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.