Customs warehouse records and temporary storage records – who, what, why, how and when?

All received and removed undeclared goods must be entered in the warehouse/storage records. If the goods have been indicated to be unloaded into the warehouse/storage facility, they must be entered in the records even if they were in the warehouse/storage facility only for a short period.

The operator responsible for the records must keep records of all the following goods:

• goods unloaded into the warehouse/storage facility
• goods indicated to be unloaded into the warehouse/storage facility by providing the warehouse ID in the unloading request for transit, in the presentation notification or in the temporary storage declaration
• goods arriving at the warehouse/storage facility without documents and no notification of them has been submitted to Customs. In the warehouse/storage facility it is noticed that the goods are undeclared.

An entry in the records is also required when

• the goods are deposited as discharge of transit, e.g. by an authorised consignee or when a TIR Carnet is discharged by temporary storage
• the goods are not physically unloaded into the indicated warehouse/storage facility; instead, they are, for example, kept in the transport unit or declared without unloading them into the warehouse/storage facility.
• the goods arrive at a temporary storage facility as a movement from another temporary storafe facility.
  • How soon the goods will be transported onward is irrelevant. An entry in the records is required even if the goods had already been declared.
• a customs warehousing declaration has been submitted for the goods and they are moved to a customs warehouse.

Customs must be able to identify the stored goods as well as the quantity and customs status of the goods. If the warehouse authorisation permits Union goods or e.g. goods under the export procedure to be stored in the temporary storage facility or in the customs warehouse, they must be kept separate from undeclared goods. Their customs status must also be entered in the storage/warehouse records. The customs status indicates whether the goods are e.g. undeclared goods, EU goods or export goods. Use codes when you make entries.

You can also either have separate areas in the storage facility/warehouse for these consignments or mark them in such way that they are distinguishable from undeclared consignments. Read more about keeping the goods separate on the page Authorisations and responsibilities of storage operators and warehouse keepers, under “The place used for storing undeclared goods must be clearly separated from the rest of the facilities or areas”.

The records contain the entries and verifications

The warehouse/storage records consist of the transaction entries and of the verifications that the entries are based on. The verifications show what goods have been sent, by what, from where and to where. The verification for undeclared goods in the warehouse/storage records is always a customs document, such as a decision on release.The verification can, for example, be a PDF file generated by Customs’ system or a document stamped by Customs. The person collecting the goods shall present the document. The verification can also be an electronic release notification sent by Customs to the storage operator/warehouse keeper. The customs declarations and other documents that begin and end storage/warehousing are part of the records.

Other clarifying documents with details that are necessary regarding the operation of the company can also be attached to the records.

The audit trail must be continuous

The release documents can be any kinds of verifications, but the storage operator/warehouse keeper is responsible for ensuring that Customs can, based on the details in the removal certificate, connect the goods released from the storage facility/warehouse to the consignment and goods that arrived at the storage facility/warehouse. It must be possible to follow the audit trail from arrival to removal.

Check that the records contain all the required details and that they are accurate. Make sure that the movements of goods e.g. from one customs procedure to another can be tracked using the entries in the records. The audit trail must be continuous and it must be possible to connect the verifications to the warehouse/storage transactions. Make sure that you as a warehouse keeper/storage operator can provide the details to Customs quickly and easily.

The packaging material used in warehouse/storage operation and handling of consignments as well as other equipment needed for transport are not included in the warehouse/storage records.

The goods items in each consignment must be specified in the records. The goods must be entered in the records by goods item and package type, and these details may not change during the warehousing/storage so that the audit trail of the goods breaks.

Enter the goods description in the records according to the common trade name. Just a product code or similar is usually not sufficient as goods description. Some of the details, such as kind of packages, are entered using codes. You can check the required codes in the code list.

The goods must be removed from the warehouse/storage facility using the same measurement units or kinds of packages as on deposit and entry in the records. If the goods arrived at the warehouse/storage facility and were been entered in the records e.g. as a number of cases, they cannot be removed as a number of pieces. And if the goods were entered in the records e.g. as a number of cases and as a number of pieces, they cannot be removed only as a number of cases or pallets. The only exception to this is a declaration submitted in Customs’ Import Declaration Service for private persons, where the person who submits the declaration cannot choose the kind of packages.

If the goods are entered in the records by goods item, one goods item can only contain goods with the same technical or commercial goods description. If the goods are entered by product number, the records must indicate, in addition to the goods description, also the goods item in which the goods had arrived.

The entry concerning the discharge of the procedure must be made in the stock records no later than when the goods are removed from the warehouse/storage facility or from the authorisation holder’s facilities. The warehouse keeper/storage operator must see to that the goods released from the warehouse/storage facility match, in terms of quantity and quality, the details provided in the customs declaration (e.g. transit declaration) that ends warehousing/storage.

To create the records, you can use e.g. an appropriate stock records system or spreadsheet program used by your company. Making entries only in a logistics system is not sufficient. If you use a spreadsheet program, you can ask Customs for a template.

From the records, it must be possible to generate various reports for Customs, showing e.g. stock balances and transactions.

It must be possible to check electronic record electronically. Customs can require that documents stored on a mechanical data device be submitted to Customs in a commonly used storage format. You should save the details in electronic records in a machine-readable file format, such as .xls and ascii.

If the warehouse/storage records and the company’s main accounts for customs purposes are separate, there must be references between them so that the audit trail of entries can be verified.

Enter each detail in a separate field or column

Make the entries in the records in accordance with Customs’ instructions. If you use a stock records system, enter each detail in a separate field. If you use a spreadsheet program, enter each detail in a separate column. Enter e.g. the reference number and date of the document in separate fields/columns and in the same way the details of the arrival and removal of the goods.

What is essential from Customs’ perspective is when the customs declaration was submitted to Customs. If goods removed from the warehouse/storage facility remain waiting for collection and you need to know, e.g. for invoicing, when the goods were collected, enter the collection date in a separate column.

If you use a spreadsheet program, make particularly sure that it easy to connect the deposit entries concerning a goods item to the removal entries. This is important especially if the goods are removed from the warehouse/storage facility in parts. If there are several removals concerning one goods item, enter the details of each removal on separate rows. Note that the deposit details must also be entered on each row. Check that the quantity of deposited goods has only been entered once for the goods item.

The records for a temporary storage facility and a customs warehouse must be kept and the entries must be made in Finnish, Swedish or English. Even if the goods description in the declaration preceding the storage/warehousing (e.g. in the transit declaration) was provided in another language accepted in the country of departure, the entries in the records must be made in one of these three languages.

Keep the records for six years from the end of the year when the storage/warehousing ended and the goods were placed under a customs procedure or re-exported, destroyed or abandoned to the State.Archive the required verifications in a format approved by Customs.

The storage/warehouse records can also be archived electronically. Electronic archiving can also mean archiving a message declaration or a PDF file or scanning a paper document into an electronic format. For example, a release decision notification in xml format for a message declaration does not need to be stored in PDF format, the notification in xml format is sufficient. 

The xml notification must be kept as long as a similar PDF file or paper document. The storage operator/warehouse keeper still has the right to ask the customer for the decision on release on paper or in PDF format before releasing the goods from the storage facility/warehouse. 

The storage operator/warehouse keeper must also be able to convert the electronically archived material into plain-language text that can be inspected and, if necessary, print it out on paper. It must be possible to convert the material without undue delay within the time limit prescribed by Customs. The operator is responsible for the conversion costs.

The declarant has the responsibility to archive documents related to the customs declaration. If you still haven’t archived a customs clearance decision or decision on release, you can request it from Customs afterwards.

Customs will collect a charge for decisions that are sent separately. It is a charge for performance under public law, in this case for extracts from and copies of decisions and other documents. Read more about charges.

Request the decision by email to arkisto@tulli.fi.

Customs keeps decisions on release and customs clearance decisions for six years. The period starts from the end of the calendar year when the decision was made.

The records for a temporary storage facility should contain at least the following details:

1. The date and reference of the declaration that starts temporary storage. The reference number can be one of the following three:
   • MRN of the entry summary declaration and goods item number
     • MRN of the entry summary declaration or temporary storage declaration, goods item number, house level transport document number (e.g. number of the bill of lading or House Airway Bill) and the transport document type (check the code in the code lists, code list CL754 – Transport document type).
     • If the consignment arrived in several split consignments, the MRNs of all received split consignments must be entered in the temporary storage records. Read more about split consignments in air transport on the page Entry declarations, under “Declaring goods arriving by air in split consignments”.
     • movement under temporary storage, receiving storage facility: MRN of the temporary storage declaration after movement (FI377), goods item number and house level transport document number
   • transit MRN
   • other reference number (e.g. transport document number for goods transported across the Åland tax border).
2. Date and reference number of the declaration that ends temporary storage:
   • MRN and goods item number, if any
     • movement under temporary storage, dispatching storage facility: MRN of the temporary storage declaration after movement (FI377), goods item number and house level transport document number
   • other reference number (e.g. reference to a certificate of detention, certificate of destruction or document concerning abandonment to the State)
3. when necessary, dates of customs documents and other documents and their identification data
4. goods description and quantity:
   • package details and any ID numbers, number and type (kinds of packages, check the code in the code lists, code list CL017 – Kind of Packages)
   • goods quantity
   • common commercial or technical description. It cannot be replaced with the commodity code.
   • container ID (when necessary)
5. location of the goods (at least the address of the storage facility)
6. customs status of the goods (Code lists, code list NCL295 – Customs status)
7. details of the forms of handling designed to ensure the preservation of goods in an unaltered state
8. details of any movements of goods under temporary storage.

If needed, enter also the house level transport document type

If the entry declaration is a declaration submitted to the Commission’s ICS2 system for safety and security data or a temporary storage declaration, the identifier of the type of house level transport document reference number must also be provided in it. Enter it in the records either together with the transport document identifier or separately. If you enter the detail in the records e.g. the section or column for additional information, enter the document type before the identifier. Enter N714 as the type for goods that have arrived by sea and N703 for goods that have arrived by air.

Details of movements of goods under temporary storage

If goods are moved under temporary storage, the records of both the dispatching and the receiving storage facility must have details of the movement. Such details are, for example, the MRN of the temporary storage declaration after movement (FI377), details of the house level transport documents as well as goods item numbers.

If goods are moved under temporary storage between storage facilities located in different Member States, an entry of the arrival of the goods at the temporary storage facility at the destination must be made in the records of the dispatching storage facility.

Attach the documents preceding the storage and customs clearance verifications to the temporary storage records

Attach the verifications to the records in electronic or paper format. It must be possible to present electronically archived documents to Customs, when required.

Deposit in the storage facility

Attach the following documents:

• the decision on release for a declaration submitted to Customs’ e-service or the notification “TSD information”.
• the release notification or decision on release or the notification “TSD information” for a declaration submitted via message exchange
• fallback procedure document, e.g. a declaration on a SAD form that starts storage, and attachments, if any
• a copy of the transit accompanying document, if any
• TIR Carnet: copy of voucher (volet) no. 2 of the TIR Carnet with attachments, if any.

Removal from the storage facility

Attach the following documents:

• the decision on release for a customs declaration submitted to Customs’ e-service and attachments, if any
• the release notification or decision on release for a customs declaration submitted via message exchange
• fallback procedure document, for example a customs declaration on a SAD form and attachments, if any.

Please also note the following:

• T1 transit
  • The transit MRN in the records is sufficient. However, Customs recommends that you attach a copy of the accompanying document to the records, along with any specifications of the goods.

• TIR Carnet
  • TIR Carnet: copy of voucher (volet) no. 1 of the TIR Carnet with attachments, if any.
• destruction under customs supervision
  • Attach either the certificate of destruction endorsed by Customs or the decision on release for inward processing.
• Abandonment to the State
  • Attach the document concerning abandonment of goods to the State, endorsed by Customs.
• Detention of goods:
  • Attach the certificate of detention endorsed by Customs.

The records of the customs warehouse must contain at least the details required by law. The authorisation holder can also enter other details they consider important to the records.

The records must contain at least the following details:

1. Reference to the customs declaration used for placing the goods under the customs warehousing procedure
   • electronically submitted declaration: MRN and goods item number
   • standard customs warehousing declaration submitted in the fallback procedure: warehouse deposit number issued by the holder of the authorisation or holder of the procedure, or another similar reference as well as date of placement under the procedure
      
2. Reference to the declaration preceding the customs warehousing declaration, e.g. one of the following:
   • MRN and goods item number, if any
   • other reference number, e.g. warehouse deposit details for procedure no 7171 provided by the dispatching warehouse, when moving goods for which no electronic customs declaration has been submitted or when moving goods between warehouses covered by the same authorisation
      
3. Reference to the customs declaration discharging the warehousing procedure (MRN), or similar details of the document with which the goods have been destroyed or abandoned to the State. The reference can be one of the following:
   • MRN (see point 5)
   • other reference number, e.g. reference to the document concerning abandonment of goods to the State.
      
4. If the goods are not transited after the submission of the re-export declaration, but they are moved under the customs warehousing procedure to the customs office of exit, an entry of the final exit of the goods from the European Union must be made in the records within 100 days of the exit. The records must then contain two separate entries: one of the removal from the warehouse and another of the exit from the EU.
    
5. If needed, data that unequivocally allows the identification of customs documents other than customs declarations, of any other documents relevant to the placing of goods under the procedure and to the discharge of the procedure
   • For example: if customs warehousing has been discharged with re-export and a transit procedure has been started after that, details of the transit must also be entered in the records.
      
6. Details necessary to identify the goods: marks, identifying numbers, number and kind of packages and, where relevant, the identification marks of the container.
7. Goods description: usual commercial or technical description of the goods, which must be sufficiently accurate and precise to enable identification of the goods. It cannot be replaced with the commodity code.
8. Quantity of the goods:
   • gross mass
   • supplementary quantity and unit required by the commodity code
      
9. Location of the goods, at least the address of the warehouse
10. Details of any movements of the goods
11. Customs status of the goods. Where accounting segregation is required, information about type of goods, customs status and, where appropriate, origin of the goods:
    • union goods kept in the customs warehouse facilities
    • common storage of undeclared goods and Union goods, such as bulk goods in the same tank or silo
       
12. Details of usual forms of handling and, where applicable, the new commodity code resulting from the handling
13. Where the records are not part of the main accounts for customs purposes, a reference to the main accounts for customs purposes
14. Additional information for special cases, at the request of the customs authorities for justified reasons.

 

Attach the verifications to the customs warehouse records

It must be possible to present electronically archived documents to Customs, when required. Attach the following documents concerning various measures as verifications to the records in electronic or paper format:

Deposit in the warehouse:

• the decision on release for a customs declaration for customs warehousing submitted to Customs’ e-service and attachments, if any
• the release notification or decision on release for a customs declaration for customs warehousing submitted via message exchange
• the customs declaration that was submitted with a SAD form and that starts customs warehousing and attachments, if any

Removal from the warehouse:

• the decision on release for a customs declaration submitted to Customs’ e-service and attachments, if any
• the release notification or decision on release for a customs declaration submitted via message exchange
• fallback procedure document, for example a customs declaration on a SAD form and attachments, if any.

Please also note the following:

• T1 transit: The transit MRN in the records is sufficient.
• re-export declaration: Provide the decision on release for the procedure and the certification of exit.
• re-export declaration, with a subsequently opened TIR Carnet: Attach the decision on release for the re-export procedure and a copy of the Volet no. 1 of the TIR Carnet with attachments, if any. A certification of exit can also be attached to the records.
• re-export declaration, with a subsequently started T1 transit: Attach the on release for the re-export procedure and the MRN of the T1 transit. The warehouse keeper can also attach the certification of exit to the records.
• destruction under customs supervision: Attach the decision on release for inward processing.
• abandonment to the State: Attach the document concerning abandonment of goods to the State, endorsed by Customs.

Temporary storage

• Union Customs Code (UCC) (EU) No 952/2013, Article 148 (Records shall be kept of a temporary storage facility)
• Commission Delegated Regulation (EU) 2015/2446, Article 116, the data content of temporary storage records
• Regulation 14/2016 of Finnish Customs on keeping records of temporary storage (in Finnish)

Customs warehousing

• Union Customs Code (UCC) (EU) No 952/2013, Article 214 (Records shall be kept of a customs warehouse)
• Commission Delegated Regulation (EU) 2015/2446, Article 178, the data content of the customs warehousing records
• Regulation 3/2019 of Finnish Customs on keeping records in the customs warehousing procedure (in Finnish)