CFSP14600 - Processing the application: multi-site authorisations

Many traders have multiple sites of operation within the UK and may wish to operate each set of premises independently. Although the Legal Entity may decide to apply to have more than one site included in their CFSP operation the authorisation must be in the name of the Legal Entity.

Where a legal entity makes a CFSP application and the Head office is in one Business area whilst the trading premises are in another, care should be taken to make sure the trader is authorised by the most appropriate local authorising office. There is little point in a local office authorising a trader for whom they have the Head office if the records, premises and goods are in another area. If however the Head office does hold the records but the trading activities are carried out at a site in another area then it would be appropriate to authorise the trader at the Head office location.

Where any physical checks are required on goods or premises the authorising office would make a request via the Risk team in the area where the goods are physically held. If in doubt authorising officers should consult the CFSP U of E.

Therefore when an application for CFSP is received, it is vital that the officer establishes the following before proceeding with the authorisation process:

• Has the application been made by the head office for the legal entity?
• Does the application cover more than one site?
• Is it the intention for more than one site of the same legal entity to operate CFSP?
• Does each separate site use its own TURN and
• how does the applicant intend to operate CFSP, ie one TURN for the legal entity or multi-TURNs flagged for CFSP?

Authorisation and site control responsibilities

It is vital that the HMRC office with responsibility for the trader’s head office establishes communication with the offices responsible for the area in which the trader has indicated they wish to operate CFSP at the time the application is received. The head office control team should verify with each office that:

• no other CFSP applications have been received
• no other ‘branches’ of the trader are currently CFSP authorised
• local staff have no knowledge of any past instances of serious non-compliance and
• any local approvals to operate ‘other customs procedures’ are valid (ie warehousing, etc).

Once it has been established that there are no barriers to the application being issued (ie past compliance problems, auditability, legal entity already authorised, etc) discussions should take place between all offices to ensure consistency of treatment for each site. Officers should agree whether:

• each site will be self-accounting (ie submit declarations under different TURNs, CFSP EPUs, etc)
• each site will maintain its own records (LCP, TS, Warehousing)
• the trader’s head office will submit declarations to one CFSP EPU on behalf of all sites (one TURN one EPU)
• whether the records will be maintained at a central location
• what assurance /control work each office will undertake.

It is important to agree each of these issues at the outset to ensure that each officer is clear on their responsibilities, ensuring that no controls slip through the net. If these issues are not resolved before the trader begins operating it may result in documents not being maintained correctly, officers not being assigned an appropriate amount of resource for control or officers not being able to access the necessary paperwork (ie papers in Scotland whilst the officer is in Southampton).

Authorisation scenarios

If it is the intention for CFSP activities to take place at more than one site of the same legal entity, serious consideration must be given before authorisation is granted as to whether:

1. Scenario one - one TURN set up to one CFSP EPU will cover all activities.
   
   

The consequences of scenario one are as follows :

• One office has responsibility for all the CFSP activities for the legal entity wherever they are taking place, eg Scotland or the South of England.
• Only one office has resources allocated for assurance activity for the legal entity. ( Note: regardless of the number of sites Large/ Significant/ SME traders set up in this way will only be resourced as one trader.)
• HMRC offices covering different locations of the sites will need to resource any responses to references etc from the controlling office from within locally allocated resources. This control activity would not have been accounted for under the areas ITBAM allocation.

If this type of authorisation is adopted the trader should be advised that all records, declarations etc from all sites should be produced at the office stated on the authorisation for assurance activity to be carried out. Documents must be produced to the authorising office for all sites’ activities, ie irrespective of where the goods are located all documents/ records would be controlled by one office.

The controlling office must ensure that all new designated premises are examined by appropriate HMRC officers prior to inclusion on the authorisation and local clearance records are maintained at each site, not centrally. Again, no resource would have been allocated within the respective areas ITBAM to cover these activities.

The authorising office would be responsible for issuing a ‘Certificate of Assurance’ for the trader’s entire CFSP operations.

2. Scenario two - a separate TURN, set up to the CFSP EPU for the geographical location of the site is used. (The second scenario is more desirable from an HMRC point of view)
   
   

The consequence of scenario two are as follows :

• Each site’s TURN can be set up to the relevant CFSP EPU for the geographical location.
• Resources will be allocated by the ITBAM for each site separately, as the trader will appear on more than one areas list.
• Whilst the officer for the head office will issue the authorisation letter to cover the whole legal entity, locally applied conditions and controls, relevant to risks that have been identified on a site by site basis, can be included as additional annexes.

If this type of authorisation is adopted the head office control officer will retain overall responsibility for the trader’s authorisation but must also act as a co-ordination point for the legal entity/ other sites by:

• keeping the authorisation up to date
• providing a copy of the authorisation to each office controlling a site
• facilitating the exchange of information gleaned on assurance activity at any of the sites
• agreeing an audit plan to cover all the legal entities’ CFSP activities if appropriate
• facilitate the inclusion of new sites (as detailed below) and
• issuing the ‘Certificate of Assurance’ based on information obtained from other offices.

With the establishment and maintenance of clear communication links across areas, the option of multi-sites with different TURNs offers the best opportunity for gaining a higher level of assurance. Authorising officers should bear this in mind and consider very carefully any applications based on multi-sites with only one TURN.

Inclusion of new sites within a CFSP authorisation

If an authorised trader wishes to add additional sites to their CFSP authorisation, the head office control officer will need to complete the action detailed in the following paragraphs.

Multi-site - one TURN number operation

The trader should be requested to put all the details in writing, ie address and plan of the new site etc for inclusion if relevant in the authorisation letters. If LCP is being operated, any new designated premises must have a TS ‘deed of undertaking’ completed and signed by the company. Agreement should be reached with the new site on the maintenance of records, end of transit notifications and notification of putting the goods into a customs procedure, etc as appropriate.

Multi-site - multi TURN

The trader should be requested to put all the details in writing to the office where authorisation for the whole legal entity was issued. The head office control team should then contact the local officer for the new site immediately and send a copy of the trader’s letter. Contact should then be established between the new site and the local officer.

Testing of the system, PA forms etc at the new site should be the responsibility of the local officer. Contact should be maintained between the head office control team and the local officer in order to ensure that procedures agreed for the new sites are correctly reflected in the authorisation letters. Copies of the authorisation letters should be held by the authorising officers for all the sites, as well as the Issuing Officer.