HMAG30040 - Registration and approval: revenue trader approval under CEMA section 100G (2)
Source: gov.uk (2025-03-17)


The term revenue trader is defined by CEMA section 1(1)(a) as follows:

The holding and movement revenue trader approvals described in the Warehouse keepers and Owners of Warehoused Goods Regulations 1999 (WOWGR) and the Excise Goods (Holding, Movement and Duty Point) Regulations 2010 (HMDP) are approved under the powers contained in CEMA section 100G (2). This section provides us with the discretion to:
- • approve and enter in a register maintained by them for the purpose, any revenue trader who applies for registration under this section and who appears to them to satisfy such requirements for registration as they may think fit to impose.• approve and register a person under this section for such periods and subject to such conditions or restrictions as they may think fit or as they may by or under the regulations prescribe.• at any time for reasonable cause revoke or vary the terms of their approval or registration of any person under this section.
The main conditions and restrictions of approval are published in our public notices 196 and 197. In addition to these, we may impose further bespoke conditions and restrictions on approvals where we can justify a proportionate reason for them. Bespoke conditions must be achievable under the privileges of the approval they are applied to. We cannot impose a condition or restriction on an approval which does not relate to the general privilege of that approval type. Please see the separate conditions section in this guidance.

Although the fit and proper test is discussed further on in this guidance, we should not authorise any person(s) (including a limited company) where we can evidence, to a reasonable balance of probabilities standard, that that person would be unable to fulfil the obligations of approval or posed a significant risk to the revenue. Authorisation should not be granted where risks are identified that could not be mitigated by a condition placed on the approval.

Warehouse keeper and Owner of Warehoused Goods Regulations 1999 (WOWGR) CEMA 100G approvals

The CEMA 100G approval type under WOWGR isthe Authorised warehouse-keeper, set by Regulation 3 WOWGR which, amongst other things, states that we have the discretion to:

The warehouse-keeper Once approved, the excise warehouse-keeper has the following privileges (WOWGR regulation 11 refers). A warehouse-keeper can:
- receive goods liable to excise duty at a warehouse he occupies,
- remove goods liable to excise duty from warehouse either under duty suspension arrangements or on payment of duty, and
- carry out operations on the goods whilst they are in the warehouse under duty suspension arrangements.
An excise warehouse-keeper may hold both their own and third-party goods in their excise warehouse, subject to any conditions of approval that may be in place.

CEMA 100G approvals under the Excise Goods (Holding, Movement and Duty Point) Regulations 2010 (HMDP) that apply in both Great Britain and Northern Ireland

A registered consignor can consign excise goods under excise duty-suspension arrangements on their release to free circulation when all customs duties have been paid or accounted for. A registered consignor can consign non-UK goods imported into Great Britain through a United Kingdom port or airport and non-UK or non-EU goods imported into Northern Ireland. They can only be moved in excise duty-suspension to allowable destinations using the Excise Movement and Control System (EMCS) once the imported goods are released to free circulation. We publish the following guidance for businesses wishing to become registered consignors:

Apply for approval as a registered consignor of excise goods - GOV.UK (https://www.gov.uk/guidance/apply-for-approval-as-a-registered-consignor-of-excise-goods)

The goods can only be moved in excise duty-suspension to allowable destinations when a registered consignor has started the movement, using the Excise Movement and Control System (EMCS), following the release of the goods to free circulation. Registered Consignor approval is set by Regulation 30 HMDP which provides us with the discretion to:

We will only consider a request for registered consignor approval from a person who is based in the UK and is one of the following:
- an import agent who makes import declarations on behalf of an importer, using the Customs Handling of Import and Export Freight (CHIEF) or CDS (Customs Declaration Service) system to declare the goods to free circulation,
- an authorised warehouse keeper for the UK destination warehouse after release from customs control to free circulation,
- a person authorised to despatch goods from Northern Ireland to EU based businesses,
- a person that can demonstrate a business need to consign their own goods under excise duty suspension arrangements following their release from Customs control to free circulation.
The main conditions and requirements are published in our public notice 196.

HMDP CEMA 100G approvals which only apply in Northern Ireland

The categories of CEMA 100G HMDP approval types which apply only in Northern Ireland, are set by a version of HMDP which only applies to Northern Ireland, which provides us with the discretion to

The following authorisations are available only to Northern Ireland traders:
- registered consignees
- temporary registered consignees
- certified consignors
- temporary certified consignors
- certified consignees
- temporary certified consignees
- tax representatives
For more information on duty suspended excise approvals and authorisations read Registration and approval of excise goods held in duty suspension (Excise Notice 196) (https://www.gov.uk/guidance/registration-and-approval-of-excise-goods-held-in-duty-suspension-excise-notice-196). For more information on approvals needed to send or receive released for consumption (excise duty paid) goods read Commercial importers, certified traders and tax representatives — EU trade in duty paid excise goods (Excise Notice 204b) (https://www.gov.uk/government/publications/excise-notice-204b-commercial-importers-and-tax-representatives-eu-trade-in-duty-paid-excise-goods).