HMAG30030 - Registration and approval: warehouse premises approval
Source: gov.uk (2025-03-17)


Before an excise warehouse can be allowed to operate the premises must first be approved. There are two types of excise warehouse premises approvals. These are general storage and distribution warehouses and trade facility warehouses. Both types are approved under the Customs and Excise management Act (CEMA) 1979 Section 92, which provides us with the discretion to:

approve, for such periods and subject to such conditions as they think fit, places of security for the deposit, keeping and securing—(a) of imported goods chargeable as such with excise duty (whether or not also chargeable with customs duty) without payment of the excise duty,(b) of goods for exportation or for use as stores, being goods not eligible for home use,(c) of goods manufactured or produced in the United Kingdom [or the Isle of Man] and permitted by or under the customs and excise Acts to be warehoused without payment of any duty of excise chargeable thereon,(d) of goods imported into or manufactured or produced in the United Kingdom [or the Isle of Man] and permitted by or under the customs and excise Acts to be warehoused on drawback,subject to and in accordance with warehousing regulations; and any place of security so approved is referred to in this Act as an excise warehouse

General storage and distribution warehouses enable an authorised warehouse-keeper to hold their own excise goods, or third-party excise goods under duty suspension arrangements indefinitely. Approval is only granted where the occupier can demonstrate a real economic need to store goods under excise duty suspension arrangements at the premises. To do this the occupier must show they will have enough clients or business to run the warehouse as a viable going concern (please refer to Notice 196).

Trade facility warehouse approval is only granted to a business which has a genuine need to hold goods under duty suspension arrangements because the duty suspension chain needs to be maintained. For example, to carry out operations on the goods, such as bottling etc. Examples of trade facility approvals include Aircraft Store Floors and Export Shops (for more information please refer to public notices 197a and 197b). Please note, that in a trade facility warehouse:
- a warehouse-keeper may store their own goods indefinitely,
- goods owned by a third party, may only be stored in the warehouse for a period of 90 days following the completion of the operation they were entered for. If further duty suspension storage time is needed, they must be placed in a general storage and distribution warehouse,
- a trade facility warehouse-keeper cannot receive, hold, or move duty-suspended excise goods outside the terms of their warehouse approval.
Before either approval type is granted it should be established:
- that the premises are suitable for the secure storage of excise goods,
- that health and safety requirements are met,
- sufficient space is available to enable HMRC to carry out checks on goods,
- whether the record-keeping systems / management checks are sufficient to:
- correctly account for and record the goods’ location at any given time,
- identify when duty is due,
- identify the status of goods where co-storage of duty suspended and duty-paid is allowed,
- whether the warehouse has an adequate Information Technology (IT) infrastructure in place to support HM Revenue & Customs system requirements such as the Excise Movement and Control System (EMCS),
- whether a premises financial security should be in place.
Where a premises financial security is required, a guarantee is the only form of security acceptable. This is an agreement between us, the business requiring the guarantee and the financial institution provider. It is only companies approved by us that can act as guarantors, a list of these is held by the financial securities centre. Please refer to notice 196 for further information.

Approval of premises for both a general storage and separate trade need

As both trade need and general storage and distribution warehouses are approved under CEMA s92(1), functions associated with either type normally requiring a separate approval can be carried out under a single approval. The approval document should clearly set the conditions for the two types of warehousing activities. For example, whilst the premises could be approved as a general distribution warehouse it may have designated areas set out in the approval document where we permit the warehouse-keeper to operate an Aircraft stores floor or other type of trade need approval. Each case should be considered on its own merits, with careful consideration given to record, security requirements and risk generally