Does my warehouse need HMRC fulfilment approval?
Not every stock arrangement needs HMRC fulfilment approval. Storing goods you own is excluded; storing imported goods for an overseas seller can require approval when the scheme’s conditions apply. Check the owner, seller’s establishment and sale history before booking storage. Discuss your sourcing and stock handover with Cambridge China Bridge.
Start with the stock arrangement
HMRC’s Fulfilment House Due Diligence Scheme applies to the storage business. Its guidance requires an application where stored goods were imported from outside the UK, are owned by or stored on behalf of someone established outside the UK, and are offered for sale without having been sold in the UK before. Check these conditions together.
Write down who owns the goods during storage, whose behalf they are held on, where that business is established and whether a UK sale has already happened. Our guide to importing without a warehouse covers premises and delivery choices; this guide addresses the separate fulfilment approval question.
Separate your own goods from another seller’s stock
HMRC tells businesses that own the stored goods not to apply for this scheme. If you buy and own stock, then store it yourself, that ownership exclusion is relevant. If a separate warehouse stores your goods, assess the warehouse’s position against the scheme’s conditions.
For consignment stock or goods awaiting purchase, ask when ownership passes and compare the agreement with the stock records. Do not assume paying freight or receiving cartons establishes ownership. Use our guide to ownership and transit risk to prepare the handover discussion.
Check where the seller is established
HMRC directs businesses to consider where central administration takes place, including essential management decisions, the registered office and management meetings. It also recognises a UK establishment where there is a permanent physical presence with the human and technical resources to make or receive taxable supplies.
Ask the seller for information about its actual management and operating presence. Where the arrangement is unclear, send HMRC a written description rather than relying on an address printed on an invoice. HMRC also states that storage in Northern Ireland solely for sellers established in the EU and Great Britain does not require an application.
Check approval before committing to storage
For an arrangement within the scheme, ask the storage operator for its approved business name and check HMRC’s registered businesses list. HMRC says an in-scope business must apply before trading and cannot trade as a fulfilment business until approval has been granted.
Ask which business will actually hold the stock, especially where your contracting provider uses another operator. Compare its name with the approval evidence and clarify any mismatch before dispatch. Our guide to choosing a UK warehouse helps with the wider storage brief.
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Review changes before the next stock movement
HMRC says an application is also needed where relevant goods are released into free circulation after storage under a customs regime. Flag that release when discussing the arrangement rather than assuming the initial storage position remains unchanged.
Keep an arrangement note with the purchase agreement, ownership handover, seller details, sale history and storage operator. Recheck it when those facts change. Cambridge China Bridge’s staff in China can help coordinate factory documents and shipment handover information for your UK storage discussion.
Frequently asked questions
Do I need HMRC approval to store stock I own?
HMRC tells businesses that own the stored goods not to apply for this scheme. If a separate warehouse stores them, assess that operator’s arrangement separately.
Can I store goods for a Chinese seller?
Check whether the goods were imported from outside the UK, are owned by or held for someone established outside the UK, and are offered for sale without a previous UK sale. Together, these conditions trigger an application.
How do I check a fulfilment house is approved?
Ask for the approved business name and check HMRC’s registered businesses list. Clarify who actually stores the goods if your provider uses another operator.
Can a warehouse start while approval is pending?
An in-scope business cannot trade as a fulfilment business until HMRC has granted approval. An application alone is insufficient.