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Comprehensive guarantee authorisation

The comprehensive guarantee authorisation (CGU) is the one most often used by companies. A company should apply for a comprehensive guarantee authorisation, if it regularly needs to lodge a guarantee for a customs debt. The comprehensive guarantee is an alternative to the individual guarantee, which has to be lodged for each customs declaration. 

You will need a comprehensive guarantee authorisation from the Customs Authorisation Centre to be able to apply for an authorisation for the following customs procedures:

  • transit
  • temporary storage
  • customs warehousing
  • inward processing
  • outward processing
  • end-use
  • temporary admission
  • warehousing at a location approved by Customs

Apply for a comprehensive guarantee authorisation in the Authorisations and Decisions Service.

Guarantee categories

When a company applies for a comprehensive guarantee authorisation, it simultaneously applies for a guarantee category. The amount of comprehensive guarantee is based on the company’s guarantee category and the reference amount.

  • The guarantee category of the customs debt concerns all operators who have a comprehensive guarantee authorisation and a payment deferment authorisation.
  • The guarantee category for the liability for customs duty concerns operators who have special procedures: transit, warehousing, inward and outward processing and specific end-use or temporary admission.

Companies are placed into guarantee categories e.g. based on their solidity and payment behaviour. In addition to the economic criteria, the guarantee categories have other requirements that are connected to e.g. sufficient resources, accounts or in-house control.

The customs debt guarantee category related to a comprehensive guarantee authorisation applies to all operators who have a comprehensive guarantee authorisation and a payment deferment authorisation. For authorised economic operators (AEO), the guarantee category of the customs debt is AB upon application and AA for other operators.

The required guarantee in category AA is 

  • 100% for the customs debt and 0% for the VAT debt (guarantee that is only valid in Finland)
  • as well as 100% for the customs debt and the VAT debt (EU-wide guarantee)

An AEO is entitled to a reduction of the guarantee. The amount of guarantee required for customs debt is 30 % and for VAT debt, it is either 0 % (guarantee valid only in Finland) or 30 % for both customs debt and VAT debt (EU-wide guarantee).

Read more about the amount of guarantee for companies acting as representatives on the page Using a representative.

The guarantee category for liability for customs duty related to the comprehensive guarantee concerns transit, warehousing and other special procedures. When determining the amount of comprehensive guarantee for these, the companies are placed into guarantee categories BA, BB, BC and BD based on their financial solidity and payment behaviour.

Furthermore, in guarantee categories BD 0%, BC 30% and BB 50%, companies must, for example meet requirements relating to sufficient resources, records and in-house control.

Applying for exemption or a reduction

If you apply for comprehensive guarantee for special procedures or temporary storage and exemption from providing a guarantee (guarantee category BD 0%) or a reduced guarantee (guarantee category BC 30% or BB 50%), fill in the questionnaire in the management system for commercial and transport records. you do not have to fill in the questionnaire in guarantee category BA 100%.

How the guarantee category is determined is influenced by certain criteria in the questionnaire as well as solidity, for example. Below is an indicative table on the guarantee category enabled by the equity ratio. Customs will confirm the guarantee category during the processing.

Equity ratio

Guarantee category

negative

BA 100

0 % - 4,9 %

BB 50

5 % - 9,9 %

BC 30

10 % -

BD 0

The guarantee category for liability for customs duty related to the comprehensive guarantee concerns transit, warehousing and other special procedures. When determining the amount of comprehensive guarantee for these, the companies are placed into guarantee categories BA, BB, BC and BD based on their financial solidity and payment behaviour.

Furthermore, in guarantee categories BD 0%, BC 30% and BB 50%, companies must, for example meet requirements relating to sufficient resources, records and in-house control.

Applying for exemption or a reduction

If you apply for comprehensive guarantee for special procedures or temporary storage and exemption from providing a guarantee (guarantee category BD 0%) or a reduced guarantee (guarantee category BC 30% or BB 50%), fill in the questionnaire in the management system for commercial and transport records. you do not have to fill in the questionnaire in guarantee category BA 100%.

How the guarantee category is determined is influenced by certain criteria in the questionnaire as well as solidity, for example. Below is an indicative table on the guarantee category enabled by the equity ratio. Customs will confirm the guarantee category during the processing.

Equity ratio

Guarantee category

negative

BA 100

0 % - 4,9 %

BB 50

5 % - 9,9 %

BC 30

10 % -

BD 0

When assessing a company's solvency, the starting point is the company's financial statement. If the company is the parent company in a group of companies, the financial statement of the parent company is used in the assessment.

For the company to receive a reduction of the guarantee it must not have serious payment disruptions or bad credit rating. Serious payment disruptions comprise for example cases of bankruptcy, reorganisation or distraint, as well as payment disruptions relative to the size of the customer or the guarantee/reference amount.

Guarantee category Equity ratio Sufficient funds Payment behaviour
BA Negative No -
BB 0 % - 4,9 % Yes No serious or frequent payment disruptions
BC 5 % - 9,9 % Yes No serious or frequent payment disruptions
BD ≥ 10 % Yes No serious or frequent payment disruptions

Sufficient funds

In guarantee categories BD, BC and BB, companies must have sufficient funds in relation to the reference amount.

When determining if the funds are sufficient, all the different procedures used by the customer are added up (import, transit, warehousing and special procedures); the reference amount, i.e. the amount of customs debt as well as the amount of liability regarding customs duty and taxes.

The guarantees that the customer provides to Customs are deducted from the reference amount, and the reference amount not covered by the guarantee is compared with the customer’s balance sheet total.

The funds are sufficient when the balance sheet total is at least half of the reference amount with no guarantee:

  • (Total reference amount – guarantees) / balance sheet total ≤ 2.

In guarantee category BD, the requirement for sufficient funds is scaled according to equity ratio so that when the ratio increases, the requirement for sufficient funds is based on a lower balance sheet total.

Requirements for sufficient funds in guarantee categories:

Guarantee category

Equity ratio required for the guarantee category

Maximum reference amount without guarantee in relation to the balance *)

BA

negative

-

BB

≥ 0 %

2

BC

≥ 5 %

2

BD

≥ 10 %

2

BD

≥ 15 %

3

BD

≥ 20 %

4

BD

≥ 25 %

5

BD

≥ 30 %

6

BD

≥ 35 %

7

BD

≥ 40 %

8

BD

≥ 45 %

9

BD

≥ 50 %

10

 

*) (Total reference amount – guarantees) / balance sheet total

Example

  • The customer’s total reference amount is 200 000 euros (the import reference amount is 50 000 and the reference amount for inward processing is 150 000 euros).
  • The balance sheet total is 60 000 euros and the equity ratio is 10%.
  • The customer has no payment delays or payment disruptions.

When it comes to customs debt, the customer belongs in guarantee category AA (100%).

When it comes to liability for customs duty, the customer belongs in category BD (0%) based on their equity ratio and payment behaviour. Furthermore, the customer also meets the requirements specific to the guarantee category, e.g. related to records and in-house control.

In order to qualify for guarantee reductions, the customer must also have sufficient funds in relation to the reference amount.

Checking of sufficient funds in guarantee category BD (0%):

The amount of guarantee required is 50 000 euros in total. The import guarantee is 100% and the guarantee for inward processing is 0% of the reference amount.

(200 000–50 000 euros) / 60 000 euros = 2.5, i.e. the requirements regarding sufficient funds and guarantee category BD are not fulfilled.

Checking of sufficient funds in guarantee category BC (30%):

The guarantee requirement is 95 000 euros in total (50 000 euros + 45 000 euro). The import guarantee is 100 % of the reference amount and the guarantee for inward processing is 0 %.

(200 000–95 000 euros) / 60 000 euros = 1.75 i.e. < 2.

The requirement regarding sufficient funds is fulfilled when the customer delivers a guarantee in accordance with guarantee category BC for the liability of customs duty, and a guarantee in accordance with guarantee category AA for the customs debt.

Reference amounts for the procedures

When Customs determines the guarantee requirement for import, it takes into account the reference amount of the company’s import, i.e. the largest customs debt during the credit period. In order to make sure that the guarantee is sufficient, it is recommended that the import guarantee/reference amount is as least as much as the customer’s largest customs debt for 7 weeks.

The holder of a payment deferment authorisation is entitled to a payment period of about five weeks for customs duties and taxes to be collected in connection with the import clearance of goods. The company receives a periodic filing regarding the customs duties and taxes to be paid for goods released during one week. The due date for the payment of customs duties and taxes accordant with the periodic filing is the Friday of the fourth week following the week of release.

An amount corresponding to the customs debt is reserved as guarantee, from the comprehensive guarantee for import in connection with customs clearance. The reserved amount is released when the debt is paid (a delay of 1-2 days may occur from the time of payment). If there is not a sufficient amount of guarantee available for a new guarantee reservation, it is not possible to import goods using a credit number.

If a company wishes to make use of the payment period of about five weeks, the comprehensive guarantee must cover any pending payments during the credit period as concerns customs duties. Customs clearance decisions can also be paid for prior to their due date, using the payment reference number in the decision. In such cases, guarantee reservations are released earlier, and a smaller guarantee can be lodged for import.

Guarantee reservation for debt in different guarantee categories:

Release for free circulation

Guarantee category

Customs debt VAT
AEOC AB 30 % 0 %
Other AA 100 % 0 %

 

What is my company’s reference amount regarding importation?

The reference amount for the import procedure release for free circulation is the company’s largest customs debt during the credit period.

A company can indicate a higher reference amount if it wants to have more room for fluctuations in customs invoicing.

When releasing goods for free circulation, a 100% guarantee is required for the customs debt.

An AEO is entitled to a reduction of the guarantee required for customs debt. For the AEO, a guarantee of 30% is required for the customs debt.

Read more about the import reference amount for companies acting as representatives: Using a representative

In inward and outward processing, temporary admission and end use procedures a guarantee is required for the liability for customs duty in accordance with the customer’s guarantee category.

The reference amount for temporary admission and processing is the maximum amount of customs debt as well as VAT and excise debt (liability for customs duty and liability for tax) possibly to be collected for goods simultaneously under the procedure. However, a guarantee is required only for the liability for customs duty. Guarantee is reserved in connection with the customs clearance from the comprehensive guarantee according to the customer’s guarantee category, 0% – 100% for the liability for customs duty, and the guarantee remains reserved until the liability has expired (e.g. an acceptable bill of discharge has been presented).

The reference amount for the end-use procedure is the maximum amount of unlevied import duties for goods simultaneously under the procedure. Unlevied import duties means the difference between the general customs duty (as well as a possible anti-dumping duty) and the reduced rate of duty for end-use. Guarantee is reserved in connection with the customs clearance from the comprehensive guarantee according to the customer’s guarantee category, 0% – 100% for the liability for customs duty, and the guarantee remains reserved until the liability has expired (e.g. an acceptable bill of discharge has been presented). In the end-use procedure, the company must provide the maximum amounts of unlevied customs duties using this form:

The Union Customs Code provides that a company may be authorised to use a guarantee with a reduced amount for possible customs duties and other payments or to have a guarantee waiver, provided that, certain requirements are met. The company must not have a record of any serious payment disruptions or negative credit rating (e.g. bankruptcy, reorganisation or distraint). In addition, the company must meet the general requirements for the comprehensive guarantee authorisation, as well as the specific requirements based on guarantee category.

When the amount of liability guarantee is determined, companies are placed into guarantee categories based on their solidity and payment behaviour. Furthermore, companies must meet requirements specific to the different guarantee categories, for example relating to records and in-house control. In guarantee categories BD, BC and BB, companies must also have sufficient funds in relation to the reference amount.

The authorisation holder must keep track of the reference amount and contact the customs office of guarantee if the amount is not sufficient.

Guarantee reservation in different guarantee categories for specific use and processing:

Guarantee category BD BC BB BA
Customs duty 0 % 30 % 50 % 100 %
VAT and excise duty 0 % 0 % 0 % 0 %

What is my company’s reference amount regarding inward processing or temporary admission?

If the authorisation for inward processing or temporary admission was applied for with a customs declaration (simplified authorisation)

In guarantee category BA (100%), the reference amount for inward processing or temporary admission is the maximum amount of customs debt (liability for customs duty) possibly to be collected for goods simultaneously under a procedure.

In other guarantee categories, the reference amount for inward processing or temporary admission is the maximum amount of customs debt as well as VAT and excise debt (liability for customs duty and liability for tax) possibly to be collected for goods simultaneously under a procedure. However, a guarantee is required only for the liability for customs duty.

If the authorisation for inward processing or temporary admission was applied for from Customs Authorisation Centre (standard authorisation)

The reference amount for inward processing or temporary admission is the maximum amount of customs debt as well as VAT and excise debt (liability for customs duty and liability for tax) possibly to be collected for goods simultaneously under a procedure. However, a guarantee is required only for the liability for customs duty.

According to EU legislation, the operator must monitor and ensure that the amount of customs duties and taxes relating to inward processing and temporary admission simultaneously under a procedure does not exceed the reference amount. If the reference amount is insufficient, the operator should contact the Customs office of guarantee (lupakeskus@tulli.fi) before starting the procedure.

Guarantee for liability for customs duty in different guarantee categories

Guarantee category BD BC BB BA
Liability for customs duty 0 % 30 % 50 % 100 %

What is the reference amount for the company's end-use procedure?

The reference amount for the end-use procedure is the maximum amount of unlevied import duties for goods simultaneously under the procedure. Unlevied import duties means the difference between the general customs duty (as well as a possible anti-dumping duty) and the reduced rate of duty for end-use.

According to EU legislation, the operator must monitor and ensure that the amount of customs duties and taxes relating to end-use procedures simultaneously open does not exceed the reference amount. If the reference amount is insufficient, the operator should contact the customs office of guarantee (lupakeskus@tulli.fi) before starting the procedure.

Guarantee from the reference amount in different guarantee categories:

Guarantee category BD BC BB BA
Reference amount 0 % 30 % 50 % 100 %

The warehouse keeper must declare to customs the maximum value of goods stored simultaneously in the warehouse.

The warehouse reference amount, i.e. the amount of liability for customs duty and tax, is determined based on the maximum value of the warehouse. In the reference amount, the default liability for value added tax is 25.5% and the liability for customs duty it is 4.5%. If the warehouse contains only one type or a few types of products, the reference amount can be determined according to actual tax and customs duty percentages.

The reference amount will also include any possible excise duties. As concerns excise duties, 30% of their maximum value will be taken into account in the reference amount.

When determining a guarantee for a customs warehouse or a temporary storage facility, the reference amount for the warehouse is considered based on the guarantee type. 

Warehouse guarantee share of the reference amount in different guarantee categories:

Guarantee category BD BC BB BA
Customs duty and excise taxation 0 %  30 % 50 % 100 %
VAT 0 % 0 % 10 % 50 %

The authorisation holder must keep track of the value of the stored goods. The warehouse keeper must make sure that the value of goods stored simultaneously in the warehouse does not exceed the reported maximum value.

Provide the warehouse information with form 945e – Value declaration for goods in storage

Example for calculating the reference amount of the warehouse

The maximum value of goods stored simultaneously in a warehouse: 100 000 euros
The average amount of excise duty on goods stored simultaneously in a customs warehouse: 50 000 euros
Liability for customs duty: 4.5% x 100 000 euros = 4500 euros
Liability for VAT: 25.5% x 100 000 euros = 25 500
Liability for excise duty: 30% x 50 000 euros = 15 000 euros
VAT liability for excise duty: 25.5% x 15 000 euros = 3 825 euros
Total reference amount 48 825 euros

The operator must monitor and ensure that the amount of customs duties and taxes on goods simultaneously in the warehouse does not exceed the reference amount. If the reference amount is insufficient, the operator must contact the Customs office of guarantee (lupakeskus@tulli.fi) before starting the procedure.