Can I sell goods in a UK customs warehouse?
Yes. A wholesale batch can be sold while it remains in customs warehousing without supply VAT; retail sales are excluded from that treatment. Duty and import VAT normally become due on later release to free circulation. Agree the depositor and release arrangements before selling. Discuss the sourcing paperwork with Cambridge China Bridge.
Separate the sale from the release
HMRC says sales of goods while they are in a customs warehouse are not charged supply VAT unless they are retail sales. This guide concerns a wholesale batch remaining under customs warehousing, before release to free circulation.
Before agreeing the sale, ask the warehousekeeper to confirm the batch’s customs status. Describe the transaction as a sale of stock remaining in customs warehousing, and record the batch identity, quantity and location. Avoid a vague promise of goods delivered with all taxes settled.
Name the owner and the depositor separately
The depositor does not have to own the goods, but takes responsibility and liability if duties and import VAT become due. Ask the seller, buyer and warehousekeeper to confirm who will be the depositor after the sale, rather than assuming the buyer automatically takes over.
Agree who instructs the customs broker and funds the later release. For the separate questions of importer identity, representation and VAT recovery evidence, use our importer of record guide.
Get the warehousekeeper’s confirmation
The warehousekeeper must be authorised by HMRC. Customs warehouse stock records must show the current stock under the procedure. Ask for written acknowledgement of the sale and confirmation that the batch remains recorded under customs warehousing.
Send a handover pack identifying the seller, buyer, batch, warehouse location and agreed ownership date. Include the warehouse declaration reference and release contacts. Our customs documents guide covers the underlying shipment paperwork.
Treat release as a separate instruction
A sale agreement is not a collection instruction. For release to free circulation, any Customs Duty due and import VAT normally become payable; qualifying import VAT relief can change that outcome. Goods must not be removed until the clearance confirmation arrives, rather than merely the declaration acceptance.
Before booking collection, ask the broker to confirm the release declaration, importer, tax arrangements and clearance evidence. Our UK customs clearance guide explains the wider process. Ask your accountant to check VAT recovery separately.
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Agree the commercial handover before invoicing
Put responsibility for storage charges, insurance, shortages and delayed collection into the sale agreement. Specify whether the buyer wants continued warehousing or later UK release, and who will authorise that next step.
Have the warehousekeeper, broker and accountant review the proposed invoice wording together. Keep the sale invoice, ownership handover and later customs release evidence together so a future query can be traced to the same batch.
Frequently asked questions
Do I charge VAT on a wholesale sale in a customs warehouse?
HMRC says goods sold while in a customs warehouse are not charged supply VAT unless the sale is retail. Confirm the batch’s customs status and the transaction with your accountant before invoicing.
Does the buyer automatically become the depositor?
Do not assume so. HMRC says the depositor need not own the goods. Ask the warehousekeeper and broker to confirm who holds that role after the sale.
When are duty and import VAT due?
Normally on release from customs warehousing to free circulation. Selling the batch while it remains warehoused is a separate event. Qualifying import VAT relief may apply.
Can the buyer collect as soon as the sale is agreed?
For release to free circulation, wait for the message confirming customs clearance. A declaration acceptance message alone does not permit removal.