FHDDS40200 - Record keeping and due diligence: obligations
(The Fulfilment Businesses Regulations 2018, regulations 10)
A fulfilment business must keep certain information and comply with obligations and restrictions (see FHDDS24200). The following table sets out the records that must be maintained.
| Record | Comment |
|---|---|
| Name | The name of the registered business, including any trading name(s), if applicable |
| Contact details | The address of the overseas customer, an email address and telephone number |
| VAT registration numbers | A VAT registration number should be held for each overseas customer |
| A description of the imported goods stored for that customer, including the type and quantity of such goods | The description should match the description in commercial documentation (for example, invoices, delivery notes etc) for the fulfilment business as well as the goods stored on the premises. The fulfilment house must record what they believe to be in the boxes. Good due diligence would include some kind of cross-check to ensure that the goods held match the documentation. |
| The import entry number of the imported goods (these are flagged as Movement Reference Number (MRN) within the Customs Declaration Service (CDS)) |
In CHIEF: the format must always include the date. An IEN is an 18-digit code - 3 digits for the Processing Unit; 7 digits for the Entry Number; and 8 digits for the date of entry. In CDS: an MRN is an 18-digit code - 2 digits for the year; 2 digits for the country code; and a further 14 random digits. |
| The address to which goods are delivered from storage |
A fulfilment business will need to evidence that it has issued a Notice of Obligations to each of its overseas customers The Notice should contain all the information specified in the law. For simplicity, HMRC provides a template for business use. |
| Any further information relating to the customer and imported goods stored for customers that HMRC might specify | At this point HMRC has not specified any further information. Officers wishing to add a specific condition should consult the VAT Serious Non-Compliance & Fraud Team. |
These records must be made available for inspection by an HMRC officer when required and must be kept for 6 years.