HMRA4130 - Refusal/cancellation: If I have enough evidence to revoke an approval do I need to give a period of notice to the trader before the revocation becomes effective?
CEMA s98 provides a revocation period of three months for
withdrawal of warehouse approvals.
There is no mandatory revocation period for:
warehousekeeper, owner, duty representative, REDS registrations;
the revocation can become immediately effective. In practice you
should weigh the risk to the revenue against setting the revocation
date to a date allowing the trader to deal/account for stock on
hand or in transit.
It is worth noting that immediate revocation of the
warehousekeeper registration causes a duty point to occur for all
suspension goods in the keeper’s warehouse. This would cause
significant disruption and logistical problems. In most cases, the
warehousekeeper should be allowed a month revocation period; during
this period, conditions and restrictions can be placed on the
premises approval to address specific risk.
