CBW Goods Transfer Compliance Rules

The Memorandum directs compliance in line with CMO No. 39-91, which implements CAO No. 2-91.
The Memorandum states that the improper practice conflicts with the CMO No. 39-91 rules on the establishment, supervision, and control of Customs Bonded Warehouses.
The Memorandum frames “Accredited Subcontractors” and other accredited users as transfer recipients from CBWs operating under Section 105 of the TCCP.
The Memorandum directs action to Operating Divisions and to Customs Warehouseman functions under the CBW control mechanisms.

The Memorandum requires operational controls that safeguard against misdeclaration and over quantity in the farming out of raw materials or goods.
The Memorandum requires controls that support the expeditious monitoring of imports.
The Memorandum treats the previously practiced “certify based solely on requisition slips/withdrawal permits/authorities submitted simultaneously with warehousing entries” approach as ineffective and contrary to CBW control requirements.
The Memorandum mandates corrective measures that restore verification before transfer.

Transfer rules apply to CBWs operating under Section 105 of the TCCP.
Transfers are governed when goods or raw materials are intended for Accredited Subcontractors.
Transfers are governed when goods or raw materials are intended for Accredited Members of Common Bonded Warehouse and Special Economic Zone Locators.
The Memorandum treats goods transfer from CBW to accredited parties as the triggering compliance point requiring the listed conditions.

All importations must be physically transferred and deposited to the Customs Bonded Warehouse in accordance with the pertinent provisions of CMO No. 39-91 implementing CAO No. 2-91.
Transfer from a CBW to accredited subcontractors and accredited members of common bonded warehouses and locators under Section 105 of the TCCP must follow the listed conditions before transfer is allowed.
The Memorandum prohibits allowing transfer based only on requisition slips/withdrawal permits/authorities that are filed and approved simultaneously with warehousing entries without required verification by the Customs Warehouseman.

A Warehousing Entry must be filed before transfer is allowed.
Upon submission of the formula of manufacture, the stages to be subcontracted must, whenever practicable, be specified.
The Customs Warehouseman must certify the description and quantity of the goods sought to be transferred.
The transfer must be covered by a corresponding boatnote/withdrawal permit/authority to withdraw.
The Customs Warehouseman must record the transfer in a logbook.
For garment manufacturers, only pre-cut or cut-to-pattern materials may be transferred unless otherwise approved by GTEB.

Operating Divisions must stop approving requisition slips/withdrawal permits/authorities in a way that enables direct transfer from the piers to accredited subcontractors and locators without previous transfer and/or storage at the operator’s warehouse.
Customs Warehouseman certifications must follow the verification and certification mandate tied to the identification and determination of the exact description and quantity of goods before transfer.
Transfers are permitted only after completing all conditions, and the corresponding documentation must be properly issued and logged.
The Memorandum applies through immediate and strict compliance for CBW transfer operations.