STO
Also known as: storage declaration, placement declaration
An STO is the declaration for placement in a customs warehouse. The goods remain non-Union goods, duty and VAT stay suspended, and from that moment the stock records have to line up with what you declared.
When do you file an STO instead of an IMA?
An IMA brings goods into free circulation: duty and VAT are established and the goods become Union goods. An STO does not. The STO places the goods in an authorised customs warehouse, under suspension. You pay when you later release to free circulation, or you never pay if the lot leaves the customs territory again as re-export. You make that choice when the destination is not yet fixed at entry, or when you want to hold stock without paying the charge yet. A distribution centre that supplies both inside and outside the Union from one stock places the entry in a warehouse. Chairs for a customer in the Union are later released with an import declaration. Chairs for the United Kingdom go as re-export. Technically the STO is the same kind of import declaration as an IMA, with a different data element: placement in the warehouse instead of release for consumption. In DMS you file it over the same connection. The difference sits in the procedure code, the warehouse authorisation and the fact that no charge is assessed.
What happens to the goods after placement?
After acceptance of the STO the goods remain non-Union goods under customs supervision. They may not leave the warehouse without a follow-up declaration. Usual forms of handling are allowed: repacking, sorting, labelling, taking samples and treatments that keep the goods in being. Real processing or assembly is not allowed, inward processing exists for that. The T1 or the summary declaration with which the goods were presented is discharged by the STO. That is the same chain logic as with an IMA: the previous declaration points to the next, and a gap produces questions from customs. Without a discharged T1 the transit guarantee stays occupied, even if the goods already sit on the rack. In principle the goods may stay in the warehouse without a time limit. Customs can set a period in special cases, but the procedure has no standard maximum. What does have a time limit is the alignment of the records: every movement has to be traceable to a declaration, at any moment.
How does the STO line up with the warehouse records?
Every STO is an inbound entry. In the warehouse stock records that inbound has to be found with the same commodity code, the same weight and the same quantities as on the declaration. Every later outbound (to free circulation, to re-export, or under T1 to another member state) has to refer back to that inbound. At an authorisation check customs lays the records next to the physical stock. Stock movements that only sit in the WMS and not in the customs records, or the other way around, are a finding. A difference that cannot be explained leads to a customs debt over the missing goods. The holder of the warehouse authorisation is liable for that. That is why a closed link between warehouse and customs is an authorisation condition, not a neat extra. A manual monthly reconciliation rarely meets that demand. File the STO without recording the inbound in the WMS and you build a difference from day one that only shows up at the next inventory.
How do you take goods out of the warehouse later?
There are three exits. To free circulation: an import declaration (IMA) that refers to the STO, with duty and VAT established over the lot released. To a third country: a re-export declaration, with no charge, taking the lot off stock. To another member state under suspension: a T1 that lets the goods travel on as non-Union goods. The exit has to line up with the inbound. The same code, the same weight, the same quantities, or an explained split if you release part of the lot. An outbound of eighty chairs from an inbound of a hundred is in order if the records show the remaining twenty. An outbound of a hundred and ten is not. The order in the chain is fixed. First the STO, then the outbound. An IMA or a re-export that does not point to an open inbound is refused or produces a gap later. Watch open inbounds as tightly as open T1 movements: it is the same liability, only the stock is sitting still instead of moving.
What does DMS ask of an STO that it does not ask of an IMA?
DMS wants to see the warehouse authorisation, on the EORI number of the authorisation holder, with the location where the goods are placed. If that number does not match the authorisation, DMS refuses the declaration. The commodity code is the same ten-digit TARIC code as for an IMA, because customs has to be able to test which measures sit on it, even though nothing is charged now. The customs value has to be on it too. That value is the base for the warehouse guarantee and for the charge at a later release to free circulation. A value that is too low on the STO only postpones the problem: at release or at a later check the correction still comes, with interest. Document codes and prohibitions and restrictions apply at placement just as much. A certificate that is mandatory at import can also be mandatory at placement in a warehouse, depending on the measure. If it is missing, the STO comes back as a refusal, not as a warning the way it used to in AGS.
What goes wrong when an STO does not line up with the stock?
The first thing that goes wrong is the discharge of the preceding T1. If the container is already in the warehouse while the STO has been refused, the transit guarantee keeps running and in time the enquiry starts. The goods are there physically, but administratively they are still in transit. That is a standard cause of open T1 movements on warehouse shipments. The second is an inbound that never landed in the WMS. Customs sees an STO, the warehouse sees the goods, and the customs records of the warehouse have a gap. At the next inventory or at a check that gap is a finding. Repairing it later is possible, but you then have to show that the physical stock matched for the whole period. The third is an outbound under the wrong procedure. A lot that leaves as re-export but was declared as IMA has paid duty that was not due, or the reverse has left duty unpaid. The chain does not repair itself. Every outbound has to follow the inbound, the order and the actual destination.