Anyone can deposit goods in a public customs warehouse, that is, there can be several procedure holders. Public customs warehouses are or two types; type I and type II. The difference between the two is mainly how the responsibility is divided. In the case of public customs warehouses type I, the responsibilities lie with both the holder of the authorisation (warehouse keeper) and the holder of the procedure (depositor). In public customs warehouses type II, the responsibilities of the holder of the procedure are more extensive. In practice, the holder of the procedure is often referred to as the depositor.
In a private warehouse the holder of the authorisation is also the holder of the procedure and is responsible for keeping the goods under customs supervision as well as for fulfilling the obligations connected with the storing of the goods. The holder of the authorisation does not have to own the goods. The goods is deposited in the warehouse with a customs declaration, which is submitted in the name of the authorisation holder.
In warehouse deposits, the holder of the authorisation is the company, which has been granted a comprehensive guarantee and warehousing authorisation from Customs. In practice, the holder of the procedure is often referred to as the warehouse keeper.
In customs warehousing the holder of the procedure is the company, which draws-up the customs declaration regarding goods to be deposited in the warehouse. The holder of the procedure is always responsible for the customs declaration and its data content. Depending on the type of warehouse, the responsibility can also include record keeping.
All goods brought into the country must be presented to Customs. Transports arriving by road are presented to Customs, or else the transport operator submits an electronic manifest presentation to Customs. If the undeclared goods are subsequently unloaded into a temporary storage facility, you have 90 days from the date of the manifest presentation, i.e. about three months, to decide what you aim to do with the goods. You can for instance re-export the goods out of the EU or clear them through Customs into Finland.
Please note that 90 days is the maximum time provided by law, and some of the temporary storage keepers apply a shorter time limit.
Goods under the customs warehousing procedure can under certain circumstances be moved under this procedure, which means that they do not have to be transited. No separate authorisation is needed for moving the goods. However, legislation requires that the location and movements of the goods are entered into the warehouse records.
The following transfers are possible:
- Transfer from the place where the goods were placed under the procedure means that, for example, goods that have arrived in Finland by sea can be placed under the customs warehousing procedure already in the harbour. After this, they can be moved from the place where they were placed under the procedure (entry to warehouse).
- Moving goods between warehouses mentioned in the same authorisation means that goods can be moved between these warehouses without customs formalities.
- Transfer from a warehouse to a place of exit in the Union means that a re-export declaration is submitted for goods to be taken to the EU. After the declaration is submitted, the goods are moved from the customs warehouse under the customs warehousing procedure to the place of exit in the EU for re-exportation. The warehouse operator is responsible for the goods for the duration of the transfer.
- Goods are moved from the warehouse to a customs office where they are placed under the subsequent customs procedure.
Goods in temporary storage can be moved in two different situations.
- The temporary storage keeper has applied for permission from Customs to move consignments in temporary storage to warehouses of certain cooperation partners. The goods are moved under the responsibility of the authorisation holder.
- An import declaration has been submitted to Customs for the goods and a guarantee has been reserved for the customs clearance. Customs has decided to inspect the goods, and possibly take samples. The holder of the goods notes that inspecting the goods in the temporary storage facility is hard or impossible, and requests that the goods be moved during temporary storage. Customs grants a transfer permit for the goods under temporary storage. With this document, the goods can be moved for example to the importer’s own warehouse. A copy of the document is left in the records of the temporary storage facility. When the inspection and possible laboratory examinations have been made, the customs clearance process is concluded. The declarant is responsible for possible further measures and interactions with Customs. For the temporary storage records, the storage keeper only needs the transfer permit for the goods in temporary storage.