The ABC of warehousing and storage

You need a warehouse or storage facility for undeclared goods, when you don’t want to or can’t declare the goods as soon as they arrive in Finland. Undeclared goods are goods which have been imported from outside the customs and fiscal territory of the EU and for which customs duties, taxes or any other charges haven’t yet been paid.

Customs duties or other tax-like charges don’t have to be paid for the goods when they are kept at a temporary storage facility or in a customs warehouse. The temporary storage facility and the customs warehouse are places or spaces were undeclared goods can be kept with an authorisation from Customs awaiting the choice of the final customs procedure and customs clearance. When goods are deposited in a warehouse or at a storage facility, authorisations or licences usually don’t need to be presented to Customs. If the goods are re-exported, no customs duties and taxes need to be paid for them in Finland.

There are no free zones in Finland. In practice, customs warehousing replaces free zones.

If you store goods, for which customs duties but no other taxes, such as excise duties or VAT, have been, you need an authorisation from the Finnish Tax Administration. Excise goods imported from within the EU can be also stored in a tax warehouse free of excise duty.

Temporary storage facilities are intended to be used e.g. by port or airport operators, terminal operators and importers as storage facilities where undeclared goods can be unloaded and stored for a short period.

Customs warehouses are intended e.g. for forwarding agencies or importers who need to store goods for a longer period of time or who handle the goods in some way, e.g. sort and repack them.

For operators, the most significant differences are the storage period, the declarations and notifications submitted for the goods and what can be done to the goods during storage.

Key similarities between temporary storage and customs warehousing

  • Both require an authorisation from Customs as well as a guarantee that covers any customs and tax debt incurred.
  • In both cases, goods can only be stored at the facilities or address indicated in the authorisation and a declaration or notification must be submitted to Customs for incoming and outgoing goods.
  • Neither of them requires, with a few exceptions, any authorisations or licences when the goods are received.
  • In both cases, EU goods can also be stored with an authorisation from Customs.
  • In both cases, storage/warehouse records must be kept of the stored goods in order to have a continuous trail of storage/warehouse transactions.
  • In both cases, the movement of outsiders at the storage facility/in the warehouse is restricted and it must be possible to prevent access to the storage facility/in the warehouse.
  • The storage operator / warehouse keeper is responsible for the goods for the duration of the storage.

Key differences between temporary storage and customs warehousing

  • In temporary storage, the goods can be stored no more than 90 from the presentation of the goods to Customs, whereas in the customs warehousing procedure, there usually isn’t any time limit.
  • Temporary storage is an “intermediate phase” before the goods are placed under a customs procedure, whereas customs warehousing is a customs procedure.
  • Goods cannot be handled at a temporary storage facility. In a customs warehouse, there are better possibilities to handle goods.

In temporary storage, there is an authorisation holder, and in customs warehousing, there is an authorisation holder and a holder of the procedure

In temporary storage and in customs warehousing, the authorisation holder is the company to which Customs has granted a comprehensive guarantee authorisation and a warehouse authorisation.

In customs warehousing, the holder of the procedure is the party that submits the customs declarations for goods to be placed under the customs warehousing procedure. The holder of the procedure is always responsible for submitting the customs declaration and for the data content of the declaration. In the case of a public customs warehouse type II, the responsibility may extend e.g. to the warehouse records.

Public or private customs warehouse?

Customs warehouses can be public or private. If you own the goods or handle the whole warehousing process, the records and the warehousing-related customs declaration yourself, a private customs warehouse could be a suitable alternative for you. If you only offer facilities for goods to be stored, a public customs warehouse could be more suitable for your activities.

A public customs warehouse is intended for storing goods belonging to any person. The customs declaration can be submitted by the authorisation holder or by any person having the required information for submitting the customs declaration. In a public customs warehouse, there can be several holders of the procedure.

There are two types of public customs warehouses, type I and type II. The difference between these two is the division of responsibility between the operators. 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 the case of public customs warehouses type II, the responsibilities of the holder of the procedure are more extensive.

The costs associated with storing undeclared goods are different from the costs of other storage.

  • If you apply for a warehouse authorisation, Customs will require that you lodge a guarantee. The amount of the guarantee is calculated according to the amount of taxes possibly levied on the stored goods.
  • Customs usually charges for a visit to the storage facility/warehouse, if the storage operator/warehouse keeper asks Customs to come to the storage facility/warehouse e.g. to inspect goods or take samples.
  • Every now and then, Customs’ inspections reveal errors and shortcomings that may result in a penalty fee or subsequent recovery of taxes.
  • The storage operator/warehouse keeper also pays the storage/warehouse maintenance costs. These costs are generated e.g. for system maintenance and updates in accordance with Customs’ requirements as well as keeping the records and related documents up-to-date.

A. Choose your approach: will you buy the service or will you store the goods yourself?

  • If you wish to store undeclared goods at a storage facility/in a warehouse used by your company, you will need an authorisation from Customs. One of the conditions for this is that your company is established in the territory of the EU and that it has facilities appropriate for storing goods as well as reliable records.
  • Obtaining a warehouse authorisation requires a comprehensive guarantee authorisation from Customs. Find out how much taxes should be paid on the goods. The amount of taxes is often around 30% of the value of the goods. Be prepared to lodge a guarantee for that amount to Customs. More information about the comprehensive guarantee authorisation
  • Storage service can also be bought. Many freight carriers, traders in port and airport cargo areas as well as forwarding agencies are authorised to store undeclared goods

  • The choice of warehousing/storage type determines what can be done to the stored goods and your responsibilities as the storage operator/warehouse keeper.
    • You don’t need to own the undeclared goods stored in your facilities. If the warehouse authorisation is in the name of your company, however, you are usually responsible for the goods during storage.
  • The choice of warehousing/storage type depends e.g. on the length of storage and on whether the goods need to be handled during storage. The choice may also depend on whether the goods are going to stay on the Finnish market. The warehousing/storage type also determines the responsibilities of warehouse keeper/storage operator, that is, the authorisation holder.
    • Temporary storage can be suitable e.g. if the goods are stored for less than 90 days at the place of entry and they don’t need to be handled in any way. The goods are, for example, declared for free circulation within the time limit for temporary storage or Finland is only a transit country for the goods.
    • Customs warehousing can be a suitable alternative if you need to store the goods for a longer period of time, if the goods are exported from the EU via Finland or if the goods have to be handled in some way. Examples of usual forms of handling permitted in a customs warehouse are sorting and repacking, affixing price tags or other similar signs as well as addition and replacement of components.
  • The legislation specifies how long goods may be stored at a temporary storage facility or in a customs warehouse.
    • Goods can be stored at a temporary storage facility for no more than 90 days. The storage operator can also determine a shorter storage period for their customers.
    • The storage period of goods placed under the customs warehousing procedure is usually not restricted.

B. What to check before storing the goods

  • Storing undeclared goods requires an authorisation from Customs. Undeclared goods are goods which have been imported from outside the customs and fiscal territory of the EU and for which customs duties, taxes or any other charges haven’t been paid.
  • Goods not declared into the EU can also be delivered to Finland from within the territory of the EU. An example of such a situation is where goods are sent to Finland from another EU country under the transit procedure.

  • For example, there are restrictions on storage of waste, medicines, weapons and defence materiel that may also affect the activities of the warehouse keeper/storage operator.
  • There is a specific national administrative or licensing authority for the different restrictions (such as Fimea, the Finnish Medicines Agency, for medicines). Customs restrictions manual (available in Finnish) features the most important export, import and transit restrictions that Customs supervises.

  • Provide the commercial or technical description of the goods in the warehousing/storage declarations. The commodity code cannot replace the goods description.
  • The commodity code determines, among other things, the restrictions on the goods. That’s why it is important to use the correct commodity code.
  • The commodity codes can be found in the Fintaric service. If you need help, you can also contact Customs.

C. Submit a declaration to Customs for the goods to be stored

  • If you buy the storage service from another company, the service provider must have the required authorisations. If the service also includes submission of declarations, the buyer of the service usually only needs an EORI number.
  • If you submit warehousing/storage declarations to Customs via Customs’ online service, you must submit them as an identified user. In some situations, you may need mandates.
  • You need an EORI number for submitting declarations. If your company doesn’t have an EORI number, obtain it from Customs in good time. Read more about the EORI number
  • If you want to submit declarations directly from your company’s system as message declarations, you should apply for the authorisation for message exchange. Read more about message exchange.

All undeclared goods received at the storage facility/warehouse must be declared to Customs. The declaration procedure on whether the goods are declared for temporary storage or customs warehousing.

  • The declarations used for temporary storage are transit declarations or entry declarations or temporary storage declarations. These declarations are to be submitted by the freight carrier, not by the holder of the temporary storage authorisation. The storage operator must compare the received goods with the above-mentioned declarations and report any discrepancies to Customs.
  • A customs warehousing declaration must be submitted for goods to be placed under the customs warehousing procedure. You can submit the customs warehousing declaration yourself or use a representative.
  • The declarations are submitted electronically via Customs’ online service or via message exhange. You can find the guidance on submitting declarations in the online services or in the message implementing guidelines.

  • The goods can only be removed from the storage facility/warehouse against a customs declaration accepted by Customs. If you are a storage operator/warehouse keeper, remember that you must also make sure that the goods remain under customs supervision. You are responsible for keeping the goods at the storage facility/in the warehouse and for the storage/warehouse records.
  • Undeclared goods in temporary storage must be placed under a customs procedure or re-exported within 90 days. The holder of the temporary storage authorisation is responsible for ensuring that there are no goods at the temporary storage facility that were presented more than 90 days ago.
  • Customs carries out controls of warehouse/storage operations and records. If goods are lost during warehousing/storage, the warehouse keeper/storage operator is responsible for the customs duties and taxes.

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D. What if something needs to be amended or the transport is cancelled?

  • Customs must be notified if discrepancies in the quantity or quality of goods arriving at the warehouse/storage facility are detected when counting the unloaded goods compared to the customs declaration. The actual quantity that arrived is always entered in the records.
    • If the goods arrive at a temporary storage facility, any discrepancies are indicated in the unloading report.
    • If the goods arrive at a customs warehouse under the transit procedure and no customs warehousing declaration has yet been submitted for them, any discrepancies are indicated in the unloading report for transit.
    • If a customs warehousing declaration has been submitted for the goods, the declaration can be can be amended before Customs releases the goods for the customs warehousing procedure. If Customs has already released the goods for the procedure, the customs declaration must be amended after release.
  • The customs declaration submitted for the goods must match the good released from the warehouse/storage facility also when goods are removed from the warehouse/storage facility.
    • The customs declaration that ends the warehousing/storage can be amended until Customs releases the goods for a customs procedure.

  • If the goods remain in the warehouse/at the storage facility e.g. because the transport of the goods is cancelled for some reason, the customs declaration must be invalidated.
  • If goods in temporary storage have been placed under the transit procedure and the transport is interrupted, the transit procedure can be discharged to the same storage facility and the goods can be entered in the records as new goods. A new customs declaration must be submitted for goods returned to a customs warehouse.

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