Bonded Warehouse Security Requirements

Every pallet in a bonded warehouse carries duty that hasn’t been paid yet, and HM Revenue and Customs (HMRC) is trusting you to keep it safe until it is.

That’s why security is so important in these environments and why bonded warehouse security requirements need more than an alarm panel by the door.

Most of the warehouse security you’d expect at a non-bonded warehouse still applies.

The difficulty is, HMRC guidance tells you your premises has to be secured, without giving you a definitive list of what that looks like.

What “Bonded” Means For Your Site’s Security

“Bonded” means goods are held with duty suspended under HMRC approval, with the warehousekeeper (the business authorised to run the site) answerable for the duty on every unit on site.

Physical security is a separate requirement.

And while everything in our guide to warehouse security applies here, the fact the stock is bonded just means the risks are even higher, and the consequences for things going wrong higher again.

Customs Warehouses And Excise Warehouses

In the UK, there are two warehouse options to think about around bonded warehouse security.

A customs warehouse can store imported goods with Customs Duty and import VAT suspended, under customs supervision, until they’re released.

These are either public (storing goods that other businesses put there) or private (storing the warehousekeeper’s own stock).

An excise warehouse holds excise goods like alcohol, tobacco and vaping products with excise duty suspended, under Excise Notice 196.

Security requirements overlap between the two, but the excise notice says more about stock control and losses, so if you hold excise goods, that’s what you need to plan your security around.

What HMRC Looks At Before Approving Your Premises

Before approving excise premises, an HMRC officer visits your site (customs applicants can expect HMRC to organise a site visit if it needs one).

During the visit, HMRC tests your bonded warehouse’s security area by area.

Your Perimeter And Site Plan

Your site plan is often the first look HMRC gets of your bonded warehouse security.

For a customs warehouse, it has to show your perimeter dimensions, clearly marked entrances and fire exits, CCTV and security gates, along with the customs area.

And everything needs to match it.

Security fencing and lighting mark the physical boundary, but gaps – like a broken panel or a dark corner by your loading bay – undermine any plan you submit and put your application at risk.

Walk your perimeter against the site plan before any visit, so anything that’s changed gets fixed.

Entrances, Exits And Everyone Who Uses Them

Every entry point is a place where goods can leave without a record.

A gatehouse security team that checks drivers and paperwork, logging everyone on site (visitors included), gives you a full record of every movement in and out.

At the Avery Dennison manufacturing site, for instance, our officers control the gatehouse and check driver documentation before vehicles are let in.

Excise warehouses have an extra job to do.

Warehousekeepers must display the Notice 50 duty-free warehouse warning poster at each entrance and exit, so check it’s there and visible.

Inside Your Bonded Area

The customs area (or approved area, for excise) needs to be clearly marked.

Fewer people should be able to get into this area compared to the rest of your warehouse, so additional security layers need to be put in place.

Access control systems like badges, fobs or biometric readers with role-based permissions give you an auditable record of every entry or exit so you at least know who was where if something happens.

HMRC can even make this a condition of approval, for example by limiting access to approved areas to named persons.

On top of this, CCTV overlooking your bonded area and the goods stored there provides 24/7 coverage, so each entry on the log can be matched to footage of who walked through.

For our packages, our National Operations Centre (NOC) monitors all feeds, deploying guards to incidents with an average 30-minute response time when we don’t have officers on site.

Out Of Hours Protection

After the last shift is the time when bonded warehouses become particularly vulnerable.

Intruder alarms, remote monitoring from our NOC and keyholding with alarm response cover your building when it’s locked and empty.

Where high-duty bonded goods sit in your building overnight, a static guard may suit you better than patrols or remote response, so you have a clear deterrent and point of contact if you need one.

We’d recommend matching out-of-hours cover to the duty value you hold after close, rather than to what a standard warehouse would need.

Keeping Your Security Compliant After Approval

HMRC officers carry out regular checks once you’re approved. Any gap in security tends to appear later as a stock loss with a duty bill attached.

Why Stock Losses Become Your Duty Bill

An excise warehousekeeper is responsible for the care and control of the goods on site.

It’s up to them to safeguard stock, investigate any losses and report “notifiable losses” immediately.

Excise Notice 196 says HMRC will charge duty on losses unless you can show they’re due to natural causes or an accident. It also says concealing a discrepancy is a serious offence.

Customs warehousekeepers are responsible for security and control of the goods too, including accounting for shortages.

That’s the job of your security.

It stops bonded goods going missing and, when something does, it gives you the footage and access records your investigation will rely on to understand what happened.

Unannounced Visits And Officer Access

HMRC normally arranges visits, but can also show up unannounced, particularly for physical checks.

At an excise warehouse, officers must be given access to any area during operating hours, or whenever activity is taking place.

At a customs warehouse, it’s at any “reasonable time”.

Officers carry identification (and they’ll show it when they arrive or if you ask), so there’s no reason for a genuine visit to stall at the barrier, but is something your security team should be aware of to prevent any deception.

They should check the officer’s ID, let them in, tell the right manager and log the visit like any other.

Changing Your Security Set-Up

Upgrading security measures can need HMRC’s involvement if it changes what they’ve approved.

Excise Notice 196 says any structural additions or alterations to approved premises (other than routine repairs) are a variation to the initial approval.

It says it’s in the warehousekeeper’s own interests to get written consent before work starts.

Don’t forget or ignore this because failing to tell HMRC of any security changes can lead to your approval being withdrawn.

So if new fencing or a layout change would alter your approved premises, raise it with HMRC first.

We’d advise reviewing your security whenever the stock profile or layout changes, as well as after any incident.

What Your Security Provider Can And Can’t Cover

A security company covers the physical layers of bonded warehouse security and the records they produce, while the customs and excise obligations stay with you as the warehousekeeper.

On the physical side, ProFM Group provide SIA-licensed security guards, gatehouse teams, mobile patrols with RFID check-ins, canine teams, access control, CCTV installation and monitoring, and intruder alarms with keyholding and response.

We also install and maintain security fencing and lighting, and every one of these services produces gate logs, patrol records and incident reports.

If a shortage turns up, records like these help show when an area was last checked and who came and went, supporting the audit trail you keep for HMRC.

What stays with you is the administration (declarations and other customs procedures, stock accounts, returns, any guarantee and due diligence on the supply chain).

Layered Bonded Warehouse Security With ProFM Group

HMRC judges bonded warehouse security on the site in front of it, so security has to be designed around that site.

With the gate, patrols, alarms and monitoring under one contract, your records sit in one place and there’s one team to call when an officer asks what happened on a given night.

We’re an SIA Approved Contractor for security guarding and keyholding, with ACS Pacesetters status, NSI Gold for our installed security systems and Paxton Gold, and every officer we deploy is vetted to BS7858 with right-to-work and DBS checks.

We cover sites UK-wide, and every engagement starts with a review of your site.

If you’re preparing for an approval visit, or checking whether your current set-up will stand up to one, we’ll walk your site and give you a free, no-obligation quote.

Call our experts on 0808 175 0116