Some details on the status of "authorised warehousekeeper" and the procedure for obtaining such an authorisation;


As part of its control competence but also as the authority responsible for issuing authorisations to companies wishing to operate as authorised warehousekeepers, customs regularly publish instructions to supplement and clarify certain regulatory points;

This is the case with an instruction published in the Official Customs Bulletins (BOD) No. 6533 of 13 November 2001*, which is still in force and provides many answers, in particular as regards the preparation of the file, a mandatory procedure for obtaining this approval, depending on the particular cases in which the applicant may find himself;

Thus, it is learned that the establishment of a bank guarantee is a prerequisite for approval as an authorised warehousekeeper and that certain operators may be exempted from it with regard to the operations they are going to carry out or their status; moreover, it is the competent customs service that will calculate the amount of this guarantee on the basis of the information provided to it by the applicant (evaluation of the volumes imported/exported) - As regards the form, it is advisable to complete CERFA No 10646*02 and obtain a return signed by the Bank that agreed to give this guarantee;

It should also be noted that the files must be compiled by all companies/entities wishing to become authorised warehousekeepers, but that some relief is provided for the following operators:
- winegrowers registered in the "CVI" computerised vineyard register: they are exempt from producing all the documents required of authorised warehousekeepers. However, for their intra-Community shipments, they must have an excise identification number and, where applicable, a security;
- new authorised warehousekeepers (in the case of newly created companies): they are exempt from presenting balance sheets and tax settlements;
- former wholesalers: they are authorised warehousekeepers by law and therefore do not have to create a new file. However, they must provide certain documents to the department on which they depend (material accounting model and any other missing documents, in particular the tax balance sheet for authorised warehousekeepers carrying out suspended operations);"

In addition, there are specific accounting obligations attached to this status; Thus, the particularities of the accounting system and the related justifications are required of approved warehousekeepers - The territorially competent D.R.D.D.I. must be informed of the material accounting method used by the future warehousekeeper, and must validate its application; 

This instruction has also clarified the status of warehouses temporarily rented by supermarkets to store beer or alcoholic beverages, which must be considered'as an extension of a site with the authorisation of the competent local authority (specification of the rental period of the warehouse, copy of the lease and extension of the security, if any)'.
The maintenance of the stock records must comply with the stock records instruction as explained above;
 This instruction also provides for different statuses of the warehousekeeper, whether he is a "harvester", "trader", "cooperative cellars", or simply "winegrowers" producing wine only for his personal/family consumption and for whom obtaining the status of authorised warehousekeeper is nevertheless necessary....

It also offers answers relating to the movement of products, the obligation to keep stock records mentioned above, the capsules representing duties (CRD) as well as excise duty arrangements and warrants.

* * Source in "BOD n°    6533 du  13 novembre 2001 texte  n°    01-138    DA  du  31 octobre 2001  R - bureau :    F/3 -  NOR : BUD D 01 00 138 S " Réformes des contributions indirectes - Questions réponses" - Site