Stock Records: The invisible ally of suspensive customs regimes

When a company places its goods under a suspensive customs regime, transparency becomes both a requirement and a guarantee. This is precisely the role of stock accounting: established under Article 286 J of Annex II of the French General Tax Code, it is not a mere bureaucratic formality, but the true core of the system. Serving both as a traceability tool and an operational dashboard, it reassures customs authorities about the legitimacy of the suspension while providing operators with a detailed view of their flows and inventories. In other words, it forms the foundation of trust between businesses and customs.

Practically, stock accounting takes the form of a register tracking the lifecycle of goods step by step. Every movement is recorded: date, quantity, nature of the operation, and customs reason. Upon receipt, the entry is noted; during processing, the consumption of raw materials and the emergence of finished products are recorded simultaneously; at exit, whether for release for free circulation or re-export, the stock decrease is noted.

An example illustrates this principle clearly:

An approved warehouse holds 100 aluminum coils. A delivery of 40 coils brings the total to 140. Twenty are then sent for cutting under inward processing, reducing the balance to 120. Finally, 50 are released for free circulation, leaving the register at 70. In every instance, the algebra of movements matches the physical stock: a guarantee of absolute transparency for both customs authorities and the operator.

To be compliant, the register must include a minimum set of information: date, quantities in and out, theoretical balance, type of operation, and applied customs regime. Two signed copies are required: one kept on-site, and the other submitted to the customs office of reference, every ten days for volume-taxed products (alcohol, fuels) and monthly for others, except in special cases. Approximate record-keeping exposes the operator to financial penalties, and potentially the suspension of their authorization. Losses and damages must also be rigorously recorded.

The digital era has significantly transformed this obligation. Integration into an ERP or dedicated customs module now allows automated entries from electronic declarations, continuous reconciliation of theoretical stock with inventories, and alert generation in case of discrepancies. The result: fewer errors, faster inspections, and better cash flow management.