HMOWTR8110 - Sanctions: When should a Commissioners Direction (CD) be imposed?

A CD is a temporary condition or restriction, having immediate effect, placed on the warehouse by Customs to address a particular risk identified in the removal of goods from the warehouse (EWER Regulation 17(3) refers). It may be applied to protect the revenue where we believe it to be at risk. They should normally only be made where there is insufficient time to add conditions to the trader’s approval.

A CD can be used to good effect to place tighter control on a particular high-risk owner of warehoused goods. You could, for example, direct the warehouse keeper to notify us, prior to despatch, of any removals of a high-risk owner’s goods. Or indeed, you may further restrict the removal of those goods. A CD may be issued to:

• control movements from a warehouse during the notice period immediately before the warehouse approval is to be revoked; for example, goods in the warehouse cannot be despatched under suspension arrangements, but only released to home use;
• prevent a particular suspect load from leaving the warehouse until you are satisfied that the movement is legitimate, or until the duty has been paid or fully guaranteed on those goods;
• restrict the movement, out of the warehouse, of goods belonging to particular owners; for example, require prior notification of these removals, or direct that they can only be removed once the duty has been paid.