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Customs Warehousing: Common Storage & Equivalent Goods

Common storage is the storage of the same type of goods, with a different customs status, known as equivalent goods.


About common storage

Common storage is the storage of the same type of goods, with a different customs status, known as equivalent goods.


Businesses need to be authorised by customs authorities if they want to make use of the benefits of common storage.


Authorities usually consider common storage is more appropriate to private warehouses where the warehouse keeper is also the depositor because of the need to keep records and to prove equivalence.


What customs means by equivalent goods

Equivalent goods are goods that share

  • the same 8-digit commodity code,

  • the same commercial quality and

  • the same technical characteristics

but have a different customs status, and where it's not possible for businesses to identify their status at all times.


It can also apply where businesses have a high incidence of goods returned to warehouse duty paid, or where they hold existing duty paid stock prior to a warehouse authorisation being granted.


Note: Usually, any goods that will be subject to excise duty, on their release to free circulation, cannot be stored under common storage.


How to apply for common storage

Usually, businesses apply for common storage at the same time as applying for a customs warehouse authorisation.


When they apply to use common storage, they must provide sufficient information to enable us to make a comparison between the goods.


They must state factors common to the equivalent goods and the customs warehousing goods and suggest how this can be checked (for example technical specifications or samples).


The record-keeping requirements for common storage


Customs authorities need to be satisfied that the trader's records and/or systems can identify, monitor and correctly account for goods that are stored under common storage.


This means the system needs to be able to identify the number of goods allocated to free circulation and those that have a different status.


On removal, the number of free circulation goods cannot exceed the amount shown in your stock records as having that status.


A negative stock balance of customs warehouse stock is not permitted.


Example


Stock records show 1,000 cartons of third-country goods and 1,000 cartons in free circulation (aka for sale in-country). The goods meet the equivalence criteria. This means there are 2,000 cartons with goods in common storage.


The warehouse keeper wants to remove 1,500 cartons. As 1,000 cartons are already in free circulation, a declaration to free circulation is required for the other 500 cartons, as duty has not been paid on them.


The stock balance after removal would show 500 cartons of third-country goods under customs warehousing and a nil balance for the free circulation stock.


Duty is required to be paid on the remaining 500 cartons as and when they are removed to free circulation.


Licensable goods in common storage


Your records and/or systems need to provide safeguards preventing the removal to free circulation of goods liable to restrictions. For example, goods being removed to free circulation without an appropriate valid licence is available. We also need to be sure that authorising common storage doesnʼt adversely affect the customs warehousing procedure or any subsequent customs procedure. For example, itʼs not being used to circumvent anti-dumping duty requirements.


If there is a difference between the stock records and the physical stock held


Variations can occur when a comparison is made between the warehouse stock records and the physical stock held of goods with a different customs status. This doesnʼt refer to discrepancies when the goods were first received. You should investigate any variations that arise and make the necessary adjustments to your records including providing an explanation for variations.


However, if there is no identifiable explanation, you can apply the following:


  • shortages (negative adjustments) should first be deducted from free circulation status stock where there is a positive balance. If this stock adjustment exhausts the free circulation stock, the remaining balance of the adjustment should be made against any non-free circulation stock. Youʼll need to make a declaration to free circulation

  • excesses (positive adjustments) should first be added to free circulation stock unless the excess existed when the goods were first received at the warehouse

  • excesses and shortages can be “off-set” that is, adjusted against each other if the goods concerned are equivalent


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