Customs Fulfilment House

If a business stores goods in the UK for overseas sellers who sell through online marketplaces such as Amazon or eBay, it may fall within the Fulfilment House Due Diligence Scheme.

Hammad advises fulfilment businesses, warehouse operators, online marketplace-linked businesses, and advisers on registration obligations, due diligence requirements, record keeping, HMRC checks, and penalties arising under the fulfilment house rules.

When Registration May Be Required

A business may need to register where it stores goods in the UK and the relevant conditions are met, including where the goods were imported, are owned by or stored on behalf of overseas sellers, and are offered for sale in the UK.

• Goods imported from outside the relevant customs territory
• Goods owned by, or stored on behalf of, an overseas seller
• Goods offered for sale and not previously sold in the UK
• Storage activities carried out as part of a fulfilment or warehouse business

Businesses may still be required to register even if they do not consider themselves to be a fulfilment business, where their activities fall within the scope of the scheme.

Due Diligence & Customer Checks

Once approved, fulfilment businesses must carry out checks on overseas customers and the goods being stored. These checks are designed to help ensure that overseas sellers meet their UK VAT and customs obligations.

• Checking overseas customer details
• Verifying VAT registration numbers or exemption references
• Reviewing import and storage information
• Taking action where non-compliance is suspected

Where a fulfilment business suspects that an overseas customer has not met VAT or customs duty obligations, it may be required to notify HMRC and stop working with that customer if the issue is not resolved.

Records & Ongoing Compliance

Approved fulfilment businesses are required to keep specific records, including details of overseas customers, goods stored, import entries, delivery countries, and notices issued to customers regarding UK tax and duty obligations.

• Customer names and contact details
• VAT registration numbers or exemption references
• Type and quantity of goods stored
• Import entry numbers and delivery country records
• Notices issued to overseas customers

These records may need to be retained for several years, and failure to keep proper records can lead to penalties.

Applications, Amendments & HMRC Decisions

Hammad assists with applications, amendments, withdrawals, HMRC information requests, premises inspection issues, approval conditions, and challenges where applications are rejected or penalties are imposed.

His advice helps businesses understand whether they are within the scheme, how to comply with their obligations, and how to manage HMRC enquiries or disputes effectively.

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