation.
We store cars in our customs warehouse and normally we receive them complete. But now we received a consignment where the indicator glass needs to be replaced to meet Swedish safety standards. Can I do this in my customs warehouse or do I have to declare the goods for inward processing?
Yes, this way you can handle the goods according to point 12, as the replacement of the indicator glass brings the car to the correct technical standard.
The replacement also does not change the nature of the car as already had an indicator, although the glass was incorrect.
I store trousers in my customs warehouse, but when they are placed under the customs warehousing procedure, there is a pocket missing on the trousers that I would like to sew on. Can I sew on pockets on the trousers?
No, you are not allowed to sew pockets on the trousers, as this would change their nature.
I store clothes in my customs warehouse but they are missing Swedish washing instructions. I would like to affix a label with this on the trousers before we sell them. Is this a preparation for distribution according to paragraph 22 of Annex 71-03?
Yes, you can handle the goods in this manner.
However, it is a handling according to point 18 of the annex, as this is an application of labels.
I have a customs warehouse where I receive fruit. Sometimes I need to remove damaged fruit. Can I do this in my customs warehouse?
Yes, you can handle goods in your customs warehouse in this manner.
Improving the appearance or marketable quality of the goods, including preparing them for sale, is allowed under point 22 of the Annex. However, this requires that the measures do not change the nature of the original goods or improve their performance.
I have a customs warehouse where I receive fruit. Sometimes I need to remove damaged fruit. There is no space for this activity at the warehouse, so I want to do it elsewhere. Is that allowed?
Yes, this handling is allowed, but as you cannot do it in your own customs warehouse, you must first apply for temporary removal. Swedish Customs will then examine whether you need to temporarily remove the goods from the warehouse and whether you, as the holder of the authorisation, can ensure customs supervision.
We have a customs warehouse where, for transport reasons, the goods are dismantled into smaller components when they arrive at the warehouse. Are we allowed to assemble these parts into the final product in our warehouse?
Yes, you may do so according to point 2 of the Annex, as the CN code of the intended finished product does not change when the components are assembled.
Do you want to handle the goods in a way that does not meet the requirements?
If you want to handle the goods in a way that does not fulfil the requirements, you can apply for inward processing instead. If you have an economic need for this, Swedish Customs can authorise processing to be carried out in your customs warehouse, provided that the goods are placed under the inward processing customs procedure.