Tax and SARS knowledge base
When can an importer use customs warehousing?
When can an importer use a customs warehouse rather than enter goods for home consumption?
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Direct answer
An importer can consider warehousing where the goods are to be held under Customs control pending payment of duty or re-export, rather than being entered directly for home consumption. SARS lists warehousing as one of the import processes, alongside home consumption, transit and temporary admission. It is not a duty exemption and it is not permission to store goods in an ordinary commercial warehouse.
The correct route depends on the goods, the licensed facility, the declaration, permits, intended outcome and current Customs conditions. Use the route only after the importer and its adviser have confirmed the appropriate procedure.
What this means in practice
Home consumption and warehousing have different legal and operational purposes. SARS explains that home consumption places goods into free circulation after applicable import duties and taxes are paid and formalities are completed. Warehousing keeps the goods under a Customs procedure pending another event such as later home-use entry or re-export.
SARS also confirms that Customs storage warehouses are licensed under section 19 of the Customs and Excise Act for storage of dutiable imported goods. The licence forms and conditions differ by warehouse type. The importer cannot assume that a logistics provider's normal storage facility is licensed, or that a storage agreement shifts the importer's evidence and declaration responsibilities.
Customs warehousing requires strong stock control. The business should be able to trace every unit from arrival to entry, warehouse receipt, movement, release and final procedure. A missing stock reconciliation may create more risk than the cash-flow benefit of deferring the point at which duty is settled.
Step-by-step
- Identify the commercial objective.
Ask why the goods should not be entered for home consumption immediately. Examples can include awaiting a customer, deciding whether to re-export, holding stock pending a permitted procedure or managing a legitimate timing issue. Record the purpose and do not use warehousing simply because the landed-cost calculation is incomplete.
- Compare the Customs routes.
SARS lists home consumption, warehousing, transit and temporary admission as separate import processes. Confirm which one fits the goods and transaction. Consider whether a permit, preferential origin proof, valuation review or classification issue needs to be resolved before a final home-use entry.
- Confirm the warehouse status.
Obtain written evidence that the intended facility has the appropriate current Customs warehouse licence and that it can accept the particular goods. Review the warehouse agreement, stock-reporting process, access controls and responsible persons. Identify who will make the Customs declarations and reconcile records.
- Prepare the import and warehouse declaration file.
Retain purchase contracts, invoices, packing lists, transport documents, permits, tariff information, value support and broker instructions. Ensure that the declaration identifies the correct procedure and warehouse. Use the current SARS goods-declaration requirements and seek advice where the goods have special restrictions.
- Reconcile stock under Customs control.
Reconcile each receipt, movement, loss, adjustment, transfer and release to the warehouse statement and Customs file. Investigate a discrepancy immediately. Do not record a warehouse adjustment only in the accounting system and assume it has corrected the Customs position.
- Control the exit route.
Before goods leave the warehouse, confirm the next authorised procedure, documentation, duty and tax treatment. SARS's policy notes that clearance into a Customs storage warehouse is not entry for home use. Final entry and release obligations therefore still need to be addressed.
Documents and records to keep
Keep supplier contracts, commercial invoices, packing lists, transport documents, permits, tariff and valuation support, entry declarations, warehouse receipts, stock reports, movement documents, release records, duty assessments, payment proof and correspondence. Retain proof of the warehouse's appropriate status and the agreement allocating operational duties.
Important limits and exceptions
This guide does not authorise warehousing, identify a warehouse type, promise a storage period or calculate duty. Warehousing does not extinguish duty, VAT, permit, valuation or classification obligations. It also does not cure a late or incomplete declaration.
SARS records time limits for due entry after goods land. If goods are not declared on time, they may be removed and detained in a State Warehouse. That is different from a planned private Customs warehousing arrangement and should not be treated as a commercial solution.
When to get tailored advice
Get Customs advice before using warehousing for high-value goods, restricted products, alcohol, tobacco, related-party imports, goods with uncertain valuation, goods intended for re-export or a new warehouse arrangement. Seek urgent help if goods are detained, a declaration is late, the warehouse stock does not reconcile or release has been refused.
TaxProof can help create the documentary checklist and stock-reconciliation process. We cannot select a Customs procedure or approve a warehouse arrangement.