How does Temporary Storage differ from a Customs Warehouse in the UK?

Temporary Storage (TSF) is short-term holding of uncleared goods in premises approved by HMRC at a port or airport — up to 90 days, without a separate importer authorisation, run by the port/terminal operator. A Customs Warehouse (CW) is a long-term special procedure — no time limit in practice (5+ years), requires HMRC authorisation, a financial guarantee and a compliant WMS. You use TSF for unloading and clearance time; CW to defer duty and VAT payment until the goods are actually released onto the UK market. Basis: UCC art. 144-152 (TSF), UCC art. 240-242 (CW), HMRC Notice 199.

How long can goods stay in Temporary Storage in the UK?

A maximum of 90 calendar days from the date the TSD (Temporary Storage Declaration) is lodged. After that, the goods must be cleared (IMA/IMZ), re-exported, destroyed or moved to a special procedure (CW, IP, End-Use). Inaction = HMRC treats the goods as abandoned and will charge duty + VAT + a penalty. In practice at EasyClearance we see the average consignment sit in TSF for 3-14 days — the 90-day cap is a safety margin.

How long does it take to obtain a UK Customs Warehouse authorisation?

HMRC states 60 working days from a complete application; in practice 6-12 weeks, depending on whether the applicant already holds a CCG (Customs Comprehensive Guarantee) and whether the warehouse is new or being re-authorised. Stages: (1) application on gov.uk via CDS, (2) HMRC site visit, (3) WMS and procedure verification, (4) decision. The warehouse keeper must hold a UK EORI, a compliance history and premises suitable for the type of goods.

Can I do anything with the goods while they are in Temporary Storage?

Only a very narrow scope — so-called usual forms of handling: unloading, repacking for transport, protective marking, inspection, sampling for HMRC. You cannot sort, combine into sets, assemble, repair or change the nature of the goods. In a Customs Warehouse, the scope of usual forms of handling is wider (UCC Annex 71-03) and covers, for example, kitting, relabelling for the target market and testing.

Who pays for the goods in TSF vs a Customs Warehouse?

TSF: the terminal operator (port/airport) charges a handling + storage fee — typically £15-£60 per container for a few days, then a daily demurrage rate of £30-£100 after the free days. CW: your own warehouse or a 3PL — a warehousing rate (£0.50-£2 per pallet per day) instead of demurrage, plus a CW management fee (typically £500-£2000/month for a 3PL). Break-even: beyond 14-21 days of port storage, a 3PL CW starts to be cheaper.

Does a Customs Warehouse require a bank guarantee?

Yes — the warehouse keeper must hold a financial guarantee covering potential duty + VAT on the goods held in the CW at any given moment. For compliant importers with an HMRC track record, the guarantee can be reduced by 50-100% (waiver). Forms: bank guarantee, cash deposit, surety bond. In practice most EC clients use a Customs Comprehensive Guarantee (CCG) — a single guarantee covering CW, deferment and IP at the same time. Basis: UCC art. 89-100, HMRC Notice 799.

Can I move goods from TSF to a Customs Warehouse after 89 days?

Yes — it is a standard operation if it turns out you won't make the clearance deadline. You submit a customs declaration CPC 7100 000 (entry into CW) on CDS, physically transport the goods from TSF to CW and lodge an MRN closing the TSF. The condition: you must already have CW authorisation (your own or a 3PL's). You cannot start a CW authorisation application only once the goods have been sitting in TSF for 80 days — 6-12 weeks is too long. A better strategy: re-export or release on a cash account with a later C285 for a refund.

Can alcohol and cigarettes be held in TSF and CW?

Yes — with caveats. Excisable goods (alcohol, tobacco, fuels) additionally require an excise warehouse authorisation (HMRC Notice 197) layered on top of the CW. Not every CW is also an excise warehouse — if you import whisky or wine, make sure the warehouse keeper holds both authorisations. TSF also accepts excise goods, but with a shorter realistic window (typically 30 days, because the HMRC excise team keeps a close eye).

Temporary Storage vs Customs Warehouse UK

Pick TSF (Temporary Storage Facility) when the goods need a short stop of up to 90 days before you clear them — no HMRC authorisation required, because the operator is the port or airport. Pick a Customs Warehouse (CW) when you want to hold goods for longer than 90 days (practical limit: 5+ years), run a regular flow and defer duty and VAT until the goods are actually released onto the UK market. Break-even sits around the 90-day mark for a one-off delivery and around a 6-12 month ROI for a regular flow once CW is set up. Legal basis: UCC art. 144-152 (TSF) and UCC art. 240-242 (CW), UK implementation: gov.uk/guidance/using-temporary-storage, gov.uk/guidance/apply-to-operate-a-customs-warehouse and HMRC Notice 199.

In brief

TSF = the default — after unloading at port/airport the goods land in TSF automatically, no application needed. Max 90 days. The operator is the port.
CW = premium — requires HMRC authorisation (6-12 weeks), a CCG guarantee and a compliant WMS. No hard time limit.
Time break-even: <90 days → TSF. >90 days or uncertain release timing → CW.
Cost break-even: beyond 14-21 days in port, TSF demurrage costs exceed CW warehousing via a 3PL.
Duty and VAT: TSF only defers (until clearance within 90 days). CW defers indefinitely until the goods are actually released to the UK market — a cash flow benefit.
WhatsApp: +44 7404 091 503 — we'll help you choose the right setup for your flow.

This article sits in the "Storage and special procedures" cluster as a decision guide. If you want a detailed walk-through of Temporary Storage itself — structure, TSD, operators — head to the spoke Temporary Storage UK — how TSF works (90 days, operator, TSD). If you're interested in the benefits of a Customs Warehouse — Customs Warehouse UK — benefits, procedures, cash flow. Related: UK Customs Value (Method 1-6), PVA, Cash account vs deferment account.

What makes TSF and Customs Warehouse different in practice

TSF is a "waiting room" at the port. CW is a "controlled warehouse" with deferred customs obligations. Both hold goods in non-Union (non-UK) status, but the philosophy, operator, duration and cash-flow consequences differ.

Temporary Storage (Temporary Storage Facility)

A TSF is premises approved by HMRC where goods may sit for a maximum of 90 calendar days from the time the TSD (Temporary Storage Declaration) is lodged. The TSD is lodged by the terminal operator automatically on unloading — the importer doesn't have to do anything extra. The operators are ports (DP World Southampton/London Gateway, Forth Ports, Peel Ports, PD Ports), airports (Heathrow cargo, Manchester, East Midlands) and private IBFs (Inland Border Facilities — e.g. Sevington, North Weald). Basis: gov.uk/guidance/using-temporary-storage, UCC art. 144-148.

Customs Warehouse

A CW is a special procedure with HMRC authorisation under which goods can be held without a hard time limit. Typical CW agreements run for 5 years with a renewal option. The operator is the warehouse keeper — your own company with its own warehouse or a 3PL (e.g. Wincanton, Kuehne+Nagel, DHL) holding the authorisation. The key difference: duty and import VAT are not paid when the goods enter the CW — they are paid when the goods leave for the UK market (IMA/IMZ) or on re-export (0 duty). Basis: gov.uk/guidance/apply-to-operate-a-customs-warehouse, UCC art. 240-242, Notice 199.

TSF vs CW compared — 10 dimensions

The comparison table is built on an analysis of 40+ EasyClearance client setups over the last 18 months (a mix of one-off deliveries, regular flow, e-commerce and B2B wholesale setups).

Dimension	TSF (Temporary Storage)	CW (Customs Warehouse)
Maximum storage time	90 calendar days (hard limit — UCC art. 149)	No hard limit — typical agreements 5 years, with renewal
HMRC authorisation	Not required from the importer — the terminal operator holds it	Required — application, 6-12 week process
Financial guarantee	No (operator provides its own cover)	Yes — CCG covering duty + VAT on goods in the CW
Who the operator is	Port, airport, IBF (DP World, Forth, Peel, etc.)	Your own company or a 3PL with CW authorisation
Duty and VAT on entry	Deferred (must be paid on clearance within 90 days)	Deferred indefinitely — paid only on release to the UK market
Permitted operations on the goods	Only usual handling (unloading, inspection, sampling)	Wider scope: usual handling + kitting, relabelling, testing (UCC Annex 71-03)
Typical storage cost	£15-£60 handling + £30-£100/day demurrage after free days	£0.50-£2/pallet/day + £500-£2000/month management (3PL)
Setup time	0 days (goods land in TSF automatically)	6-12 weeks (HMRC application + site visit)
Record-keeping	Handled by the operator — the importer just has the MRN reference	Warehouse keeper — WMS integrated with CDS, 4-year retention
When it pays off	Deliveries ≤90 days holding, low volumes, no regular pattern	Regular flow, >90 days holding, re-export, kitting/labelling, cash flow benefit

Decision tree — which setup to pick

Five questions we put to every new EC client before the TSF vs CW decision. The order is not accidental — the first question often closes the case.

Question 1 — How long will the goods remain uncleared?

<90 days → TSF is enough. >90 days → TSF is ruled out by definition, you need CW or another special procedure (IP, End-Use). There is no route to extend TSF beyond 90 days — HMRC treats the goods as abandoned.

Question 2 — One-off delivery or regular flow?

One-off / a few per year → TSF (no ROI on a 6-12 week CW setup). Monthly containers, distribution centre, re-export >20% of volume → CW.

Question 3 — Do you need to work on the goods (kitting, relabelling, testing)?

Yes → CW (TSF bars most operations). No → TSF will do.

Question 4 — Do you want to defer duty and VAT for cash flow?

Yes and volume >£500k/year → CW delivers a real interest-rate ROI (typically 4-6% annualised on working capital). Low volume → TSF + PVA on VAT and a deferment account on duty will be enough.

Question 5 — Are you ready for the CW compliance overhead?

WMS integrated with CDS, monthly stock reconciliation, 4-year retention, HMRC site visits. If not — pick a 3PL with CW instead of going it alone.

Break-even — when CW stops being overkill

In EasyClearance's day-to-day work we see three break-even points at which the recommendation flips from TSF to CW.

Time break-even — 90 days (hard limit)

Beyond 90 days TSF ceases to exist as an option. If you import, say, seasonal clothing from Asia and the sell-through date is uncertain — CW is mandatory. Moving goods from TSF to CW after day 85 is technically possible but risky: you need an active CW authorisation (your own or a 3PL's), physical transport and time to lodge the declaration. See the spoke Temporary Storage UK, section "what happens after 90 days".

Storage cost break-even — 14-21 days of demurrage

Average UK port demurrage: £45 per 40ft container per day after 5-7 free days. At 21 days of TSF, demurrage = 14 × £45 = £630. Warehousing in a 3PL CW for 20 pallets from the same container: 14 × £1.50 × 20 pallets = £420 + £300 fee = £720. For a single container TSF is cheaper by ~£90. But with 6 containers a month and an average of 14 days: TSF cost £3,780, 3PL CW ~£2,520 — CW saves £1,260/month.

Regularity break-even — 6-12 month ROI on setup

CW setup: application, site visit, WMS integration, CCG — typically £3,000-£8,000 one-off for a 3PL or £15,000-£40,000 for your own warehouse. With the savings of £1,000-£3,000/month described above, ROI is 6-12 months. For a regular flow the decision is obvious; for ad hoc imports — stick with TSF.

EC case study — from TSF to CW in 8 months

Client: a furniture importer from Vietnam, 12 containers a year. For the first 18 months they ran TSF + Felixstowe demurrage — averaging 18 days/container × £45 = £810/container × 12 = £9,720/year in demurrage alone. The EasyClearance team proposed a setup through a 3PL with CW authorisation: £4,500 one-off, £900/month management, warehousing at £0.80/pallet/day. One year after the switch: storage cost £6,200 (a saving of £3,520) and a cash flow benefit from deferred duty and VAT of £48k × 5.2% = £2,500. Total benefit: £6,020/year. ROI: 9 months.

When to go firmly TSF, and when firmly CW

You pick TSF if:

One-off delivery or fewer than 6 containers a year — CW setup has no ROI.
Clearance within 7-30 days of arrival (the standard happy path).
No work on the goods — you pick them up, clear them, drive to your own warehouse.
E-commerce fulfilment after a fast clearance — the goods head to a 3PL fulfilment partner (e.g. Amazon FBA) without being held in non-UK status.
Baggage and small-vehicle imports — goods in a small car do not need a CW.

You pick CW if:

Regular flow of >10 containers/year with holding over 14 days.
Re-export of >20% of volume — CW lets you export without paying duty (a saving of, say, 12% on clothing re-exported to the EU).
Seasonality — goods must wait for the season (clothing, seasonal items) for longer than 90 days.
Kitting/relabelling/testing — building UK-market sets, testing compatibility, relabelling packaging (especially common for Amazon FBA from Chinese supply).
Cash flow critical — volume >£500k/year, tight working capital.
Excise goods (alcohol, tobacco) — CW + excise warehouse (Notice 197) is the industry standard.

How to set up each option — step by step

TSF — zero setup, standard flow

The freight forwarder submits an ENS before arrival (0-2h pre-arrival depending on mode).
On unloading, the terminal operator lodges the TSD on CDS — automatically.
You get the TSF MRN and the 90-day clock starts.
Within 90 days: the customs agent (EC) lodges IMA/IMZ — release from TSF into free circulation.
On release you pay duty + VAT (or use a deferment + PVA) and the goods leave the port.

CW — 6-12 week setup, then flow

Application on gov.uk: form, warehouse plan, procedures, WMS spec. Basis: gov.uk/guidance/apply-to-operate-a-customs-warehouse.
CCG — bank guarantee or cash deposit (Notice 799).
HMRC site visit — inspection of premises, procedures and systems.
Authorisation decision — you receive a CW number (CW1234) and can start the flow.
Flow: on each import lodge CPC 7100 000 on CDS (entry into CW), stock-in on the WMS, monthly reconciliation.
Exit: CPC 4071 000 (release for free circulation) or CPC 3171 000 (re-export), depending on the destination.

Frequently asked questions

Can I use TSF for sensitive goods (e.g. excise)?

Yes, TSF accepts every type of goods, but excise goods have additional HMRC Excise control requirements and in practice the real window is shorter than 90 days (often 30 days). For long excise holding, pick CW + excise warehouse (Notice 197).

What happens if I go over the 90-day TSF limit?

HMRC treats the goods as abandoned — it charges duty + VAT + a penalty, and the goods can be seized by HMRC for destruction or public sale. In practice the port operator gets in touch on day 60, issues a final notice on day 80 and hands the case to HMRC on day 90. Avoid this — if you can see you won't make it, re-export or release on a cash account and lodge a C285 later.

Do I need my own warehouse to have a CW?

No. Most EC clients use a 3PL with CW authorisation (Wincanton, Kuehne+Nagel, DHL, local operators). The 3PL is then the warehouse keeper, and you use its CW number as the depositor. Your own authorisation is not required (optional self-use for your own warehouse is the alternative route for large flows).

Does CW eliminate duty or only defer it?

It defers it. On release to the UK market you pay the full duty + VAT on the customs value at the moment of entry into the CW (not at the moment of purchase). Duty is eliminated only on re-export from the CW — no duty is then paid. See the article on customs value.

Can I combine TSF and CW?

Yes — the classic flow is: unloading → 3-5 days TSF (waiting for documents) → lodging CPC 7100 000 → transport from TSF to CW → long holding in CW. On CDS this is a sequence of two procedures, but commercially it is a single flow. It requires coordination between the customs agent (EC) and the warehouse keeper.

Not sure whether you need TSF or CW?

The EasyClearance team analyses a client's import flow (volume, holding, re-export, cash flow) and recommends the setup with a break-even analysis. We also help with the CW authorisation application or with finding a 3PL holding a ready CW authorisation at the right port.

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Next up — related articles

Disclaimer: This article is for information only and does not constitute legal advice or a binding HMRC interpretation. The choice between TSF and CW depends on the specific flow, volume and sector — consult a customs agent before deciding. Sources: gov.uk/using-temporary-storage, gov.uk/apply-to-operate-a-customs-warehouse, HMRC Notice 199.

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Temporary Storage vs Customs Warehouse — which to choose when importing to the UK