Common Storage
Unlike piece goods, bulk products require accounting segregation. This principle is applied in relation to all sorts of disciplines. In relation to customs status this has been a topic of discussion for many years.
The scope
COMMISSION DELEGATED REGULATION (EU) 2015/2446 of 28 July 2015
Article 177
Storage of Union goods together with non-Union goods in a storage facility
(Article 211(1) of the Code)
1. Where Union goods are stored together with non-Union goods in a storage facility for customs warehousing and it is impossible or would only be possible at a disproportionate cost to identify at all times each type of goods (common storage), the authorisation as referred to in Article 211(1)(b) of the Code shall establish that accounting segregation shall be carried out with regard to each type of goods, customs status and, where appropriate, origin of goods.
1. Where Union goods are stored together with non-Union goods in a storage facility for customs warehousing and it is impossible or would only be possible at a disproportionate cost to identify at all times each type of goods (common storage), the authorisation as referred to in Article 211(1)(b) of the Code shall establish that accounting segregation shall be carried out with regard to each type of goods, customs status and, where appropriate, origin of goods.
2. Union goods stored together with non-Union goods in a storage facility as referred to in paragraph 1 shall share the same eight-digit CN code, the same commercial quality and the same technical characteristics.
3. For the purposes of paragraph 2, non-Union goods which would be subject, at the time where they would be going to be stored together with Union goods, to a provisional or definitive anti-dumping duty, a
countervailing duty, a safeguard measure or an additional duty resulting from a suspension of concessions if they were declared for release for free circulation, shall not be considered to have the same commercial quality as the Union goods .
countervailing duty, a safeguard measure or an additional duty resulting from a suspension of concessions if they were declared for release for free circulation, shall not be considered to have the same commercial quality as the Union goods .
4. Paragraph 3 shall not apply where non-Union goods are stored together with Union goods which were previously declared as non-Union goods for release for free circulation and for which the duties
referred to in paragraph 3 have been paid.
referred to in paragraph 3 have been paid.
TAXUD/A2/SPE/2016/001-Rev 23 EN
Original EN
SPECIAL PROCEDURES Title VII UCC/ Guidance for MSs and Trade
Common storage in different tanks connected with each other
An applicant wants to obtain an authorisation for customs warehousing. The application
requests the application of common storage to a group of tanks, which are connected with each
other, commonly referred as a ?tank pit?. The purpose is to store products with different
customs status in the whole ?tank pit?. If the products have different characteristic, then it
would not be common storage.
Customs authorities could only grant this authorisation according to Article 177 UCC-DA if
the purpose is that all the tanks in the ?tank pit? contain exactly the same Union and non-Union
product (i.e. same CN code, same technical characteristics and same commercial quality), then
the authorisation for common storage may be granted.