Bonded Warehouses & Deferred Clearances — Holding Goods Duty-Unpaid

Every lesson so far in this Customs & Excise chapter has assumed that an importer wants the goods now and is ready to pay now: we classified the goods to a tariff line, valued them to a Value for Duty Purposes (VDP), applied any origin preference, computed customs duty, surtax, excise and VAT on importation, and cleared the consignment for home consumption. This lesson studies the great exception to "pay now". The bonded warehouse is a licensed, secured building (or tank, or enclosure) in which dutiable imported goods — and locally manufactured excisable goods — may be lodged, kept and secured without payment of duty until the requirements of the Act have been satisfied. The legal point of the institution is deferral: the goods physically enter Zimbabwe but the duty point is postponed until the importer takes them out of the warehouse and enters them for consumption, exports them, or removes them in bond elsewhere.

The governing law is Part VII (Warehousing of Goods), Sections 68 to 84, of the Customs and Excise Act [Chapter 23:02], fleshed out by Part XI of the Customs and Excise General Regulations (the "General Regulations 2021"), regulations 71 to 93. The architecture is built on three pillars. First, Section 68 lets the Commissioner, by notice in the Gazette, appoint and license private bonded warehouses (one proprietor's goods), public bonded warehouses (many importers' goods) and duty-free shops — but only at a place that has been appointed a warehousing port under Section 14(1)(c) (the Ports of Entry and Routes Order, SI 256 of 2000). Second, Section 69 requires the warehouse keeper to give a general bond, with sufficient surety, securing the full duties on all goods that may at any time be warehoused and their safe removal — the bond is the security that lets the State release physical control of uncustomed goods without losing the revenue. Third, Section 70 delivers the benefit: the importer "may warehouse … without the payment of duty on the first importation", and crucially Section 70(5) defines "duty" to include the import VAT payable under the VAT Act [Chapter 23:12] — so warehousing defers customs duty, surtax, excise and the 15.5% import VAT together.

Three rules give the regime its discipline and are the heart of this lesson. Section 75 fixes the rate of duty: goods deposited without payment of duty are, on being entered for consumption, subject to the rate of duty in force at the time of that entry — not the rate at importation. The duty point and the rate-setting moment are the day the goods leave the bond for home use, which makes warehousing a calculated bet on future tariff changes as much as a cash-flow tool. Section 76 imposes the two-year limit: imported goods warehoused under Section 70 must, after two years, be entered for export in bond and exported, or entered for consumption and removed — failing which the Commissioner may sell them (duty first, then rent and State charges, balance to the owner) or, if they cannot be sold for enough, destroy them or appropriate them to the State without compensation. Bulk oil and petroleum spirits in storage tanks are exempt from the two-year rule. Section 71 controls removal: no warehoused goods may be taken from a warehouse except on entry and payment of any duty due, and removal in contravention is an offence carrying a fine of level 12 or three times the duty-paid value, whichever is greater, or up to five years' imprisonment (the same penalty protects the customs locks under Section 179).

Around this spine sit the operational provisions. Section 71(4) and regulations 90–91 govern deficiencies — if the quantity found is less than what was entered for warehousing, duty is payable on the deficiency, with prescribed allowances for natural losses on wet goods, bulk oil and motor spirit where the loss was neither wilful nor negligent. Section 77 permits, under safeguards, sorting, repacking, and even assembly, blending, mixing, conversion or manufacture in bond — the legal basis for "manufacturing under bond". Section 82, with regulations 87–89, lets the Commissioner remit duty on warehoused goods accidentally lost or destroyed (if every reasonable precaution was taken), or consensually destroyed or abandoned to the State. Section 78 allows transfer of ownership of warehoused goods on written notice; Section 79 lets an officer lock the warehouse; Section 81 and regulations 85–86 govern sampling. The licence costs US$100 a year (reg 173), expires every 31 December (Section 68(5)), and the keeper must keep a warehouse register (reg 73) and issue a Form No. 26 receipt for goods received.

Finally, Section 83 introduces removal in bond / removal in transit (RIB/RIT) — moving uncleared goods under bond to another port inland or out of the country on a Form No. 121 removal-and-transit bond or a Form No. 122 undertaking plus cash deposit (regs 27–28, 80–81, 148). This lesson treats RIB/RIT only as the bridge to the dedicated Deferred Clearances (RIB, RIT, T1) module that follows, because warehousing and removal-in-bond are the two faces of the same idea — keeping the duty suspended while the goods are physically present or in motion. The contrast throughout is with the State warehouse (Section 232), which is not a deferral facility the trader chooses but a place of detention the State uses for goods not duly entered, on which rent runs (reg 172) and a 60-day auction clock ticks.

Mastering this module means being able to: license and bond a warehouse; enter goods into bond and out of bond on the right Customs Procedure Code (CPC); apply the Section 75 rate-at-consumption rule; size a Section 69 bond to cover full duties including 15.5% import VAT; compute duty on a deficiency net of allowances; and know exactly when removal becomes the Section 71 / Section 179 offence. It connects backwards to Customs Registration (the Section 69 bond and warehouse-keeper licence), Documentation (the Form 21 bill of entry that effects both warehousing and ex-bond clearance), Valuation (the VDP captured at warehousing governs duty at consumption), and Refunds, Remissions & Bonds (Section 82 remission, the bond mechanics); and forwards to Deferred Clearances, ASYCUDA World, Temporary Imports, and SEZs/Free Zones.

Imagine a Bulawayo distributor who has just imported a 40-foot container of assorted dutiable goods through Beitbridge. Under everything we have learned so far, the moment those goods are imported the distributor must make entry and pay the duty due — customs duty, surtax, any excise, and 15.5% VAT on importation — before the goods are released (Section 38, no importation without entry; Section 40, entry and payment on a Form 21 bill of entry). For a large consignment the duty bill can be tens of thousands of US dollars, payable before a single unit has been sold. That is a severe cash-flow burden, and it is the precise problem the bonded warehouse was invented to solve.

A bonded warehouse is a building or structure (and, by extension, a bulk storage tank or a secured enclosure) that the Commissioner has appointed and licensed under Section 68 as a place where dutiable goods may be lodged, kept and secured without payment of duty until the requirements of the Act have been satisfied — that is the statutory definition of "warehouse" in Section 1 of the Act. The word "bonded" signals the legal mechanism: the keeper has given a bond (a financial guarantee backed by surety) that the duty will be paid, or the goods accounted for, so the State is willing to let the goods sit physically inside Zimbabwe with the duty suspended. The goods are uncustomed — "uncustomed goods" in Section 1 means goods on which the full duties have not been paid — but they are under customs control, secured by lock, bond and record.

The benefit to the trader is deferral of the duty point. Duty (including import VAT) is not paid when the goods cross the border; it is paid later, and only on the goods actually taken out for home consumption — when the distributor draws stock from the bonded warehouse to meet orders, paying duty on that withdrawal only. Goods that are never sold in Zimbabwe can be re-exported in bond and never bear Zimbabwean duty at all. This converts a large upfront tax into a series of pay-as-you-sell instalments, and it makes Zimbabwe viable as a regional distribution hub: a multinational can hold regional stock in a Harare public bonded warehouse and clear it piecemeal into Zimbabwe, or move it onward in bond to a neighbouring market, without ever triggering Zimbabwean home-consumption duty on the goods bound elsewhere.

Three reader intuitions must be corrected at the outset. First, warehousing suspends duty; it does not extinguish it. The liability is alive throughout; it merely sleeps. The bond exists precisely because the State has not been paid. Second, the rate of duty is fixed at the moment of ex-bond entry for consumption, not at importation (Section 75) — so an importer who warehouses goods is also, knowingly or not, taking a position on future tariff movements. Third, the clock is running. Section 76 gives imported warehoused goods two years; overstay, and the Commissioner can sell or destroy them.

This lesson sits at a natural hinge in the syllabus. Having completed the classification → valuation → origin → duty spine and the reliefs family (rebates, refunds/remissions/bonds, and export drawback), we now turn to the procedures that defer or relocate the duty point rather than reduce it. Warehousing is the first of these. It is intimately related to the next module, Deferred Clearances (Removal in Bond, Removal in Transit, the T1), because Section 83 — the last section of the warehousing Part — is itself a removal-in-bond provision: instead of paying duty or depositing goods in a warehouse, an importer may move the goods in bond to another port or out of the country under a transit bond. We introduce that bridge here and develop it fully in the next lesson. Warehousing also feeds directly into ASYCUDA World (the warehousing and ex-warehouse Customs Procedure Codes), Temporary Imports & ATA Carnets, Free Trade Zones & SEZs (a related duty-suspension regime), and Excise (locally manufactured excisable goods are warehoused under Section 70(3) and regulation 75 until removed for consumption).

ZIMRA's enforcement interest in bonded warehouses is high, and for an obvious reason: a warehouse is, by design, a building full of uncustomed goods under a private keeper's day-to-day control. The temptations — quiet removal without entry, "shrinkage" dressed up as natural loss, manipulated stock records — are exactly the risks the Part VII control provisions (locking, registers, stock-taking, deficiency duty, the Section 71 and Section 179 offences) are written to defeat. A clearing agent or warehouse keeper who understands why each control exists is far less likely to fall foul of it.

The primary statute — Part VII of the Customs and Excise Act [Chapter 23:02]

The warehousing regime lives in Part VII, "Warehousing of Goods", Sections 68 to 84. Take the sections in order, because they tell a story from licensing the building, through getting goods in and keeping them safe, to getting them out.

• Section 68 — Bonded warehouses. The Commissioner may, by notice in the Gazette, appoint and license approved buildings or structures as bonded warehouses — either private (Section 68(1)(a)(i): a warehouse for goods imported by one private proprietor and entered for warehousing there) or public (Section 68(1)(a)(ii): a warehouse for goods imported by one or more importers) — and as duty-free shops (Section 68(1)(b): warehousing and sale of goods without payment of duty). The private/public distinction was substituted by Act 1 of 2018. A warehouse may only be appointed at a place appointed a warehousing port under Section 14(1)(c). Section 68(2) lets the Commissioner determine the kinds of goods that may be warehoused. Section 68(3) allows separate licensing of a bulk storage tank, a set of interconnected tanks, or a secured store/shed; Section 68(4) treats a fenced or walled enclosure as a warehouse only if it secures both the goods and the duties. Section 68(5): every licence expires on 31 December each year. Section 68(6): the Commissioner may cancel or refuse to renew for breach of bond or Act. Section 68(7): a licence may be transferred from one warehouse to another in the same person's possession, but is not transferable between persons.

• Section 69 — General bond of the proprietor or occupier. The keeper must give general security by bond, with sufficient surety to the satisfaction of the Commissioner, for compliance with the Act and payment of the full duties on all goods that may at any time be warehoused, and for their removal to another warehouse, port or destination outside Zimbabwe under prescribed conditions. Section 69(2) sets the mandatory bond conditions: (a) safe deposit of goods entered for warehousing; and (b) no goods removed for consumption, exportation or removal in bond except on an officer's written order after entry — except goods sold from a duty-free shop. Section 69(3): the Commissioner may at any time alter the form or amount of the security. This is the general warehouse bond we first met in the Registration and the Refunds-Bonds lessons.

• Section 70 — Storing of goods without payment of duty. The benefit-conferring section. 70(1): the importer of dutiable goods may warehouse them without payment of duty on first importation — except anti-dumping duty, provisional anti-dumping charge or countervailing duty, and except duty on goods lost or diminished in transit to the warehouse. 70(2): goods may be warehoused, before duty is paid, in a place other than a licensed warehouse if the Commissioner approves it and security is furnished. 70(3): a manufacturer of excisable/surtax goods may warehouse them before excise or surtax is paid. 70(4): before warehousing, the importer must satisfy the officer that the keeper is willing and able to store the goods and that the Section 69 bond covers them. 70(5) (inserted by Act 5 of 2009): in this section "duty" includes any import tax payable under the VAT Act [Chapter 23:12] — i.e. import VAT is deferred with the duty.

• Section 71 — Removal of goods from warehouse. 71(1): no warehoused goods may be taken or delivered except in accordance with the regulations and upon entry and payment of any duty due. 71(1a) (inserted by Act 22 of 2001): unlawful removal is an offence — fine up to level 12 or three times the duty-paid value, whichever is greater, or up to 5 years' imprisonment, or both. 71(2): duty on goods delivered for consumption is paid on the quantities and values accepted at the time of entry for warehousing. 71(3): entry/duty are not required for certain wet-goods manipulations (regauging, racking, blending, bottling, etc.) where the goods are returned to the warehouse, nor where goods are released as stores (Section 72) or taken for re-warehousing, removal or export in bond. 71(4): if the quantity is less than entered, duty is paid on the deficiency, with prescribed allowances for wet goods, bulk oil, and petroleum spirit where loss was not wilful or negligent; an unexplained deficiency is deemed to be removal without entry. 71(5): a manipulation/manufacturing area may be treated as a warehouse for deficiency purposes.

• Section 72 — Bonded goods as stores for aircraft or ships. An officer may release warehoused goods free of duty as stores for a ship or aircraft (not on a domestic leg).

• Section 73 — Bonded goods sold from a duty-free shop. The keeper may sell goods free of duty to prescribed classes of persons under prescribed conditions; removal is otherwise barred.

• Section 74 — Clearance in terms of bond. All warehoused or re-warehoused goods must be duly cleared for consumption, export or removal in bond according to the bond's conditions.

• Section 75 — Liability to duty at the date of entry for consumption. Goods deposited without payment of duty are, on being entered for consumption, subject to the rate of duty in force at the time of being so entered. This is the rate-setting rule and the single most examinable point in the module.

• Section 76 — When warehoused goods must be cleared. 76(1): imported goods warehoused under Section 70 for two years must be entered for export in bond and exported, or entered for consumption and delivered — except bulk oil and petroleum/shale/coal-tar spirits in storage tanks. 76(2): if not so entered, the Commissioner may sell them, applying proceeds to duty first, then warehouse rent and State charges, balance to the owner; if they fetch too little, they may be destroyed or appropriated to the State without compensation.

• Section 77 — Sorting, repacking or destroying under customs authority. Permits, under safeguards, sorting/separating/repacking and preservation, destruction of separated parts (without prejudice to duty on the rest), and assembly, blending, mixing, conversion or manufacture in bond — provided the finished product is not itself liable to excise/surtax, and that duty is paid on dutiable materials used, valued as at warehousing.

• Section 78 — Transfer of ownership. The owner may transfer ownership of warehoused goods to a person who may lawfully own them; the Commissioner may refuse to recognise a transfer unless written notice was given before it.

• Section 79 — Warehouses may be locked by an officer. An officer may lock any bonded warehouse with a customs lock; during that time no one may remove or break the lock or enter or remove goods without permission. The penalty for breaching this is Section 179.

• Section 80 — Taking stock and duty on deficiencies. An officer may take stock at any time; duty on deficiencies is paid under Section 71(4).

• Section 81 — Sampling. An officer may permit the owner/importer to take samples, deferring duty on the samples until the consignment is entered for consumption or removal/export in bond; the Commissioner may remit duty on samples.

• Section 82 — Remittal of duty on warehoused goods destroyed, etc. 82(1): where goods are accidentally lost or destroyed (without going into consumption) in or in transit to/from the warehouse, and every reasonable precaution was taken, the Commissioner shall remit the duty. 82(2): the Commissioner shall remit duty on warehoused goods destroyed by the owner under an officer's supervision with consent, or given up to the State in whole packages to avoid duty (abandonment).

• Section 83 — Removal of goods in bond to another port or territory. Instead of paying duty or warehousing, an importer may remove goods in bond within Zimbabwe or export them in bond by giving a bond with sufficient surety for the duties (unless evidence of removal/export is produced in time) or a cash deposit of not less than the duty. This is the RIB/RIT bridge to the next module.

• Section 84 — Responsibility for goods. The State is not liable for any loss or damage to warehoused goods or for wrong delivery — the risk stays with the owner/keeper. Section 172 reinforces this for excisable goods in warehouses.

The subsidiary regulations — Part XI of the General Regulations 2021 (regs 71–93)

The Act sets the principles; the General Regulations 2021 set the procedure and the forms:

• Reg 71 — Appointment and licensing. Apply in writing to the proper officer with the warehouse's details and location; the officer obtains the Commissioner's interim approval, then inspects to confirm the warehouse is near a warehousing port listed in the Ports of Entry and Routes Order 2000 (SI 256 of 2000), has doors fitted for customs locks, barred and bolted windows, and is otherwise suitable; the prospective licensee then enters a bond in Form No. 125; on final approval and payment of the licence fee (reg 173, US$100), the warehouse is appointed and the licence displayed prominently.
• Reg 72 — Compulsory re-warehousing. If a licence is cancelled or not renewed, or the warehouse no longer secures the goods, the officer must have the goods removed to a properly licensed or State warehouse, unless the owner enters them for duty or exports them in bond — at the owner's expense.
• Reg 73 — Control and management. The keeper must keep a warehouse register of all receipts and deliveries with authorities, available for inspection at any time; give a Form No. 26 receipt for goods placed in the warehouse; stack goods for inspection; note date warehoused and owner; keep inflammable/dangerous goods separate; allow no naked lights, no public sale, and no opening between sunset and sunrise without permission; be responsible for locking (the Commissioner may require a customs lock); and forbid any non-officer from examining or altering packages except with permission.
• Reg 74 — Warehousing of goods. No warehousing of duty-unpaid goods except in a duly licensed warehouse; goods must be entered for warehousing (under Section 18, 75 or 76); damaged/incomplete packages may not be warehoused (with wet-goods and duty-free-shop provisos); goods must be consigned without delay and a Form No. 26 receipt signed; loss in transit to the warehouse must be reported and duty brought to account by Form No. 21; and no goods leave except on an officer's written order.
• Reg 75 — Warehousing of excisable goods. Local excisable/surtax goods are entered for warehousing on a Form No. 21 plus clearance fee (reg 175); cigarettes only in unbroken packages of ≥ 500.
• Reg 76 — Re-warehousing / removal in bond to another port. Entry on Form No. 21 + clearance fee; goods removed to another port must be entered for re-warehousing within 3 days of arrival or sent to a State warehouse.
• Regs 77–78 — Wet-goods manipulation. 24 hours' notice on Form No. 51 before regauging/racking/blending/bottling, etc.
• Reg 79 — Export in bond of warehoused goods. Entry on Form No. 21 + clearance fee; carrier authority under Section 63.
• Reg 80 — Responsibility for duty on goods removed/exported in bond. Security required: a removal-and-transit bond in Form No. 121 or an undertaking in Form No. 122 plus a cash deposit of not less than the duty; the remover/exporter is liable for the duty until evidence of safe removal/export is produced.
• Reg 81 — Marking. Containers of in-bond goods must be marked "In Bond".
• Reg 82 — Removal for consumption. Entry on Form No. 21 + payment of the duty + clearance fee; the keeper must deliver immediately unless permission to retain (>7 days needs the Commissioner's permission); errors corrected on Form No. 45 or 46.
• Reg 83 — Removal as ship/aircraft stores. Form No. 21 + clearance fee; sealed by an officer.
• Regs 85–86 — Sampling. Owner samples need written permission and a cash deposit of the duty; bulk wet goods limited to 1 litre per vessel, deducted from the warehoused quantity.
• Reg 87 — Destruction. Apply on Form No. 43 with reasons; an officer witnesses destruction and signs the certificate.
• Reg 88 — Accidental loss/destruction. Apply on Form No. 43 with an explanation; remission under Section 82(1) if the Commissioner is satisfied loss was accidental and every precaution was taken.
• Reg 89 — Abandonment. Apply on Form No. 43; goods removed to a State warehouse at the owner's expense for disposal under Section 39(2).
• Regs 90–91 — Deficiencies. General deficiencies brought to account on Form No. 21; special allowances for wet goods, spirits, wine and motor spirit (e.g. 66.67% of actual losses or 0.5% of withdrawals over 3 months, whichever is less, for bulk motor spirit) under the Second Schedule, but only where the loss was not wilful or negligent.

Fees, the State warehouse, and the VAT interface

• Reg 173 — warehouse licence fee US$100 (half if issued after 30 June); reg 174 — accounting fee US$10 per bill of entry; reg 175 — clearance fee per Form 21; reg 176 — late-payment surcharge 2% per day; reg 178 — prescribed interest 35% p.a. (Section 202); reg 177 — Section 120(3) de minimis FOB value US$20.
• Section 232 / reg 172 — the State warehouse. A State warehouse is premises the Commissioner appoints to detain goods until the Act is satisfied; rent runs (reg 172: US$2/day ≤500 kg, US$4/day ≤1 tonne, US$6/tonne/day over a tonne, US$10/day for motor vehicles), and goods not entered are auctioned under Section 39(2) after 60 days. The State warehouse is a place of detention and default, not a deferral facility the trader elects.
• VAT on importation. Import VAT is charged under Section 6(1)(b) read with Section 12 of the VAT Act [Chapter 23:12]; the value for import VAT is the customs value plus customs duty (excluding surtax) under Section 12(2); the standard rate is 15.5% from 1 January 2026. Because Section 70(5) folds import VAT into "duty" for warehousing, import VAT is deferred along with customs duty and excise while the goods sit in bond, and becomes payable on ex-bond entry for consumption at the rate then in force (Section 75). Capital-goods import VAT may be separately deferred under Section 12A.

C.1 What a bonded warehouse is, and the three species under Section 68

A bonded warehouse is, in plain terms, a State-supervised strong-room for uncustomed goods. Legally it is "a warehouse, bonded and licensed in terms of section sixty-eight, in which goods may be lodged, kept and secured without the payment of duty or until the requirements of this Act have been satisfied" (Section 1). Three features make it work: it is appointed by the Commissioner (you cannot simply declare your store a bonded warehouse — it must be inspected and licensed under reg 71); it is secured (lockable doors, barred windows, customs locks under Section 79 and reg 73(9)); and it is bonded (the keeper's Section 69 general bond stands behind the suspended duty).

Section 68 recognises three species of licensed premises, and the differences matter:

1. Private bonded warehouse (Section 68(1)(a)(i)). Holds goods imported by one private proprietor for that proprietor's own goods. A manufacturer importing raw materials, or a fuel company holding its own product in bulk tanks, runs a private bonded warehouse. The proprietor is both keeper and (usually) owner of the goods.
2. Public bonded warehouse (Section 68(1)(a)(ii)). Holds goods imported by one or more importers — a commercial warehousing business that stores other people's uncustomed goods for a fee. A clearing-and-forwarding company at Beitbridge or a logistics operator in Harare may run a public bonded warehouse, taking in many clients' consignments.
3. Duty-free shop (Section 68(1)(b)). A warehouse for the warehousing and sale of goods without payment of duty, to prescribed classes of person (departing travellers, diplomats) under Section 73. Examples are the duty-free shops at Victoria Falls and Robert Gabriel Mugabe International Airport and at Beitbridge. A duty-free shop is the one category where goods are sold straight out without the buyer first making entry and paying duty, because the duty exemption attaches to the qualifying sale itself.

Section 68(3) extends the concept beyond buildings: a single bulk storage tank, a set of interconnected tanks, or a secured store/shed can each be licensed as a separate warehouse — which is why Zimbabwe's fuel depots (e.g. the strategic fuel reserves and commercial tank farms) operate as bonded warehouses, with duty on petrol and diesel suspended until product is drawn down. Section 68(4) allows a fenced enclosure to be a warehouse only if the enclosure itself secures the goods and duties.

Distinguish all of these from the State warehouse (Section 232) and the transit shed (Section 18). The transit shed is a place appointed for the deposit of uncustomed goods pending entry — a holding area at the port, not a duty-suspension facility chosen by the trader. The State warehouse is where goods go when the trader fails to enter them (Section 39 default), when a warehouse licence is cancelled (reg 72), or when goods are abandoned (reg 89). Rent runs and a 60-day auction looms. The bonded warehouse is elective and beneficial; the State warehouse is imposed and penal.

C.2 Duty suspension — the central legal idea

The entire institution turns on Section 70(1): the importer "may warehouse [dutiable goods] … without the payment of duty on the first importation thereof". The duty is suspended, not cancelled. Three consequences flow from this and must be held together:

• The goods remain uncustomed. Until duty is paid on ex-bond entry for consumption, the goods are uncustomed goods under customs control. They cannot be sold into the domestic market, pledged, or moved without an officer's written order (Section 69(2)(b)).
• Anti-dumping and countervailing duties are not suspended. Section 70(1) carves them out expressly: anti-dumping duty, provisional anti-dumping charge and countervailing duty are payable even on warehousing. The policy reason is that these are trade-remedy measures designed to neutralise injurious pricing at the border — deferring them would defeat their purpose. (Recall from the Origin & Preference module that anti-dumping/countervailing duties under Sections 90–93 are origin-targeted; recall from Export Drawback that they are likewise not drawback-able.)
• Import VAT travels with the duty. By Section 70(5), "duty" in Section 70 includes import VAT, so the 15.5% import VAT is suspended along with customs duty, surtax and excise. This is a major cash-flow benefit — on a large consignment the suspended VAT alone can exceed the customs duty.

C.3 The rate-setting rule — Section 75 and the "bet on the tariff"

Here is the rule that catches the unwary. Under Section 71(2), the quantities and values on which duty is computed are those accepted at the time of entry for warehousing — the VDP is locked in when the goods go into bond. But under Section 75, the rate of duty is the rate in force at the time the goods are entered for consumption — i.e. when they come out of bond. The value is fixed at entry-in; the rate floats to entry-out.

The practical effect is that warehousing is a position on future tariff changes:

• If, between warehousing and ex-bond clearance, the Tariff Notice raises the rate on the tariff line, the importer pays the higher rate on the value locked in at warehousing — a loss relative to having cleared for home consumption immediately.
• If the rate is lowered (a Finance Act concession, a new preferential margin, a suspension), the importer pays the lower rate — a gain.
• If a rebate or suspension comes into force while the goods are in bond, the importer can clear ex-bond under that relief.

This is why sophisticated importers watch the annual Tariff Notice and Finance Act cycle when timing ex-bond withdrawals, and why an examiner loves to ask: "Goods were warehoused in March when the rate was 25%; the rate rose to 40% in the January Finance Act; the importer clears for consumption in February. What rate applies?" — Answer: 40%, on the value declared at warehousing (Section 75 read with Section 71(2)).

C.4 The two-year clock and the bulk-liquids exception (Section 76)

Warehousing is deferral, not indefinite storage. Section 76(1) requires imported goods warehoused under Section 70 to be entered for export in bond and exported, or entered for consumption and removed, within two years. The exceptions are oil in bulk storage tanks and petrol or other petroleum/shale/coal-tar spirit in bulk storage tanks — recognising that strategic fuel reserves are held long-term by their nature. If the deadline passes and the goods are not entered, Section 76(2) lets the Commissioner sell them, applying the proceeds first to duty, then to warehouse rent and State charges, with any balance to the owner; and if they cannot raise enough, destroy them or appropriate them to the State without compensation. Two years is generous, but it is a hard limit for general merchandise, and overstaying is one of the commonest — and most expensive — warehousing failures (see § H).

C.5 Manipulation and manufacturing under bond (Section 77)

A bonded warehouse is not necessarily a place of pure storage. Section 77 lets the Commissioner permit, under safeguards: sorting, separating, packing or repacking for preservation, sale, export or lawful disposal (and, for wines and spirits, bottling from bulk or breaking down strengths); destruction of separated parts without prejudice to duty on the remainder; and — importantly — assembly, blending, mixing, conversion or manufacture in bond of goods wholly or partly of dutiable material. Two provisos discipline this: (i) it does not apply where the finished product would itself be liable to excise or surtax (excisable manufacture is licensed separately under Sections 128–129); and (ii) when the finished product is entered for consumption, duty is paid on the dutiable material used, valued as at warehousing. "Manufacturing under bond" is the legal basis on which, for example, a firm might import components, assemble them in a bonded facility, and re-export the finished article in bond — paying Zimbabwean duty only on whatever is eventually entered for home consumption.

C.6 Deficiencies, allowances and the deeming rule (Section 71(4), regs 90–91)

Because a warehouse is full of uncustomed goods under a private keeper's control, the Act polices stock integrity tightly. If, on stock-taking (Section 80) or on delivery, the quantity is less than was entered for warehousing, duty is payable on the deficiency (Section 71(4)). For wet goods, bulk oil and petroleum spirit, the officer may make prescribed allowances for natural loss (evaporation, regauging variance) — but only where satisfied the loss was neither wilful nor negligent. Regulation 91 sets the specific maxima — for instance, for bulk motor spirit, an allowance of 66.67% of actual losses during a 3-month period or 0.5% of withdrawals during that period, whichever is less; for ale, beer, spirits and wine in wood, the Second Schedule scales. Beyond the allowance, duty is brought to account on Form No. 21 (reg 90). Most pointed is the deeming rule in Section 71(4) proviso (iii): an unexplained deficiency above the allowance is, in the absence of proof to the contrary, deemed to have come about by removal from the warehouse without entry — i.e. presumed to be an unlawful, dutiable (and potentially criminal) removal. The burden flips to the keeper.

C.7 Control, locks, transfer, samples, destruction and remission

• Control and locking. The keeper keeps a register (reg 73), issues Form No. 26 receipts, stacks goods for inspection, keeps dangerous goods apart, and may be required to fit a customs lock. An officer may lock the warehouse under Section 79; breaking that lock or removing goods without permission is the Section 179 offence (level 12 / 3× DPV / 5 years).
• Transfer of ownership (Section 78). Warehoused goods may change owner on prior written notice to the Commissioner — useful where goods are sold while still in bond (the buyer later clears them ex-bond).
• Sampling (Section 81, regs 85–86). Owners may take samples with written permission and a cash deposit of the duty; duty on samples is deferred or remitted.
• Accidental loss, destruction, abandonment (Section 82, regs 87–89). If goods are accidentally lost or destroyed without going into consumption and every reasonable precaution was taken, the Commissioner shall remit the duty (Section 82(1), Form 43). Goods may be destroyed under supervision with consent, or abandoned to the State in whole packages, with remission (Section 82(2)). This is the warehousing limb of the remission relief studied in the Refunds, Remissions & Bonds module, and it sits alongside Section 126 (accidental loss before removal from customs control generally).

C.8 The bridge to removal in bond (Section 83) and re-warehousing

Section 83 is the pivot to the next module. Instead of paying duty or depositing goods in a warehouse, an importer may remove the goods in bond to another Zimbabwean port, or export them in bond, by giving a bond with sufficient surety for the duties (discharged on proof of removal/export) or a cash deposit of not less than the duty. The procedure and security are set by regs 27–28, 80–81 and 148: a removal-and-transit bond in Form No. 121, or a Form No. 122 undertaking plus deposit; containers marked "In Bond"; goods entered at destination within the prescribed time (10 days under reg 27(2), or 3 days for re-warehousing under reg 76(4)). Re-warehousing — moving goods from one bonded warehouse to another — is itself a removal in bond (Section 71(3)(b)(ii), reg 76), and the receiving keeper signs a fresh Form No. 26. We develop RIB, RIT and the T1 fully in the Deferred Clearances lesson; here it is enough to see that warehousing and removal-in-bond are the two faces of duty suspension — static (held in a warehouse) and dynamic (moving under bond).

C.9 Special goods — wet goods, fuel, cigarettes and vehicles

• Wet goods (potable liquor over 1.7% absolute alcohol) attract the most detailed controls — regauging on Form No. 51, manipulation under Sections 77–78, the deficiency allowances of reg 91, and the cask-marking rules of reg 92.
• Bulk fuel in storage tanks is warehoused under Section 68(3), is exempt from the two-year limit (Section 76(1) proviso), and carries the specific motor-spirit loss allowance of reg 91(3)(d).
• Cigarettes may be warehoused only in unbroken packages of ≥ 500 (reg 75(4)).
• Imported vehicles are normally registered at entry (Section 49A), but vehicles warehoused under Section 70 are registered when taken out of the warehouse under Section 71 (Section 49A proviso) — a frequently-missed step when clearing a bonded vehicle for consumption.

This section traces three procedures end to end: (D.1) licensing and bonding a warehouse; (D.2) entering goods into bond; and (D.3) clearing goods out of bond. Each uses the Form No. 21 bill of entry and an appropriate Customs Procedure Code (CPC) in ASYCUDA World.

D.1 Licensing and bonding a bonded warehouse (reg 71)

1. Apply in writing to the proper officer at the warehousing port, giving the warehouse's details and location (reg 71(1)).
2. The officer seeks the Commissioner's interim approval, then inspects to confirm the warehouse is near a warehousing port listed in SI 256 of 2000, has doors fitted for customs and licensee locks, barred, bolted and clinched windows, and is otherwise suitable (reg 71(2)).
3. On a satisfactory inspection the officer issues a certificate and calls on the applicant to enter a general bond in Form No. 125 with sufficient surety for the full duties on all goods to be warehoused (Section 69; reg 71(2)).
4. The bond and certificate go to the Commissioner; on final approval and payment of the US$100 licence fee (reg 173), the warehouse is appointed by Gazette notice and a licence issued, to be displayed prominently (reg 71(3)–(4)).
5. The licence expires on 31 December (Section 68(5)) and must be renewed annually; breach can lead to cancellation or non-renewal (Section 68(6)), triggering compulsory removal of the goods (reg 72).

D.2 Entering goods into bond — the warehousing entry

1. On arrival, the importer (or licensed clearing agent) reports the goods (Sections 24–32, as covered in the Documentation module) and elects the warehousing procedure rather than home consumption.
2. Lodge a Form No. 21 bill of entry in ASYCUDA World under a warehousing CPC (the CPC tells the system the goods are entered for warehousing, so duty/VAT are assessed but suspended, not collected). Attach the commercial invoice, packing list, Bill of Lading or Air Waybill, value declaration (Form 52A/53A where required), and Certificate of Origin where preference is in view.
3. Risk targeting routes the declaration to a lane — Green (release without intervention), Yellow (documentary check) or Red (physical examination). For warehousing entries, examination at the point of warehousing confirms the quantities and values that will govern duty at consumption (Section 71(2)).
4. Before warehousing, the officer must be satisfied the keeper is willing and able to store the goods and that the Section 69 bond covers them (Section 70(4)).
5. The goods are consigned without delay to the named warehouse; the keeper signs a Form No. 26 receipt and records the consignment in the warehouse register with the date warehoused and owner's name (reg 73–74). Any transit loss is reported and brought to duty on Form 21 (reg 74(6)).
6. The goods now sit in bond, duty (incl. 15.5% VAT) suspended, the two-year clock running (except bulk liquids).

D.3 Clearing goods out of bond

The exit route depends on the destination of the goods. In each case a Form No. 21 is lodged and the clearance fee (reg 175) paid.

• (a) For home consumption (reg 82). Lodge a Form No. 21 ex-bond entry, pay the duty — computed on the values accepted at warehousing (Section 71(2)) at the rate in force now (Section 75), plus surtax, excise and 15.5% import VAT as applicable — and the clearance fee. The officer authorises delivery; the keeper must deliver immediately (retention beyond 7 days needs the Commissioner's permission). Errors are corrected on Form No. 45 or 46. A bonded vehicle is registered at this point (Section 49A proviso).
• (b) For re-warehousing / removal in bond to another port (reg 76). Lodge a Form No. 21; goods moved to another port must be entered for re-warehousing within 3 days of arrival or go to a State warehouse. Security under reg 80 (Form 121 bond / Form 122 undertaking + deposit).
• (c) For export in bond (reg 79). Lodge a Form No. 21; the officer authorises the carrier under Section 63; security under reg 80; no duty is paid because the goods leave Zimbabwe (Section 71(3)(b)(ii)). Containers marked "In Bond" (reg 81).
• (d) As ship/aircraft stores (reg 83, Section 72). Form No. 21; goods sealed by an officer; free of duty.
• (e) Deficiency write-off (regs 90–91). Duty on any deficiency brought to account on Form No. 21; allowable natural losses written off against Form No. 51/register.
• (f) Destruction / abandonment / accidental loss (regs 87–89, Section 82). Form No. 43 voucher; remission on the Commissioner's authority.

Throughout, the keeper's register and the officer's stock-takes (Section 80) reconcile goods in against goods out + goods remaining + allowed losses. Any shortfall is a deficiency under Section 71(4), presumptively an unentered removal.

All examples use United States dollars, in which customs duty is payable (Section 115). Where an invoice is in another currency, convert at ZIMRA's Rates of Exchange for Customs Purposes for the relevant fortnight (Section 115A) and state the period. The import-VAT base is customs value + customs duty, excluding surtax (VAT Act Section 12(2)), at 15.5% (from 1 January 2026). The freight/insurance build-up uses the First Schedule deeming provisos introduced in the Valuation module (freight from RSA 5% of FOB; non-air insurance 1% of FOB). The customs-duty rate is the confirmed Tariff Notice line 6109.10.00 (cotton T-shirts) at 40% ad valorem + US$3 per kilogram (SI 203 of 2022). Surtax is excluded from these examples and flagged, because the Surtax Regulations are not in the source set.

E.1 The core benefit — deferral and pay-as-you-sell (reg 82 ex-bond entry)

Facts. A Bulawayo distributor imports 10,000 cotton T-shirts through Beitbridge from South Africa. FOB = USD 40,000; total net weight 1,500 kg. The distributor warehouses the consignment in a public bonded warehouse and later withdraws 3,000 shirts for the domestic market.

Step A — Customs Value at warehousing (locked in by Section 71(2)).

Step 1 FOB = USD 40,000.00
Step 2 + Freight (5% of FOB, RSA) = USD 2,000.00
 + Insurance (1% of FOB) = USD 400.00
 = CIF = USD 42,400.00
Step 3 First Schedule adjustments (none assumed)
 => Customs Value / VDP = USD 42,400.00 (weight 1,500 kg)

Step B — Duty assessed but suspended on warehousing (Section 70). Nothing is paid now; the figures are recorded so they can be applied on ex-bond entry.

Customs duty (whole consignment, indicative):
 ad valorem 40% x 42,400.00 = USD 16,960.00
 specific US$3 x 1,500 kg = USD 4,500.00
 = Customs duty = USD 21,460.00
Import-VAT base = 42,400.00 + 21,460.00 = USD 63,860.00
Import VAT 15.5% = USD 9,898.30
Total duty + VAT SUSPENDED in bond = USD 31,358.30

The distributor has deferred USD 31,358.30 — including USD 9,898.30 of import VAT — instead of paying it at the border.

Step C — Ex-bond entry for consumption of 3,000 shirts (30%). Value and weight apportion: Customs Value USD 12,720.00; weight 450 kg. The rate in force at this entry governs (Section 75) — here unchanged at 40% + US$3/kg.

Step 4 Customs duty:
 40% x 12,720.00 = USD 5,088.00
 US$3 x 450 kg = USD 1,350.00
 = Customs duty = USD 6,438.00
Step 5 Surtax (if listed) =
Step 6 Excise (n/a for this line) = USD 0.00
Step 7 DPV (Customs Value + duty, excl. surtax) = USD 19,158.00
Step 8 Import VAT 15.5% x 19,158.00 = USD 2,969.49
 TOTAL PAYABLE TO ZIMRA on this withdrawal = USD 9,407.49
 + clearance fee (reg 175) and US$10 accounting fee per BoE (reg 174)

The remaining 7,000 shirts stay in bond, their duty still suspended, to be cleared (and paid) as they sell — the essence of the cash-flow benefit. Contrast immediate home consumption at the border, where the whole USD 31,358.30 would have fallen due on day one.

E.2 The Section 75 trap — the rate at consumption, on the value at warehousing

Facts. The distributor warehouses the same consignment when an earlier Tariff Notice set the line at an assumed 25% + US$2/kg (illustrative historical rate). Before any withdrawal, a Finance Act / new Tariff Notice raises the line to the confirmed 40% + US$3/kg (SI 203 of 2022). The distributor then clears the whole consignment for consumption.

Value locked at warehousing (Section 71(2)) = USD 42,400.00 ; 1,500 kg
Rate applied = rate in force at consumption (Section 75) = 40% + US$3/kg (NOT 25% + US$2/kg)
 ad valorem 40% x 42,400.00 = USD 16,960.00
 specific US$3 x 1,500 kg = USD 4,500.00
 Customs duty = USD 21,460.00
Import VAT base 42,400.00 + 21,460.00 = USD 63,860.00
Import VAT 15.5% = USD 9,898.30
TOTAL = USD 31,358.30

Had the importer cleared for home consumption before the increase, duty would have been 25% x 42,400 + US$2 x 1,500 = USD 10,600 + 3,000 = USD 13,600 (plus VAT). By warehousing across a rate increase, the importer paid USD 21,460 in duty — USD 7,860 more. Section 75 cuts both ways: a rate cut during storage would have produced a saving. Warehousing is therefore a deliberate position on the tariff cycle, not a neutral parking bay.

E.3 Duty on a deficiency, and the deeming rule (Section 71(4), regs 90–91)

Facts. On an officer's stock-take (Section 80) the warehouse holds 9,920 of the 10,000 warehoused shirts — an 80-shirt deficiency. T-shirts are dry goods, so no natural-loss allowance applies (allowances are for wet goods, bulk oil and motor spirit only). Duty must be brought to account on the deficiency (reg 90), valued and weighted pro rata: Customs Value USD 339.20 (80 × USD 4.24); weight 12 kg.

Customs duty on deficiency:
 40% x 339.20 = USD 135.68
 US$3 x 12 kg = USD 36.00
 = Customs duty = USD 171.68
Import VAT base 339.20 + 171.68 = USD 510.88
Import VAT 15.5% = USD 79.19
TOTAL duty + VAT on deficiency = USD 250.87

Beyond the money, Section 71(4) proviso (iii) bites: the unexplained deficiency is deemed to be a removal from the warehouse without entry unless the keeper proves otherwise — exposing the keeper to the Section 71(1a) offence (level 12 / 3× duty-paid value / 5 years) and a call on the Section 69 bond, not merely the assessed duty.

E.4 Sizing the Section 69 general bond

Facts. A public bonded warehouse expects to hold up to USD 200,000 of customs value of general dutiable goods (assume an average effective duty rate of 40% and no surtax/excise) at any one time. The Section 69 bond must secure the full duties — including import VAT — on all goods that may at any time be warehoused.

Peak customs value held = USD 200,000.00
Indicative customs duty (40%) = USD 80,000.00
Import-VAT base = 200,000 + 80,000 = USD 280,000.00
Import VAT 15.5% = USD 43,400.00
Full duties to be secured (duty + import VAT) = USD 123,400.00

The bond's penal sum must be set to cover at least this peak exposure (the Commissioner may require a margin and may alter the amount at any time under Section 69(3)). Note that import VAT is part of the secured "duty" by virtue of Section 70(5) — a keeper who sizes the bond on customs duty alone under-secures by USD 43,400. This is the most common bond-sizing error in practice (see § H).

E.5 Re-export in bond — paying nothing to Zimbabwe

Facts. The distributor decides the remaining 7,000 shirts are surplus to the Zimbabwean market and re-exports them in bond to Zambia (reg 79). Because the goods are entered for export in bond and leave Zimbabwe, no Zimbabwean duty or import VAT is paid (Section 71(3)(b)(ii)); the only obligations are the clearance fee, the Form 121 removal-and-transit bond / Form 122 undertaking (reg 80), and proof of export to discharge the bond. The USD 21,945 of duty and VAT that would have applied to those 7,000 shirts on home consumption is never triggered — the clearest illustration of warehousing's strategic value for regional distribution.

Individual travellers. Bonded warehousing is largely irrelevant to travellers, who clear personal effects under the Travellers' Rebate (Second Schedule) on a Form 49 / PCW at the border. The one traveller-facing touchpoint is the duty-free shop (Section 68(1)(b), Section 73): a departing or arriving traveller at Victoria Falls or RGM International Airport buys liquor, perfume and tobacco free of duty because the goods are sold straight from a bonded duty-free shop to a qualifying class of person.

Small cross-border traders. Most small traders clear immediately for home consumption and do not run bonded warehouses (the licence fee, bond and recordkeeping outweigh the benefit for low volumes). They encounter the regime indirectly — for example when buying ex-bond stock from a larger importer, or when their goods end up in a State warehouse after a failed entry (rent and the 60-day auction clock).

SMEs. Bonded warehousing becomes attractive for SMEs with lumpy import patterns or high duty exposure: a vehicle dealer importing a batch of cars can warehouse them and clear one at a time as each is sold (registering each under the Section 49A proviso on ex-bond entry); a fuel retailer drawing from a licensed bulk tank (Section 68(3)) defers duty until product is pumped out; a manufacturer can import inputs into a private bonded warehouse and manufacture under bond (Section 77) for re-export. The cash-flow relief — especially the deferred 15.5% import VAT — can be the difference between a viable and an unviable import.

Large corporates. This is where the regime is most used. Fuel companies hold strategic and commercial stock in bonded tank farms, exempt from the two-year limit (Section 76 proviso). Mining houses warehouse heavy equipment and spares, clearing as projects draw them down. Supermarket chains and FMCG distributors run public bonded warehouses in Harare and Bulawayo as regional distribution hubs, clearing into Zimbabwe piecemeal and re-exporting in bond to neighbouring markets. Manufacturers assemble or blend under bond. For all of these, the Section 69 bond is a standing facility (often backed by a bank or insurance surety), the CPC discipline in ASYCUDA is routine, and post-clearance audit of the warehouse register is a fact of life.

Zimbabwean reported customs litigation is dominated by classification, valuation and origin disputes; the warehousing provisions of Part VII are, in the main, administered rather than litigated, because they are mechanical (license, bond, enter, account) and breaches are dealt with by assessment, bond call, forfeiture and the Section 71/Section 179 offences rather than by contested appeals. Where disputes do reach the Fiscal Appeal Court [Chapter 23:05] they typically concern whether a deficiency was accidental (Section 82) or negligent (Section 71(4)), or the quantum of a bond call — fact-driven questions decided on the documentary record (register, stock-take, Form 43 vouchers) rather than on novel points of law.

Two persuasive, non-binding strands of authority illuminate the principles:

• Strict construction of bonds and sureties (non-binding, South African and English commercial authority). A customs bond is a suretyship: the surety's liability is co-extensive with the principal's but limited to the bond's penal sum and conditions. South African and English authorities on suretyship (applied persuasively, not as binding precedent in Zimbabwe) hold that a guarantee is construed strictly in favour of the surety, so a bond that under-states the secured amount (e.g. omits import VAT) leaves the revenue unsecured for the shortfall. The lesson for practice (§ E.4) is to size the Section 69 bond to the full duties including the 15.5% import VAT that Section 70(5) brings within "duty".

• Strict construction of duty-suspension and relief provisions (non-binding). Just as reliefs are construed strictly against the claimant (the principle met in the Rebates and Drawback modules), a duty-suspension regime like warehousing is available only on its exact statutory terms: goods must be genuinely entered for warehousing, kept in a licensed warehouse, and removed only on entry and an officer's order. A removal outside those terms is not a benign technicality — it is an unentered removal (Section 71(4) deeming) and an offence (Section 71(1a)).

Where no on-point Zimbabwean authority exists, the safe position is that Part VII is governed by the statute and the General Regulations themselves, read with the WCO Revised Kyoto Convention (RKC), Specific Annex D (Customs Warehouses and Free Zones), which sets the international template for warehousing that Zimbabwe's regime mirrors. No case should be cited that cannot be verified.

1. Overstaying the two-year limit (Section 76). General merchandise left in bond beyond two years can be sold, destroyed or appropriated to the State without compensation. Keepers must diarise the warehousing date (reg 73(4)) and clear or re-export before the deadline. Bulk fuel is the only common exception.
2. Removal without entry / breaking customs locks. Taking goods from a warehouse without entry and an officer's written order (Section 69(2)(b), Section 71(1)) — or breaking a customs lock (Section 79) — is the Section 71(1a) / Section 179 offence: a fine of level 12 or 3× the duty-paid value, whichever is greater, or 5 years' imprisonment. "Borrowing" stock to meet an urgent order before clearing it is a criminal removal, not a paperwork lag.
3. Treating a deficiency as harmless shrinkage. Any quantity shortfall above the prescribed allowance is dutiable (Section 71(4)) and deemed an unentered removal unless explained — flipping the burden onto the keeper and exposing the Section 69 bond. Allowances exist only for wet goods, bulk oil and motor spirit, and only for non-negligent loss.
4. Under-sizing the Section 69 bond. Sizing the bond on customs duty alone ignores that Section 70(5) folds the 15.5% import VAT into the secured "duty" — leaving the revenue unsecured for a large slice (§ E.4). It also ignores excise and surtax where applicable.
5. Assuming the rate is fixed at warehousing. Importers who budget duty at the warehousing-date rate are caught by Section 75 when the rate rises before ex-bond clearance (§ E.2). Watch the Tariff Notice / Finance Act cycle when timing withdrawals.
6. Mixing dangerous or incompatible goods (reg 73(5)). Storing inflammable or damage-prone goods with general merchandise breaches the control conditions and can trigger cancellation of the licence (Section 68(6)) and compulsory removal (reg 72).
7. Duty-free-shop abuse. Selling duty-free goods outside the prescribed classes/conditions (Section 73) — e.g. to non-travellers — is an unlawful diversion of uncustomed goods, attracting forfeiture and penalties.
8. Forgetting to register a bonded vehicle on ex-bond entry. Imported vehicles warehoused under Section 70 are registered when taken out under Section 71 (Section 49A proviso), not at importation — a step routinely missed, leaving the cleared vehicle unregistrable until rectified.
9. Late or missing re-warehousing entry. Goods removed in bond to another port must be entered for re-warehousing within 3 days (reg 76(4)) or they go to a State warehouse (rent + Section 39 auction).
10. Poor register discipline. A register that does not reconcile goods in = goods out + on hand + allowed losses is the first thing a post-clearance audit finds; gaps are presumed unentered removals (Section 71(4)) and feed ZIMRA's risk profile of the keeper.

Work through the questions one at a time. Choose an answer and it is graded immediately, with an explanation and the provision it comes from. Your progress is saved, so you can stop and resume.

• A bonded warehouse (Section 68, def. in Section 1) lets dutiable imports and locally manufactured excisable goods be stored without payment of duty until entered for consumption, export or removal in bond — deferral, not forgiveness of the duty.
• The regime stands on three pillars: Section 68 licensing (private / public / duty-free shop, at a warehousing port under Section 14(1)(c) / SI 256 of 2000); the keeper's Section 69 general bond with sufficient surety for the full duties; and the Section 70 benefit, with Section 70(5) folding import VAT into "duty" so the 15.5% VAT is deferred too.
• Value is locked at warehousing (Section 71(2)); the rate floats to ex-bond consumption (Section 75). Warehousing is therefore a deliberate position on the tariff cycle.
• Two-year limit (Section 76) for general goods (bulk fuel exempt); overstaying risks sale, destruction or appropriation without compensation.
• Removal only on entry and an officer's order (Section 69(2)(b), Section 71(1)); unlawful removal or breaking customs locks (Section 79) is the Section 71(1a)/Section 179 offence (level 12 / 3× DPV / 5 years).
• Deficiencies are dutiable (Section 71(4)), with allowances only for wet goods, bulk oil and motor spirit (reg 91), and an unexplained shortfall is deemed an unentered removal.
• Manufacturing/manipulation under bond is permitted under Section 77 (not for excisable finished goods); accidental loss, destruction and abandonment attract remission under Section 82 (Form 43).
• Procedurally everything runs on the Form No. 21 bill of entry and the right ASYCUDA CPC: reg 71 licensing (Form 125 bond), regs 74–75 warehousing-in (Form 26 receipt), reg 82 ex-bond for consumption, reg 76 re-warehousing, regs 79–81 export/removal in bond (Form 121/122).
• Section 83 removal in bond is the bridge to the next module, Deferred Clearances (RIB, RIT, T1) — duty suspension in motion rather than at rest.
• Strategically, bonded warehousing underpins Zimbabwe's ambition as a regional distribution and trade-facilitation hub (WCO RKC Specific Annex D), letting traders hold and re-export regional stock without ever triggering Zimbabwean home-consumption duty — while the State warehouse (Section 232) remains the penal counterpart for goods that fall out of compliance.

Table 1 — Warehouse types and the State warehouse compared

Table 2 — Forms and Customs Procedure Codes for the warehousing lifecycle

Diagram 1 — The bonded-warehouse lifecycle (duty suspended, then resolved)

flowchart TD
 A[Goods imported and reported] --> B{Importer elects procedure}
 B -->|Home consumption| C[Pay duty surtax excise VAT now]
 B -->|Warehousing| D[Lodge Form 21 warehousing CPC in ASYCUDA]
 D --> E{Risk lane}
 E -->|Green| F[Release to bond]
 E -->|Yellow| G[Document check]
 E -->|Red| H[Physical examination]
 G --> F
 H --> F
 F --> I[Keeper signs Form 26 and records in register]
 I --> J[Goods in bond - duty and 15.5pct VAT SUSPENDED]
 J --> K{Exit within 2 years}
 K -->|Consumption| L[Form 21 ex-bond - pay duty at current rate s75]
 K -->|Export in bond| M[Form 21 plus Form 121 bond - no duty - mark In Bond]
 K -->|Re-warehouse / RIB| N[Form 21 plus security - enter at new port in 3 days]
 K -->|Lost or destroyed| O[Form 43 - remission s82]
 K -->|Overstay 2 years| P[s76 sale destruction or appropriation]
 L --> Q[Release - register vehicle if applicable - PCA window]
 M --> Q
 N --> Q

Statutes & sections — Customs and Excise Act [Chapter 23:02] - Section 1 — definitions of "warehouse", "State warehouse", "transit shed", "uncustomed goods". - Section 14(1)(c) — appointment of warehousing ports (read with SI 256 of 2000, Ports of Entry and Routes Order). - Section 49A (proviso) — imported vehicles warehoused under Section 70 registered on removal under Section 71. - Section 68 — appointment and licensing of private/public bonded warehouses and duty-free shops; kinds of goods; bulk tanks; 31 Dec expiry; cancellation; transfer. - Section 69 — general bond of the warehouse keeper; mandatory conditions; alteration of amount. - Section 70 — storing without payment of duty; anti-dumping/countervailing carve-out; Section 70(5) import VAT included in "duty". - Section 71 — removal from warehouse; offence (71(1a)); value at warehousing (71(2)); manipulation/stores/export exceptions (71(3)); deficiencies and deeming (71(4)). - Section 72 — bonded goods as ship/aircraft stores. - Section 73 — duty-free shop sales. - Section 74 — clearance in terms of bond. - Section 75 — rate of duty at date of entry for consumption. - Section 76 — two-year limit; bulk-liquids exception; sale/destruction/appropriation. - Section 77 — sorting, repacking, manufacture in bond under safeguards. - Section 78 — transfer of ownership of warehoused goods. - Section 79 — customs locks on warehouses. - Section 80 — stock-taking and duty on deficiencies. - Section 81 — sampling of warehoused goods. - Section 82 — remission on accidental loss/destruction/abandonment. - Section 83 — removal in bond to another port or for export (bridge to Deferred Clearances). - Section 84 / Section 172 — State not liable for loss of warehoused / excisable goods. - Section 115 / Section 115A — duty payable in USD; exchange at customs rate at date of entry. - Section 179 — offence of removing/breaking customs locks or removing goods without permission. - Section 232 — the State warehouse (detention, rent, Section 39 auction). - VAT Act [Chapter 23:12], Section 6(1)(b) read with Section 12 (esp. Section 12(2)) and Section 12A — VAT on importation; base = customs value + duty excluding surtax; 15.5% from 1 January 2026; capital-goods deferment.

Regulations & Statutory Instruments - Customs and Excise General Regulations 2021, Part XI, regs 71–93 — licensing (71), compulsory re-warehousing (72), control/management & register (73), warehousing of goods (74), excisable goods (75), re-warehousing/RIB (76), wet-goods manipulation (77–78), export in bond (79), security & marking (80–81), removal for consumption (82), stores (83), spirits under rebate (84), sampling (85–86), destruction (87), accidental loss (88), abandonment (89), deficiencies (90–91), cask marking (92), goods unaccounted for (93). - General Regulations 2021, regs 27–28, 148 — removal in bond on first importation and within Zimbabwe; Form 121 / Form 122 security. - General Regulations 2021, reg 172 — State-warehouse rent; reg 173 licence fee US$100; reg 174 accounting fee US$10; reg 175 clearance fee; reg 176 2%/day surcharge; reg 177 Section 120(3) de minimis FOB US$20; reg 178 interest 35% p.a. - SI 256 of 2000 — Customs and Excise (Ports of Entry and Routes) Order (warehousing ports). - SI 203 of 2022 — Customs and Excise (Tariff) Notice / 2022 Tariff Handbook (line 6109.10.00, 40% + US$3/kg, used in worked examples).

International instruments - WCO Revised Kyoto Convention (RKC), Specific Annex D — Customs Warehouses and Free Zones (international template for the warehousing regime). - WTO Trade Facilitation Agreement (TFA) — release, deferral and guarantee facilitation principles.

Case law - No on-point Zimbabwean warehousing decision is asserted (none confirmed in the source set); Part VII is governed by the statute and General Regulations. Persuasive, non-binding South African/English suretyship principles inform bond construction (§ G). `

ZIMRA guidance - ZIMRA Customs Procedure Code (CPC) schedule for warehousing/ex-warehouse/export-in-bond regimes . - ZIMRA Rates of Exchange for Customs Purposes (fortnightly) for non-USD invoice conversion (Section 115A). - ZIMRA Public Notices on bonded-warehouse licensing, duty-free shops and fees.

Continuity: builds on Customs Registration (Section 69 bond, keeper licence), Documentation & Bills of Entry (Form 21, reporting), Tariff Classification (compound rate, line 6109.10.00), Customs Valuation (VDP locked at warehousing, freight/insurance build-up, Section 12(2) VAT base), Origin & Preference (rate vs base; anti-dumping not suspended), Duty Computation (the FOB→CIF→VDP→duty→VAT cascade), Rebates and Refunds, Remissions & Bonds (Section 82 remission; bond mechanics), and Export Drawback (re-export economics). Leads into Deferred Clearances (RIB, RIT, T1), ASYCUDA World, Temporary Imports & ATA Carnets, and Free Trade Zones & SEZs.