During warehousing or storage

Undeclared goods be handled in different ways during the warehousing or storage, depending on whether the goods are in a temporary storage facility or in a customs warehouse.

  • Goods in temporary storage can only be handled to ensure their preservation in an unaltered state. However, their appearance or technical characteristics may not be modified as a result of the handling. With permission from Customs, the goods can also be examined and samples can be taken of them.
  • Goods stored in a customs warehouse can be handled more than that. Goods may undergo handling e.g. to ensure preservation of the goods, improve their appearance or marketable quality or to prepare them for distribution or resale (so-called usual forms of handling). In practice, this can mean e.g. repackaging the goods into various assortments.

Examination of goods in temporary storage

The temporary storage operator or the holder of the goods may need to examine the received goods e.g. by opening boxes in order to establish the goods description and quantity. In some cases, they may wish to take samples of the goods for import clearance.

If you wish to examine the goods or take samples of them, you should request permission from Customs. The examination of the goods and the taking of samples must be carried out under customs supervision and on the conditions determined by Customs.

Customs can give the permission to the holder of the temporary storage operator or to the holder of the goods. Upon their request, the permission can also be granted to other operators.

Request permission by sending email to the customs office supervising the operational activity of the temporary storage facility or to the nearest customs office.

Customs offices that supervise warehousing and storage operations
Contact details of all customs offices

What details to include in the request

You should include at least the following details in the request

  • contact details of the applicant (holder of the goods or temporary storage operator)
  • location of the goods
  • goods description and quantity
  • details of the previous declaration or procedure
  • what is going to be done with the goods and by whom
  • if required, details relating to the transport, such as details of the means of transport.

Customs replies to the request in writing and agrees on the details of the examination. 

The storage operator attaches the details of the examination to the records

The storage operator attaches the following to the records:

  • request concerning examination
  • reply by Customs
  • their description of the handling of the goods. 

If the examination reveals that the goods are not at all what was declared to customs or that the quantity of the goods is not what was entered in the records, the record entry must be corrected. Any corrections in the records must be approved by Customs.

If a temporary storage declaration has been submitted for the goods, it should also be amended where necessary. Read more about amending temporary storage declaration

 

The company that requested the examination of the goods is responsible for any costs caused by the examination.

If the examination or measure requires the presence of Customs you may have to pay a service charge. It is a charge for performance under public law, in this case for an inspection visit or other customs measure in a temporary storage facility, for reasons attributable to the holder of the goods or the storage operator.

Fees charged for services

 

Handling of goods during customs warehousing

Goods in a customs warehouse can, under certain conditions, be handled (so-called usual forms of handling.

The goods can also, with permission from Customs,

  • be temporarily removed from the customs warehouse
  • replaced with equivalent goods.

Goods placed under customs warehousing can undergo so-called usual forms of handling intended to

  • ensure preservation of the goods
  • improve the appearance or marketable quality of the goods
  • prepare the goods for distribution or resale.

Usual forms of handling do not require a separate authorisation, but an entry concerning the handling must be made in the records.

The goods must not change too much – any major forms of handling must be carried out under the inward processing procedure.

The handling must not change the original nature of the goods or affect its performance or characteristics.

If the intended handling operation would change the nature of the goods in such way that e.g. the device could no longer operate independently, the handling operation cannot be carried out as a usual form of handling. In such cases, the goods must be handled under the inward processing procedure.

With certain exceptions, the eight-digit commodity code (CN code) of the goods must remain the same. If the commodity code changes due to the handling, the new commodity code must be entered in the records.

What can constitute a usual form of handling?

Annex 71–03 to the Delegated Regulation (EU) 2015/2446 contains a list of permitted usual forms of handling.

Examples of usual forms of handling:

  • elementary repairs of damage incurred during transport or storage
  • change of packing
  • affixing price tags or other similar distinguishing signs
  • testing of machines or apparatus in order to control the compliance with technical standards, if only simple operations are involved
  • denaturing, even if this results in a different eight-digit CN code.

Legislation

If goods are going to be removed temporarily from the customs warehouse, the removal must be authorised by Customs in advance, unless the removal is caused by force majeure, such as a fire. The authorisation can be granted in the customs warehousing authorisation, or it can be applied for on a one-time basis from the customs office supervising the operational activity of the warehouse.

If for example, a usual form of handling cannot be carried out in the facilities of the customs warehouse, the goods can be temporarily removed from the customs warehouse for the handling.

Example

Walter’s Warehouse has received a car into their customs warehouse. The car has suffered superficial scratches during the sea transport. The repairs cannot be carried out at Walter’s Warehouse, but Rick’s Repair Shop limited partnership offers such repair services.

Walter sends an email to the customs office supervising the operational activity of the warehouse. In the email, he lists the intended handling operations, the place of handling as well as the start time and end time of the removal.

Customs authorises the removal. Walter moves the car to Rick’s Repair Shop and makes an entry of the removal and the handling in the records. The car is touched up and returned to the warehouse. Walter makes an entry in the records of the return of the car to the warehouse.

Read more about movement of goods under customs warehousing.

Legislation

Union Customs Code (Regulation (EU) No 952/2013 of the European Parliament and of the Council), Article 240(3)

Equivalent goods consist of Union goods which are stored instead of the goods placed under the warehousing procedure.

Equivalent goods become non-Union goods. The goods placed under the customs warehousing procedure that are replaced by the equivalent goods become Union goods. The change of status takes place when the customs warehousing of the non-Union goods is discharged with a subsequent customs procedure or when the equivalent goods have been taken out of the customs territory of the EU.

Import VAT and any other charges due must be paid for the equivalent goods, but no import duties.

You will need an authorisation

The use of equivalent goods requires an authorisation granted by Customs. The use of equivalent goods must be indicated in the customs warehousing authorisation. You can apply for the authorisation when applying for a new warehousing authorisation or you can apply for amendment of your current warehousing authorisation.

What goods can be equivalent goods?

Equivalent goods must be identical to the goods they are replacing. Both must have the same

  • eight-digit CN code
  • commercial quality
  • technical characteristics.

 

There are restrictions to the use of equivalent goods. For example, the use of certain agricultural products and organically produced goods as equivalent goods is restricted.

Records and identification

When you are authorised to use equivalent goods, you do not need to submit any notification of the use of equivalent goods to Customs. You must, however, make an entry of the use in the warehouse records.

Equivalent goods can be stored with other Union goods or undeclared goods. The use of equivalent goods must not jeopardise the proper conduct of the procedure or customs supervision. Customs may require special methods for identifying the goods in order to distinguish the goods from each other.

If identification is impossible at all times or would only be possible at a disproportionate cost, Customs can authorise accounting segregation to be carried out. The records must be kept up-to-date at all times.

Example

An operator has a customs warehousing authorisation permitting the use of equivalent goods. One of the customs warehouses is located in Kotka and the other one in Rovaniemi.

In the warehouse in Rovaniemi, there are 1 000 car tyres that have been placed under the customs warehousing procedure (non-Union goods). In the warehouse in Kotka, there are 400 car tyres that have been placed under the customs warehousing procedure (non-Union goods) as well as 600 tyres that have been released for free circulation (Union goods). The Union goods (600 tyres) are entered in the records as equivalent goods.

Car tyres, stock balance 12 April 2024 Kotka Rovaniemi Total
Under the customs warehousing procedure 400 1 000 1 400
Union goods, entered in the records as equivalent goods 600 0 600
Total 1 000 1 000 2 000

On 15 April, the operator receives an order to deliver 1 000 tyres to the United Kingdom.The tyres are delivered on 16 April from the warehouse in Kotka, because it is logistically sensible. The operator submits a re-export declaration and an export declaration:

  • The 400 tyres (non-Union goods) placed under the customs warehousing procedure are declared in the re-export declaration.
  • The 600 tyres (Union goods) entered in the records as equivalent goods are declared in the export declaration.

All tyres exit the customs territory of the EU on 17 April.

While the 600 tyres used as equivalent goods are declared for the export procedure, an import declaration (procedure code 4071 and additional procedure code 160) is submitted for the 1 000 tyres stored in Rovaniemi. In that case, Customs will not collect any import duties, only import VAT and any other charges due. For the customs warehouse keeper, the import release decision also serves as a document with which they move the 600 tyres in the Rovaniemi warehouse from the customs warehouse records to the records of Union goods.

Car tyres, warehouse transactions
16.–17 April 2024
 		 Kotka 15.4. Kotka 16.4. Balance Kotka 17.4. Rovaniemi 15.4. Rovaniemi 16.4. Balance Rovaniemi
17.4.
Under the customs warehousing procedure 400 -400 0 1 000 -600 400
Union goods, entered in the records as equivalent goods 600 -600 0 0 +600 600
Total 1 000 -1 000 0 1 000   1 000

 

Read more

Detailed guidance: The use of equivalent goods in special procedures (pdf, in Finnish)

Legislation

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