Frequently asked questions – Temporary storage facilities
Here are some answers to frequently asked questions about temporary storage facilities.
What is the difference between a customs warehouse and a temporary storage facility?
Customs warehouses and temporary storage facilities are both used to store uncleared goods.
In the context of temporary storage, is it permitted to repack from the arriving unit to the released unit, as long as this is shown in the records? Would it then be possible for a container terminal to have a container at its temporary storage facility, but release individual boxes for a bill of release from, for example, a transit movement, as long as the records of the warehouse shows the original number of boxes in the container? Or should this be interpreted differently?
No, it is not permitted to reload goods in temporary storage, other than for purposes such as replacing damaged packaging materials. This should show in the records.
Declaring the number of packages in a temporary storage facility.
What degree of responsibility does a authorisation holder for a temporary storage facility have to authenticate documents submitted by third parties?
The authorisation holder’s records should be correct and up-to-date. If arriving goods do not correspond with the information in the documentation, the holder of the authorisation should inform Swedish Customs of the discrepancy.
Any movement of goods should be noted in the authorisation. The procedure and records should be noted, but also the ‘frequency’ and ‘number of affected operators’. How often should this subsequently be updated? The future is not always known in advance.
Authorisation for movement must be included in the authorisation for the temporary storage facility and cannot be applied for on a one-off basis by the holder of the authorisation. In order to be granted an authorisation for movement, the application for authorisation must demonstrate procedures that ensure customs supervision during the time the goods are moved between different storage facilities. At present, Swedish Customs only approves movement between facilities within the same authorisation.
To be allowed to store Union goods at a temporary storage facility, these must be stored separately, but there must also be ‘economically justified’. Is this requirement still applicable?
Yes, it can be found in Article 148(6) of the Union Customs Code.
It states the following:
The customs authorities may, where an economic need exists and customs supervision will not be adversely affected, authorise the storage of Union goods in a temporary storage facility. Those goods shall not be regarded as goods in temporary storage.
Is it permitted to add additional information in the records if needed by the economic operator?
Yes, that is perfectly fine.
If a company has several temporary storage facilities, are movements between them allowed?
Yes, provided that this is authorised in the temporary storage facility authorisation and the facilities are covered by the same authorisation.
Can you elaborate on the requirement for EU goods to be physically stored separately despite having an accounting segregation? Article 148(6) of the Customs Code does not explicitly state that this should be done. So it is not possible to have a specific area of a terminal (both EU/customs goods) as temporary storage, but there must be walls around this storage?
The goods can be stored in the same warehouse, but you must be able to show from the accounts which pallets are Union goods and which are non-Union goods.
Union goods are not in temporary storage during the storage and therefore you do not need to report discrepancies for these goods. It must therefore be possible to determine the customs status of each unit or consignment, although this does not have to be physically visible on the goods. In other words, it is not possible to unload a cargo of non-Union status oil into a cistern that already contains Union status oil. For this type of goods flows, you should instead refer to customs warehouses and handling of equivalent goods.
Should the records also include the Union goods?
Yes, if the goods are kept at the same storage facility.
Does a record-keeping system for transport or distribution count as approved records for Union goods at a terminal where it is possible to verify that the goods are located in the terminal?
It is difficult to answer in general terms without having seen, for example, screenshots or extracts from the system.
It is important that all changes are traceable, so that the data cannot simply be overwritten without being recorded. This assessment is made in the context of authorisation management.
Do all the goods in the input document really have to be unloaded at the establishment? Is it not sufficient to list them if, for example, they are to be cleared with a simplified declaration and then delivered to the consignee with the same transport unit with which they arrived? In other words, they should only be cleared and then dispatched.
The accounts must be updated and correct and it is the responsibility of the authorisation holder to ensure this.
If you have several facilities (goods location codes), you will probably have one entry per goods location code. Is it then sufficient to enter the storage location's goods location code at the other (receiving) facility in the records of the facility from which the goods were transported? Or should the place of storage also be recorded as ‘movement’ until the goods arrive at the other establishment?
The place of storage of the goods must be shown in the records and at all times the records must reflect the actual balances of the establishment.
This means that it must be shown that the goods have left the facility by way of transport, but they cannot be recorded as a balance in the accounts of the other facility until they have actually arrived there. Therefore, it must be shown in some way that they are in transit.
Note that in order to move goods, this must be stated in the authorisation holder's permit.
The 90-day time limit for temporary storage remains in place when moving between different facilities, so the first day of the time limit will be the day the goods were originally placed in temporary storage at the first facility.
Can you strip a container at a temporary storage facility?
It depends on what you have specified in the constituent document:
- If you have specified x number of pallets, it is okay.
- If you have specified containers, the answer is no.
The same type of package declared in a declaration for temporary storage should be the one declared for release for a customs procedure or re-export.
If you have both a temporary storage facility and a customs warehouse at the same address, can you move certain consignments from the temporary storage facility to the customs warehouse (for example, if you have warehouse customers whose goods are repacked at the customs warehouse)? Can you transfer goods from the temporary storage facility to the customs warehouse whenever you want?
If the goods are placed under the customs warehousing procedure, the storage at the temporary storage facility is discharged. The actual movement then takes place under the customs warehousing procedure because the goods are placed there. The goods then do not need to be transited. This can happen at any time within the 90 days that the goods may be stored at the facility.
I receive non-Union goods intended for victualling at my establishment for temporary storage, how should these be recorded in the warehouse records? In the past, we have used captain's receipts.
Non-Union goods intended for victualling or spare parts for ships should be transited in the first instance to a temporary storage facility in the port where the ship is expected to arrive. There, the transit must be completed by an authorised consignee. Once this is done, the goods are in temporary storage awaiting loading onto the vessel. In the stock records, the transit shall be used as the entry document and the unit (including quantity) used in the transit shall be recorded in the stock records.
When the goods are removed from the temporary storage facility, the records must refer to the document, e.g. the supplier's receipt, which the captain of the vessel should sign as proof that they have received the goods, together with the vessel's visitor ID. Mark the withdrawal in the records with Victuals or Ship Parts, in connection with the relevant visitor ID.