Goods that arrive in the EU from outside it normally pay import duty and import VAT the moment they are released for free circulation. If those goods are only passing through — bought in one part of the world, held in Europe, then sold on to a buyer outside the EU — paying those charges up front ties up cash for no reason. Customs warehousing exists to solve that. Non-EU goods can be stored under customs supervision with duty and VAT suspended, and if they leave the EU again, those charges are never paid at all.
General guidance, not legal or tax advice. Customs procedures depend on the goods, their origin, the authorisation held by the warehouse and national practice, and the rules change. Confirm how they apply to your shipment with a licensed customs agent or the customs authority before you rely on them.
Under the Union Customs Code, customs warehousing is one of the EU’s “special procedures” (it falls under storage, alongside free zones). It allows non-Union goods — goods that have not been released for free circulation in the EU — to be kept in premises approved by customs without import duty, import VAT or other import charges becoming payable while they are there. The goods stay under customs control until the procedure is ended.
The warehouse itself has to be authorised. In broad terms there are two kinds:
A customs warehouse is not the same as an excise (tax) warehouse. Excise warehouses suspend excise duty on alcohol, tobacco and energy products, whether those goods are EU or non-EU. Beer or spirits can need both arrangements. Our guide to excise duty suspension explains the excise side.
| Question | Released for free circulation on arrival | Placed in a customs warehouse |
|---|---|---|
| When are import duty and VAT paid? | At release, before the goods can be sold. | Only if and when the goods are later released for free circulation. |
| Goods re-exported outside the EU | Duty already paid; a refund, if available at all, needs a separate application. | No import duty or import VAT due on the re-exported goods. |
| Selling in small lots to different markets | All charges paid on the whole consignment at once. | Charges arise only on the part released into the EU; the rest can leave. |
| EU trade policy measures | Apply at release. | Generally apply when the goods are released, not while they are stored. |
For a wholesale buyer the gain is mainly cash flow and flexibility: stock can wait close to European ports and road routes while the final buyer, destination or price is settled, and each part of the consignment is only charged according to where it finally goes.
The Union Customs Code sets no general time limit for customs warehousing, although customs can set a deadline in particular cases, and the warehouse operator will charge storage for every week the goods stay. Shelf life is usually the real limit for food and drinks — see our guide to best-before dates and remaining shelf life.
While the goods are stored, only usual forms of handling are allowed: operations that preserve them, improve their appearance or marketable quality, or prepare them for distribution or resale. Typical examples are sorting, repacking, splitting consignments, palletising and labelling. Anything that turns them into a different product is processing, which needs a different procedure. Some forms of handling need prior approval, so agree what you need with the warehouse keeper before the goods arrive.
Goods leave customs warehousing in one of a few ways:
The Incoterm in the sale contract decides who arranges and pays for each of those steps. Our guide to Incoterms for FMCG buyers covers the options.
The procedure is for non-Union goods. Products made in the EU, or goods already released for free circulation, are EU goods: they move freely inside the EU and, when they are exported, VAT is handled through the zero-rating rules explained in our guide to VAT on exports from Poland, not through a customs warehouse. For short-term holding at a port, temporary storage may be enough; for goods that will be worked on, inward processing may suit better. A customs agent can say which procedure fits your flow.
If you are planning a re-export flow, tell us the products, where they will come from, where they are going and the Incoterm you have in mind. We will tell you what we can supply and on what terms, and confirm it in writing. Payment for orders is by telegraphic transfer in EUR or USD, with a deposit and the balance paid before release.
Related reading: EU export documents checklist, excise duty suspension for beer and spirits, and VAT on exports from Poland.
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