Goods from outside the EUArt. 18 LIVA Customs warehouse No VAT is paid on entry. The import takes place when the goods leave the procedure: if they are released for free circulation, import VAT is settled in that DUA (art. 18.Dos LIVA). Customs warehouse
and non-customs
warehouse (DDA)
A customs warehouse (depósito aduanero) is a warehouse authorised by customs where non-Union goods wait without paying duties or import VAT, with no time limit. They are paid if the goods are released for free circulation. The non-customs warehouse (depósito distinto del aduanero, DDA) suspends VAT on Union goods under the same rules.
What happens with VATWhat types of warehouse
are there in Spain?
Six authorisations: three for customs warehouses and three for non-customs warehouses. What changes is who can use them and who is responsible for the goods before customs.
| Authorisation | What it is | Who is responsible | Procedure in the DVD |
|---|---|---|---|
| CWP | Private customs warehouse. Only the authorisation holder uses it. | The authorisation holder and the holder of the procedure (art. 242.1 UCC). | 71 |
| CW1 | Public customs warehouse type I. Open to any depositor. | The authorisation holder and the holder of the procedure, who declares the entry (art. 242.1). | 71 |
| CW2 | Public customs warehouse type II. Open to any depositor. | Only the holder of the procedure (art. 242.2). | 71 |
| DDAP | Private non-customs warehouse (DDA). | As in the CWP: the customs warehouse rules apply to the DDA with their adaptations. | 95 |
| DDA1 | Public non-customs warehouse type I. | The authorisation holder and the holder of the procedure. | 95 |
| DDA2 | Public non-customs warehouse type II. | Only the holder of the procedure. | 95 |
General information; not advice.
VAT Is VAT paid when goods
Is VAT paid when goods
enter a warehouse?
Not on entry. VAT is deferred until the goods leave the procedure, and it depends on where they go. LIVA is Ley 37/1992, the Spanish VAT Act.
Import VAT → → Goods from outside the EUArt. 18 LIVA Customs warehouse No VAT is paid on entry. The import takes place when the goods leave the procedure: if they are released for free circulation, import VAT is settled in that DUA (art. 18.Dos LIVA). Sales and servicesArt. 24 LIVA While inside Supplies of goods placed in the warehouse, and services directly related to them, are exempt while they remain in it, provided they are not used or consumed (art. 24 LIVA). Union goodsAnnex, fifth section DDA A VAT suspension procedure for goods that cannot enter a customs warehouse because of their origin or provenance, such as Union goods. Imported goods can only enter if they are on the list in art. 65 LIVA. ExitArts. 18 and 19 LIVA On leaving the DDA Leaving for the Spanish market is an operation treated as an import if the entry benefited from the exemption, or an import if the goods were imported under the art. 65 exemption (arts. 18.Tres and 19.5.º LIVA). Entry How do goods enter?
How do goods enter?
With a warehouse entry document (DVD).
- Before the goods arrive
Pre-lodged declaration (PDC)
The depositor or its representative sends the full warehouse entry declaration before the goods arrive. Its acceptance does not admit it yet: it is not a customs declaration yet.
- While they have not arrived
Amend or cancel it
The PDC can be amended or cancelled by web service. The warehouse, the customs office, the declaration types, the number of items and the persons cannot change: annex I of the guide sets this.
- When the goods are presented
The PDC becomes a DVD
When the summary declaration for temporary storage that it cites is activated, the PDC becomes a warehouse entry document (DVD), accepted with the presentation date. The control channel arrives through the inbox and by email.
- Afterwards
Only at the customs office
Once the DVD is accepted, it can no longer be amended or cancelled by web service: this must be done at the customs office. Without a prior PDC, the DVD can be sent directly, and the response carries the control channel.
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Exit How do goods leave
How do goods leave
the warehouse?
Release for free circulation (H1)
The import declaration (DUA) cites the MRN of the DVD as the previous document, preceded by its type, and the item. On release, duties and import VAT are paid and the item is discharged.
Export (AES)
The export declaration cites the MRN of the warehouse document and the quantity leaving. The goods leave the Union without having paid duties or import VAT.
Transit (NCTS)
The transit declaration cites the warehouse document, the item and the quantity in the same way. It is used to take the goods under customs control to another customs office.
Exit from the DDA (SDD)
A national document with the destination of the goods: export, another Member State, the Spanish market, the Canary Islands, Ceuta or Melilla, another DDA, destruction, losses or return to origin.
Sale inside the warehouse (VTA)
Public warehouses only. It discharges the seller's document and the AEAT generates a new DVD in the buyer's name, without the goods moving.
Unit conversion (RUN)
Changes the units of the goods within the same warehouse. The resulting goods are declared in the header.
Transfer to another warehouse (TRS)
Moves the goods to another warehouse of the same type: customs warehouse to customs warehouse, or DDA to DDA.
What records are kept
and what does the guarantee cover?
The authorisation holder and the holder of the procedure keep records approved by customs that identify each item, its customs status and its movements (art. 214 UCC). Each document that takes goods out of the warehouse discharges the item they come from: that is why the import declaration, the export or the transit cite the MRN of the DVD and the item.
If a customs debt may arise, the authorisation requires a guarantee (art. 211.3.c UCC), with its reference number (GRN) and a reference amount that must be on record before first use. In the DDA, the holders are also secondarily liable for the VAT due when the goods leave.
How is it different
from temporary storage?
Temporary storage (depósito temporal) is the wait after arrival; customs warehousing, a procedure to keep the goods for as long as needed. They often follow each other: the DVD cites the temporary storage declaration the goods come from.
| Temporary storage | Customs warehouse | DDA | |
|---|---|---|---|
| What it is | A situation: the goods wait between their presentation to customs and their placement under a procedure or re-export (art. 5.17 UCC). | A special storage procedure (art. 240 UCC). | A VAT suspension procedure (Ley 37/1992, annex, fifth section). |
| Time limit | 90 days to place them under a procedure or re-export them (art. 149 UCC). | None. Customs only sets one in exceptional cases, such as a risk to health or the environment (art. 238 UCC). | The same rules as the customs warehouse. |
| Which goods | Non-Union goods. | Non-Union goods, and Union goods in specific cases (art. 237.2 UCC, procedure 76). | Union goods and imported goods on the list in art. 65 LIVA. |
| How goods enter | Temporary storage declaration (G4). | DVD or IDA, with procedure 71. | DVD or IDA, with procedure 95. |
| What can be done | Keep the goods unchanged, without processing them. | Usual forms of handling: preserving the goods, improving their appearance or marketable quality, preparing them for sale (art. 220 UCC). | The same rules as the customs warehouse. |
| Authorisation | Temporary storage warehouse (TST, C509). | CWP, CW1 or CW2 (art. 211.1.b UCC). | DDAP, DDA1 or DDA2, valid in Spain only. |
General information; not advice.
Authorisation How do you apply for
How do you apply for
a warehouse authorisation?
What the AEAT application asks for, in the order of the form. The DDA application follows the same instructions and is valid in Spain only.
- 01 E-office Electronic application. Lodged on the AEAT e-office (Sede) with a certificate of the applicant or of a representative empowered for that procedure, who needs an EORI.
- 02 Type CWP, CW1, CW2 or DDAP, DDA1, DDA2. The number the AEAT grants is ES plus the type, the year and a sequence number: ESCWP02025000011 or ESDDA12025000012, the examples in the instructions.
- 03 Offices Placement, discharge and guarantee. The office of placement grants release for the procedure, the office of discharge receives the declaration that ends it, and the guarantee office is where the guarantee is provided.
- 04 Records Main accounts and records. Where they are kept and with which software. They must identify the goods, their customs status and their movements. They are not required for a public type II warehouse.
- 05 Premises Storage location. The facilities being authorised, the goods (four-digit CN code or their description) and the usual forms of handling planned.
- 06 Guarantee Reference number (GRN) and amount. If the authorisation requires it, its reference amount is mandatory before first use: without it, the AEAT does not accept the declaration.
Frequently asked questions
about customs warehouses
All about customs → What is a customs warehouse and what is it for?
It is a warehouse authorised by customs where non-Union goods are stored without paying duties, other charges or import VAT (art. 237 UCC). It is used to defer those payments until the destination of the goods is known: if they are released for free circulation, they are paid then; if they are exported or leave under transit, they are not paid in Spain.
What is a non-customs warehouse (DDA) and how are goods placed in it?
It is a VAT suspension procedure for goods that cannot go into a customs warehouse because of their origin or provenance, such as Union goods, with the same rules as the customs warehouse (Ley 37/1992, annex, fifth section). Goods are placed in it with a DVD or an IDA with procedure 95, and leave with a national document, the SDD.
Is VAT paid when goods are placed in a customs warehouse?
No. While the goods are placed in the warehouse, there is no import for VAT purposes: it happens when they leave the procedure (art. 18.Dos LIVA). If they are released for free circulation, import VAT is settled in the DUA; supplies and related services while they are inside are exempt (art. 24 LIVA).
How long can goods stay in a customs warehouse?
There is no limit (art. 238 UCC). Customs can only set a time limit in exceptional cases, for example if long storage of those goods poses a risk to health or the environment. In temporary storage, by contrast, there are 90 days.
How is it different from temporary storage?
Temporary storage is a waiting situation between the arrival of the goods and their placement under a procedure, with 90 days at most and no handling. Customs warehousing is a special procedure with no time limit, in which the goods can be preserved, repackaged and sold. They are often chained: the DVD cites the temporary storage declaration the goods come from.
What is a PDC in a warehouse entry?
It is the full pre-lodged declaration: the DVD sent before the goods arrive. It can be amended or cancelled by web service until the goods are presented; it then becomes a DVD accepted on that date, and the AEAT reports the control channel through the inbox and by email.
What is an IDA?
It is placement in a warehouse by entry in the declarant's records (inclusión en depósito por domiciliación aduanera): the warehouse entry under the entry-in-the-declarant's-records procedure (declaration type Z). It requires the authorisation for entry in the declarant's records (EIR) and, since version 1.7 of the AEAT guide, it can cite the I2 entry notification as the previous document.
Who can operate a customs warehouse?
Whoever obtains the customs authorisation (art. 211 UCC): being established in the Union, offering assurance that operations will be carried out properly and providing a guarantee if a customs debt may arise. The holder also keeps records that identify the goods, their customs status and their movements (art. 214 UCC).