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# UK Customs Special Procedures: Inward Processing, Customs Warehousing, and Temporary Admission

HMRC's customs special procedures allow electronics importers to suspend duty and import VAT on goods being processed, stored, or temporarily admitted — providing significant cash flow advantages and enabling competitive pricing for re-export. Each procedure carries strict authorisation requirements, record-keeping obligations, and discharge deadlines that must be managed rigorously to avoid creating unintended customs debts.

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At a glance

Procedure types

IP, CW, OP, TA

IP discharge method

Bill of discharge to HMRC

CW storage limit

5 years maximum

Authorising body

HMRC (CDS / CCG portal)

## Customs special procedure types and how they work

### Inward Processing (IP) — Duty Suspension for Re-export

Inward Processing allows goods to be imported into the UK with customs duties and import VAT suspended, provided those goods are processed or incorporated into finished products that are then re-exported from the UK. Electronics manufacturers importing components for assembly and export are the paradigm case. The procedure is governed by the Customs (Special Procedures and Outward Processing) (EU Exit) Regulations 2018 (SI 2018/1249). The holder must close the procedure by submitting a bill of discharge to HMRC accounting for all goods entered and the disposition of each.

### Customs Warehousing (CW) — Duty and VAT Deferral in Storage

Customs Warehousing allows imported goods to be stored in an HMRC-authorised warehouse with duty and import VAT suspended indefinitely — subject to a maximum storage period of five years. Goods can be released to free circulation (duty paid), re-exported, or transferred to another customs procedure directly from the warehouse. HMRC authorises several warehouse types: Type I and Type II are public warehouses; Types E, R, and U are private warehouses operated by and for the authorisation holder. Electronics importers managing large stockholding operations frequently use Type E private warehousing.

### Outward Processing (OP) — UK Goods Sent Abroad for Processing

Outward Processing is the reverse of inward processing. UK goods are temporarily exported for processing, repair, or manufacture abroad, and the processed goods are returned to the UK. On return, duty is charged only on the value added overseas — not on the full value of the returned goods. This is commercially significant for electronics businesses that send circuit boards or sub-assemblies to lower-cost manufacturing jurisdictions for processing before returning finished goods to the UK market.

### Temporary Admission (TA) — Short-Term Import Without Duty

Temporary Admission permits goods to be brought into the UK temporarily — for trade shows, demonstrations, testing, or professional equipment — without payment of import duties, provided the goods are re-exported within the authorised period. The ATA Carnet is the principal international instrument for temporary admission across contracting countries and is administered in the UK by the London Chamber of Commerce and Industry (LCCI). For electronics companies attending international trade events or sending equipment for on-site trials, the ATA Carnet is by far the most practical mechanism.

### The Customs Procedure Code (CPC) System

Every customs declaration must carry a Customs Procedure Code — a seven-digit code identifying the customs procedure under which goods are being placed and the procedure from which they are being removed. Correct CPC selection is foundational: an incorrect CPC can result in duty being collected when it should be suspended, or in the customs system failing to link incoming and outgoing movements for bill of discharge purposes. HMRC publishes the current CPC list in its import and export procedure guidance; the Customs Declaration Service (CDS) — the successor to CHIEF — uses the same CPC framework.

### Customs Comprehensive Guarantee (CCG) — Covering the Duty Debt

When goods are placed under a suspensive procedure, a potential customs debt exists (the duty that would have been payable had goods entered free circulation). HMRC requires the authorisation holder to maintain a Customs Comprehensive Guarantee covering this potential debt. The CCG can be provided by a bank guarantee or insurance bond. HMRC may grant a full or partial guarantee waiver — available to businesses with a clean compliance record and demonstrable financial capacity — reducing the cash cost of the guarantee instrument.

## Obtaining and managing a customs special procedure authorisation

01

Identify the commercial scenario driving the import: goods for processing and re-export (Inward Processing), goods for storage pending duty-paid release (Customs Warehousing), UK goods sent abroad for processing (Outward Processing), or equipment for temporary use (Temporary Admission or ATA Carnet).

02

Apply to HMRC for the relevant authorisation — most special procedure authorisations are applied for online via HMRC's Customs Comprehensive Guarantee portal. For Inward Processing and Customs Warehousing, submit form C&E 1179 data via the online system. Ensure economic operator registration (EORI number) is in place.

03

Obtain or arrange a Customs Comprehensive Guarantee or CCG waiver. Work with your customs agent or a surety provider to source a bank guarantee or insurance bond covering the maximum potential customs debt under the procedure.

04

Ensure your customs agent uses the correct Customs Procedure Code on all import and export declarations linked to the procedure. Establish a spreadsheet or system tracking each consignment by procedure reference, quantity, and expected discharge date.

05

Maintain full records of all goods entering the procedure, all processing or storage activities, and all goods exiting or being discharged from the procedure. HMRC may conduct an audit at any time; records must be available for at least four years.

06

Discharge the procedure on time: submit the bill of discharge to HMRC within 30 days of the end of each period (for Inward Processing) or account for goods in Customs Warehousing before the five-year maximum storage limit. Late or non-discharge triggers a customs debt on all unaccounted goods.

07

Respond promptly to HMRC compliance visits or enquiries. HMRC's Customs Special Procedures team may review your records, test your bill of discharge calculations, and assess whether the authorisation conditions are being met. Proactive compliance reduces the risk of authorisation suspension.

## Frequently asked questions

### What is the difference between inward processing and a customs warehouse?

Inward Processing is specifically designed for goods that will be processed, transformed, or incorporated into products that are then re-exported. The duty suspension is conditional on re-export after processing — if goods enter free circulation instead, full duty becomes payable. Customs Warehousing, by contrast, involves no processing: goods are simply stored in their imported state with duty suspended. They can subsequently be released to free circulation (paying duty at that point), re-exported, or transferred to another procedure. The key distinction is the business purpose: IP is for manufacturing and assembly operations; CW is for stockholding and distribution operations where the import duty payment decision is deferred.

### How do I apply for an inward processing authorisation from HMRC?

Applications for Inward Processing authorisation are made online via the UK Trader Support Service or directly through HMRC's Customs Comprehensive Guarantee online system. You will need your EORI number, details of the goods and commodity codes, the processing operations to be undertaken, the expected ratio of finished products to input materials (the bill of quantities), an estimate of the customs duty at risk (used to size the CCG), and details of your record-keeping system. HMRC typically takes 30 calendar days to process a straightforward application, though complex cases take longer. Once authorised, keep a copy of the authorisation decision letter — it must be produced on request during an audit.

### Can I use an ATA Carnet for trade show equipment brought into the UK?

Yes. The United Kingdom is a contracting party to the Istanbul Convention on Temporary Admission, and ATA Carnets are accepted by HMRC for temporary importation of professional equipment, commercial samples, and goods for exhibition at trade fairs and shows. In the UK, ATA Carnets are issued by the London Chamber of Commerce and Industry (LCCI). The Carnet covers the goods for a period specified at issuance — typically up to one year — and the goods must be re-exported before expiry. HMRC border force stamps each counterfoil on entry and exit. There is no duty payment and no need for a separate HMRC customs special procedures authorisation.

### What happens if I fail to discharge an inward processing procedure on time?

Failure to discharge an Inward Processing procedure — by submitting a bill of discharge accounting for all goods entered — within the required period creates an immediate customs debt. HMRC will assess import duty on all goods that cannot be accounted for as either re-exported finished products or as waste and scrap within permitted yield tolerances. Interest accrues on unpaid customs debt. Persistent failures to manage IP procedures correctly are grounds for HMRC to suspend or revoke the authorisation, which would require all subsequent imports to pay duty at the point of entry. A clean compliance record is also a prerequisite for CCG waiver applications.

**Disclaimer:** Educational resource only. UK regulatory requirements change. Consult a qualified UK solicitor or compliance specialist before making decisions.

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