Authorisations and responsibilities of storage operators and warehouse keepers

Customs can grant an authorisation to store undeclared goods briefly in temporary storage at a location other than an actual temporary storage facility. An authorisation granted by the Customs Authorisation Centre is required for this. You also need a comprehensive guarantee authorisation for storing goods at a location approved by Customs.

The Authorisation Centre issues a unique warehouse ID for the location. The mode of transport determines whether the goods are received at the storage facility with an entry declaration or with a transit declaration. The goods are to be placed under a customs procedure or re-exported within three days from their presentation. If the goods have arrived under the transit procedure and the authorisation holder has the authorisation for the status of authorised consignee for transit, the time limit is six days.

The holder of the authorisation for a location approved by Customs must keep records of the goods in temporary storage. The records must contain the following:

• date of arrival of the goods (day of presentation)
• reference to previous declaration (such as transit MRN)
• reference to the customs procedure that ends temporary storage (such as import MRN)
• date of the decision on release.

Temporary storage at a location designated by Customs is always an exceptional situation. A location designated by Customs could be e.g. so-called industrial ports that are approved by the Finnish Transport and Communication Agency Traficom and that receive receive commercial traffic. In such cases, a pre-lodged customs declaration must have been submitted for the goods or the goods are to be presented as Union goods upon arrival. Therefore, storage at a location designated by Customs does not require an authorisation from the Authorisation Centre. Temporary storage of goods at such a location is allowed only for three days from the submission of the temporary storage declaration and presentation of the goods to Customs. Customs controls that the time limits are observed.

Read more on the page Temporary storage declaration or temporary storage declaration and presentation notification (FI337, FI335), under ”The goods are declared as arriving at a location designated by Customs, i.e. a so-called industrial port. (additional information code FIOSP)”.

As a holder of the warehouse authorisation granted by Customs, you undertake to observe the responsibilities and obligations and practices determined by the legislation. In addition, you commit yourself to observing the authorisation instructions published on our website. Customs monitors the activities of the authorisation holders and performs controls of the stored goods and records. If an authorisation holder or, in a customs warehouse, a holder of the procedure doesn’t observe the legislation or Customs’ regulations and instructions, Customs may issue an admonition or a penalty fee or impose a customs duty increase, suspend the validity of the authorisation or revoke the authorisation.

• Authorisation instruction – temporary storage
• Authorisation instruction – customs warehousing
• Authorisation instruction – authorisation for entry in the declarant’s records in customs warehousing

All authorisation instructions

Your responsibilities depend on whether you have an authorisation for temporary storage or for customs warehousing. The holder of the temporary storage authorisation is responsible for everything relating to storage. In customs warehousing, the responsibility is divided between the authorisation holder and the holder of the procedure.

Your responsibilities are the following:

• You are responsible for ensuring that the customs legislation, such as the time limits required by law, is observed at the storage facility/in the warehouse.
• As the authorisation holder, you are responsible for making sure that the goods remain at the storage facility/warehouse (under customs supervision) and that they are not released for free circulation without Customs’ permission. If undeclared goods are moved from a place approved by Customs indicated in the authorisation or if they are released from the storage facility/warehouse without Customs’ permission, a customs debt may be incurred.
• Check what you have to do if you need to move undeclared goods e.g. for an inspection by Customs or to another storage facility/warehouse. Some movements under temporary storage require that the warehouse authorisation permits movement of goods. Read more about movement of goods.

• As the authorisation holder, you have to clarify any irregularities in the storage/warehouse records to Customs. The obligation to keep records depends on the type of storage/warehouse type. If you are responsible for keeping records, you will ensure that the records are kept in accordance with the customs legislation and other instructions given by Customs, that the entries are made correctly, that the records are appropriate and up to date and that the documentation is archived appropriately.
• It is the responsibility of the authorisation holder to check that when goods are released from the storage facility/warehouse, the details in the release document match the consignment details and that the details haven’t changed during storage/warehousing. In practice, this means, for example, that the details of the previous procedure, such as code, MRN and goods item number, provided in the release document are correct.
• If goods go missing during storage/warehousing or if the audit trail in the storage/warehouse records is not complete, you will pay the customs duty, VAT and any other taxes and charges due for the goods.
• In customs warehousing, the holder of the procedure is responsible for ensuring that the customs declaration for placing the goods under the customs warehousing procedure contains sufficient and accurate details. If you store your own or your customers’ goods in the customs warehouse and you always submit the customs declarations and do the customs-related paperwork on behalf of your customers in your own name, the responsibilities for the role of the holder of the procedure also lie with you.
• As the authorisation holder for a private customs warehouse, you are also the holder of the procedure and responsible for fulfilling the obligations relating to warehousing. The customs warehousing declaration must be submitted in the name of the authorisation holder.
• If goods are moved under the customs warehousing procedure, the responsibility is divided in different ways in private and public customs warehouses:
  • The authorisation holder of a private customs warehouse is responsible for the movement. The responsibility for the goods begins before the movement, that is, when the goods are placed under the customs warehousing procedure.
  • In a public warehouse, there can be several holders of the procedure who can be other operators than the holder of the authorisation. The authorisation holder and the holder of the procedure together are responsible for the movement.
• As a holder of a comprehensive guarantee authorisation, it is your responsibility to follow the reference amount indicated in the comprehensive guarantee authorisation and the warehouse authorisation. The reference amount is the amount of taxes on the goods in the storage facility/warehouse. This includes customs duties and any other charges payable, such as VAT and excise duty. Use real time follow-up to make sure the reference amount is not exceeded. If the reference amount indicated in the authorisation is smaller than the amount of taxes on the goods at the storage facility/in the warehouse at any given time, please inform the Customs Authorisation Centre.
• You are responsible for submitting the required reports to Customs.
• As a holder of the customs warehousing authorisation, it is your responsibility to submit a discharge notification concerning customs warehousing to Customs.

If you store goods that require special circumstances, such as medicines or dangerous substances, you will need, in addition to an authorisation from Customs, an approval or a licence from other authorities, depending on the goods. As the storage operator/warehouse keeper, you are responsible for ensuring that you have all the required licenses and authorisations.

The licensing authorities in Finland are e.g. the Finnish Food Authority, the Finnish Medicines Agency (Fimea), the Regional State Administrative Agency, the National Supervisory Authority for Welfare and Health (Valvira), the Ministry of Defence, the Finnish Environment Institute (Syke) and the rescue authorities. Check what information you have to provide to other authorities or what kind licenses you need for storing goods. For example, to store cigarettes you need a license from Valvira in addition to the authorisation from Customs. There are also other provisions regarding the sale of cigarettes and alcohol. More information is available on the websites of the Regional State Administrative Agency and Valvira.

• Finnish Food Agency: foods, animals, plants
• Pelastustoimi.fi – rescue services: storing dangerous substances
• Fimea: medicines and medicinal substances
• Syke: waste, chemicals, endangered species
• Regional State Administrative Agency: alcohol, tobacco, foods
• Valvira: manufacture, import, sales and storage of tobacco and alcohol

If you store a customer’s goods at your storage facility/in your warehouse, and the customer never comes to collect them, you as the storage operator/warehouse keeper are still responsible for storing the undeclared goods. If you need to get rid of the goods, the goods can e.g. be placed under a customs procedure or destroyed. You as the storage operator/warehouse keeper are responsible for the costs.

Warehouse authorisation

Fill in the application in the Authorisations and Decisions Service. Attach a trade register extract as well as the layout of the warehouse or some other documentation of the facilities or the place intended for storing undeclared goods. You should also attach documentation of the value of the goods to be stored. Send the application via the service to the Customs Authorisation Centre.

You can speed up the processing of your application by being proactive. You can, for example, draw up a description of your company’s warehousing/storage process before submitting the application. In the application, provide the details of the person in your company who is responsible for matters regarding warehousing/storage. When the application is being processed, reply to the processing officer’s questions as swiftly and accurately as possible.

In the case of long downtime in the Authorisations and Decisions Service, you should ask the Authorisation Centre if you can apply for the authorisation using an application form.

Comprehensive guarantee authorisation

If your company does not have a comprehensive guarantee authorisation, apply for it in Customs’ Authorisations and Decisions Service and attach the details of your company’s finances requested in the service. When the comprehensive guarantee authorisation has come into force, you can submit your warehouse authorisation application.

During the application process for the comprehensive guarantee authorisation, you will be notified of the amount of the guarantee possibly required for warehousing/storage. You will receive a decision on your application indicating the guarantee reference amount for warehousing/storage. The reference amount is calculated according to the amount of customs duty, VAT and any other taxes possibly to be levied on the goods. The guarantee is usually provided as a bank guarantee.

The guarantee amount varies according to prescribed principles. You can estimate the amount of required bank guarantee by calculating 30% of the maximum value of the goods. This amount is usually the maximum amount of the guarantee. The guarantee amount may decrease if, for example, the company’s finances are in good shape.

If your current comprehensive guarantee authorisation does not cover warehousing/storage, you should apply for amendment of the authorisation

Read more about the comprehensive guarantee authorisation

 

If customs supervision is not jeopardised, Customs can grant an authorisation to store EU goods or goods placed e.g. under the export procedure in the same facilities where a temporary storage facility or a customs warehouse is operated. In practice, this usually means that the goods have been separated at least in the records. The separation can also be made e.g. with storage place markings or package markings.

Customs does not have any specific technical requirements for warehouse/storage facilities. However, staff facilities, break rooms and office spaces cannot be included in the warehouse/storage facilities. During the authorisation process, Customs will check the facilities. These facilities must be separated from the rest of the building or area so that access by unauthorised persons is restricted. During the opening hours, the warehouse/storage facility can be supervised for example so that unauthorised persons can only access it when staff is present.

If a building or an area also houses other companies in addition to the holder of the warehouse authorisation, the facilities used by these companies must be separated from the warehouse/storage facilities for example with a permanent wire fence.

Warehouse authorisations are not granted for private residences or other facilities belonging to them.

Some of the changes in warehouse/storage operations are such that the authorisation holder can contact the customs office that supervises the operational activity of the warehouse/storage facility or the Authorisation Centre to notify of the changes. Some of the changes require amendment of the valid authorisation through an amendment application.

In the case of the following changes, contact the customs office supervising the operational activity of the warehouse/storage facility:

• Changes are made to the warehouse/storage facilities in the location indicated in the authorisation.
• Changes are made to the accounting system or the whole system is replaced. Contact the customs office before making the changes. The new records cannot be introduced before Customs’ approval.

In the case of the following changes, submit an amendment application in the Authorisations and Decisions Service:

• Apply for amendment of the warehouse authorisation if the whole warehouse/storage facility is moved to another address. Apply for amendment of the warehouse authorisation also if the warehousing/storage at a specific address ends and some of the warehouse IDs in the authorisation remain valid.
• Apply for amendment of the comprehensive guarantee authorisation if the value of the stored goods changes and you wish to decrease or increase the reference amount of the comprehensive guarantee.
• Apply for revocation of the authorisation if you stop storing goods and want the authorisation to be revoked.

Apply for a new authorisation if the company’s Business ID changes due to corporate restructuring

If the authorisation holder’s Business ID changes due to corporate restructuring, you should apply for a new authorisation several months before the change to avoid any unnecessary interruption in the operation. You will also need a new EORI number.

Notify Customs of these changes in advance

If the person in charge of the company’s customs matters is changed, you should notify at least the Customs Authorisation Centre of the change. Provide the new person’s whole name and personal identity code. Send the details by secure email. You can also send a contact request by email to the Authorisation Centre and provide the personal identity code by phone.

• Contact details of the Customs Authorisation Centre
• Contact details of the customs office supervising the operational activity of warehouses/storage facilities

If undeclared goods are unloaded after presentation into a temporary storage facility, the holder of the goods has 90 days – around three months – from the date of the presentation notification to decide what to do with the goods. Goods in temporary storage must be cleared within the time-limit prescribed in the customs legislation. For temporary storage, the time limit is 90 days from the presentation of the goods. The holder of the temporary storage authorisation is responsible for observing the time limit.

Please note that 90 days is the maximum time permitted by law and cannot be extended. Some temporary storage operators apply a shorter time limit. Where possible, the temporary storage operator must notify the consignee of the goods early enough of the arrival of the goods, so that the consignee can declare the goods within the prescribed time limit.

The time limit starts to run from presentation

The time limit for temporary storage starts to run when the goods have been presented to customs.

If the goods arrive by sea, air or rail and an entry summary declaration or a temporary storage declaration has been submitted for them upon arrival, the time limit starts to run when an electronic presentation notification has been submitted for the goods.

If the goods arrive under transit, the time limit starts to run when Customs has issued an unloading permit for the goods.

Customs may impose a customs duty increase or penalty fee if the goods are cleared late.

The temporary storage operator must keep a list of goods that have exceeded time limit and submit the list monthly to Customs. The list needs to be made when a transit declaration or an entry summary declaration or a summary declaration for temporary storage submitted to the Arrival and exit declaration system (AREX) was used as the temporary storage declaration.

This means that no list needs to be kept of goods for which a temporary storage declaration (TSD) has been submitted to Customs or for which an entry summary declaration (ENS) has been submitted to the European Commission’s system. Regarding these goods, Customs can notify the storage operator and the submitter of the temporary storage declaration when the time limit for temporary storage is about to expire.

The list of goods that have exceeded the time limit must be submitted to Customs

When an entry summary declaration or a summary declaration for temporary storage submitted to the Arrival and exit declaration system (AREX) was used as the declaration that starts temporary storage, the temporary storage operator must keep a list of the goods that have exceeded the time limit. The list must include the goods that have not been placed under a customs procedure or re-exported within the prescribed time limit. These goods must be listed and reported to Customs even if they have already been released from the storage facility.

Send the list for every calendar month, by the 10th day of the following month to the customs office that supervises the operative activity of the storage facility. Customs may impose a penalty fee if the storage operator does not keep such a list or does not submit it to Customs.

The list must contain the following details:

• name and Business ID of the holder of the temporary storage authorisation and warehouse ID
• contact information of the storage operator
• date
• consignor and consignee of the goods (if known)
• goods description
• MRN of the declaration used as the temporary storage declaration and goods item number
• reference and date of the customs document ending temporary storage, if the time limit for customs clearance has been exceeded during the calendar month and the goods have then been cleared.

What to do if you are notified of the impending expiry of the time limit for temporary storage

Customs may notify the submitter of the temporary storage declaration and the storage operator when the customs clearance period is about to expire. The notification can only be sent for the goods for which a temporary storage declaration (TSD) has been submitted to Customs or for which an entry summary declaration (ENS) has been submitted to the European Commission’s system. Customs will send the notification one week before the expiry of the customs clearance period.

You will receive Customs’ notification via message exchange or via the Customs Clearance Service. When you receive the notification, you should do this:

• If the goods item has not been cleared, you should clear the goods immediately.
• If the goods item has already been cleared, submit a free-form contact message to Customs or a contact request in the Customs Clearance Service. When you contact Customs, please provide the details of the subsequent customs procedure, such as the MRN of the import declaration and the goods item number.
• If the presented goods have not arrived at the storage facility at all, see the instructions on the page Arrival of goods at the warehouse or storage facility.

If the time limit for customs clearance expires

If the goods have not been cleared within the prescribed time limit, Customs will take corrective measures. Customs may e.g. sell the goods. The temporary storage operator stores the goods in their own facilities and delivers the goods to be sold at a customs auction to Customs, when a date has been agreed on.

If the goods cannot be sold at a customs auction e.g. because of import restrictions, the condition of the goods, missing documents or for some other reason, they must be destroyed under customs supervision. The holder of the goods, that is, the party that has notified that the goods should be destroyed, is responsible for the costs of destroying and moving the goods. The temporary storage operator is ultimately responsible for the costs of destroying and moving the goods. As the holder of the goods, the temporary storage operator is responsible for the goods also during the transport.

Read more

• Regulation 14/2016 of Finnish Customs on the responsibilities of the holder of the temporary storage authorisation with regard to goods that have not been placed under a customs procedure or re-exported within the prescribed time limit (in Finnish)
• How to submit an import declaration

In the customs warehousing procedure, there is usually no time limit for warehousing. However, a time limit may be set for the warehousing if the type and nature of the goods, in the case of long-time storage, pose a threat to human, animal or plant health or to the environment.

The authorisation specifies the goods categories covered

The authorisation for the simplification specifies the product groups, at the level of at least six digits, that can be placed under the procedure with an entry in the declarant’s records. The commodity codes of the goods must be entered in the records at the level of at least six digits.

Details to be entered in the declarant's records

The nature and the scale of the company’s operation are taken into account in the requirements concerning the data content of the records. The records data required by the EIR authorisation can be either separate from the customs warehouse records or part of the customs warehouse records.

The authorisation holder must on a daily basis enter the goods received at the customs warehouse in the records.

When entry in the declarant’s records is used in customs warehousing, the following details must be entered in the warehouse records:

• date of placement under the procedure
• MRN issued to the presentation notification and sequence numbers of the goods items
• consignee (known)
• goods description to identify the goods
• kind of packages and number of packages
• marks and numbers
• container number, if any
• commodity code at the level of at least six (6) digits
• gross mass
• procedure code “7100 – customs warehousing”
• number of the simplification authorisation, if required.

Details that apply to all warehouse transactions can only be entered once in the records, so they do not need to be repeated for each transaction. Such a detail is, for example, the procedure code. In addition to the above details, the records must also contain other details that are required in the customs warehouse records. Such details are, for example, the number and date of the customs declaration preceding the customs warehousing procedure and of the customs declaration discharging the procedure as well as the supplementary quantity.

The authorisation holder must also follow the general authorisation instructions for both the EIR authorisation and the customs warehousing authorisation.

If something changes, apply for amendment of the authorisation

If the company has the EIR authorisation and there is a change in the operation, e.g. the goods coverage changes, apply for amendment of the authorisation in Customs’ Authorisations and Decisions Service.

Legislation

• Union Customs Code (Regulation (EU) No 952/2013 of the European Parliament and of the Council), Article 182
• Commission Delegated Regulation (EU) 2015/2446, Article 150
• Commission Implementing Regulation (EU) 2015/2447, Article 234

Read more

• Authorisation for the status of authorised economic operator AEO
• Instructions on authorisations
• Warehouse and storage records

The authorisation holder or the holder of the procedure must, on Customs’ request, submit an up-to-date inventory list (stock balance). It is a list of the goods that, according to the records, are still in temporary storage or under the customs warehousing procedure. It can be printed out from the stock records or submitted in some other way. Customs can request the inventory list e.g. in connection with controls. Customs may also request a list of the warehouse/storage transactions.

The inventory list for a temporary storage facility and for a customs warehouse must contain at least the following details:

• name and contact details of the authorisation holder
• warehouse ID
• MRN of the arrival document or, if there isn’t any, deposit number
• date when the goods arrived in the warehouse/storage facility
• goods description
• gross mass
• number of packages
• kind of packages.

The inventory list for a customs warehouse must also contain the following details:

• supplementary quantity if required for the commodity code
• supplementary unit if required for the commodity code

The warehouse keeper/storage operator can also add other details to the inventory list, such as warehouse/storage location and net weight.

When customs officers arrive to inspect stored goods, the warehouse keeper/storage operator must assist them with the inspection. When customs officers inspect goods transported in packages, the warehouse keeper/storage operator must open and close the transport packaging for the consignment. After the inspection, customs officers will place an adhesive tape with the text “Opened by Customs” on the opened consignment. The warehouse keeper/storage operator is also responsible for moving goods in the warehouse between the place where the goods are shelved/stored and the place of inspection, if necessary.

Some of the controls carried out by Customs are subject to a charge. For example, a charge according to the Decree on Criteria for Charges Payable to the State is collected on laboratory examinations. On the Customs website, you can check the fees charged for Customs’ services.

Legislation

Union Customs Code (Regulation (EU) No 952/2013 of the European Parliament and of the Council) , Articles 140, 188–190

See to the maintenance of the warehouse/storage facility as follows:

• See to the facilities (access control, cleanliness and order).
• Store undeclared goods only in the area indicated in the authorisation.
• Find out what goods you are receiving and ask the customer for more information, if necessary. If you detect that goods are missing or that there are excess goods, you should always notify Customs and enter the actually received quantity in the records. If the declaration for the goods was submitted electronically, submit the notification of missing or excess quantity electronically.
  • If goods need to be inspected or if packages need to be opened, ask Customs to be present. The temporary storage operator must not touch the goods at all, and the keeper of a customs warehouse can only do so in a limited manner in order to carry out so-called usual forms of handling. Read more on the page During the warehousing or storage.
  • If the presence of Customs is required, a charge according to the Decree on Criteria for Charges Payable to the State (around 100 euros/hour) will be collected on the inspection visit. Check the fees charged for services.
• If the stored goods are spoiled or if they, for some reason, are rendered unfit for sale during the warehousing/storage, you should notify Customs of it. If you destroy stored goods without notifying Customs, you will have to declare the goods at their full value. If the goods must be destroyed, attach the certificate of destruction issued by Customs to the records. Read more about destruction of goods.
• See to the records and make sure that the goods descriptions, kinds of packages and quantities in the records correspond to the actual situation and that they do not change between deposits and removals. You should notify Customs if there is a discrepancy between the documents and the goods.
  • The storage operator / warehouse keeper is responsible for goods that have gone missing during storage/warehousing. If you notice that goods have gone missing from your warehouse, notify Customs immediately and be prepared to declare the missing goods. When you report that goods have gone missing, you can declare them yourself and as a rule, no penalty fees or customs duty increase will be levied in conjunction with customs clearance.
• If you detect an error in the records, correct the error. The correction must be approved by Customs.
• If needed, notify Customs of goods that have exceeded the customs clearance period and the stock balances.
• Keep a close eye on what you release from your warehouse/storage facility. If the measurement unit or description of the goods changes during warehousing/storage, in the records this may look like goods have goon missing from the warehouse/storage facility. The warehouse keeper/storage operator is responsible for declaring the goods that have gone missing from the warehouse/storage facility.
  • The goods description can be specified during warehousing/storage? It cannot be changed completely.
  • Goods can only be removed from the warehouse/storage facility using the same measurement unit as on deposit.
    • Example: In the transit declaration, 1 pallet (1 PX) containing 15 cases (CS) has been provided. The goods are going to be handled as cases, so the pallet is split into cases. The warehouse keeper/storage operator indicates the change in the unloading report for transit with “1 PX = 15 CS” and enters the same details in the records.
  • If the change has not been indicated in the unloading report and in the records and you want to remove goods from the warehouse/storage facility using a different unit, you should contact Customs.
  • Goods can be loaded as larger units for transport. The documents must indicate how the goods are packed, e.g. “15 CS = 1PX”.