Retention of title clauses (UK): when they actually work.

By the Administrator.uk editorial teamLast reviewed

A retention of title clause is a term in a supplier's standard conditions of sale that keeps legal ownership of the goods with the supplier until they have been paid for. If the customer goes into administration or liquidation while the goods are still on site, unpaid, identifiable and unmixed, the supplier can reclaim them outright. The supplier steps outside the unsecured-creditor queue (which typically recovers 1p to 3p in the pound) and recovers the physical goods themselves.

The legal foundation is section 19 of the Sale of Goods Act 1979 and the line of cases beginning with Aluminium Industrie Vaassen BV v Romalpa Aluminium Ltd [1976] 1 WLR 676. The line between a clause that works and one that fails is well-mapped: simple and all-monies clauses on unmixed goods survive; extended and proceeds clauses are generally re-characterised as unregistered charges and fail. Below: the four sub-types, the leading cases, what an administrator will require, and what to do on day one.

When your clause works, in one minute
  • Works: simple retention of title clause, properly incorporated in the contract, goods still on the customer's premises, identifiable (serial numbers, batch codes, distinctive packaging), unmixed with other materials, not yet resold to a third party.
  • Works: all-monies clause (reserves title until all sums on any account are paid), upheld by the House of Lords in Armour v Thyssen (1990). Same physical-state conditions apply.
  • Fails: goods mixed with other materials such that the supplier's goods are no longer identifiable (resin into chipboard, Borden v Scottish Timber Products, 1981).
  • Fails: goods transformed into a new product (leather into handbags, Re Peachdart, 1984).
  • Fails: clause that attempts to claim the cash proceeds of a sub-sale, unless registered as a charge under section 859A Companies Act 2006 (Compaq Computer v Abercorn, 1991).
  • Fails: clause not incorporated in the contract (the customer's purchase order was on different terms; battle of the forms went the other way).
  • Day-one move: send the administrator a retention of title claim with the clause, evidence of incorporation, the unpaid invoices and identification of the goods. The faster the claim lands, the less likely the goods are sold on as part of a going-concern sale.
The basics

What a retention of title clause does

Section 17 of the Sale of Goods Act 1979 says that property in goods passes to the buyer when the parties intend it to pass. Section 19 then allows the seller to reserve the right of disposal of the goods until conditions imposed by the seller are met. Together, these two sections allow a supplier to keep legal title until the goods are paid for, regardless of physical possession having transferred to the buyer.

In normal trading, this matters little: the buyer pays on the invoice due date, and the question of who owned the goods between delivery and payment never arises. It matters acutely on the buyer's insolvency. Without retention of title, the supplier is an unsecured creditor for the unpaid price and joins a queue that typically recovers between 1p and 3p in the pound. With a valid retention of title clause, the supplier remains the owner of the goods; the administrator's right to possess the goods does not extend to a right to sell them or treat them as part of the insolvent estate.

A retention of title clause is not a charge. It does not need to be registered at Companies House. It does not appear on the customer's filed accounts. It is invisible to other creditors and to credit-reference checks. The whole power of the clause is that the goods never become the customer's property in the first place, so the customer has nothing to charge or pass on.

The four sub-types

Simple, all-monies, extended, and proceeds clauses

Retention of title clauses come in four common shapes. The first two work cleanly in English insolvency. The second two have largely been re-characterised by the courts as unregistered charges and fail.

1. Simple clause

Reserves title to the specific goods until the price of those goods is paid. Upheld in Clough Mill Ltd v Martin [1985] 1 WLR 111: the Court of Appeal held that a simple clause was a straightforward exercise of the section 19 right and did not create a charge. This is the most reliable form. It survives administration, it does not need registration, and the customer cannot defeat it by simply not paying.

2. All-monies (current-account) clause

Reserves title to all goods supplied until all sums owed by the customer to the supplier, on any account, have been paid. Practical effect: each delivery is treated as a continuing supply on the same title-reservation terms, so the supplier's claim survives part-payments and rolling balances. Upheld by the House of Lords in Armour v Thyssen Edelstahlwerke AG [1990] 3 All ER 481 (Scottish case, but applied across the UK). The all-monies clause is the gold standard for trade suppliers because it sweeps in every unpaid invoice on the account, not just the invoices that match identifiable goods on site.

3. Extended (aggregated) clause

Attempts to extend title to new products that the customer manufactures using the supplied goods (the leather becomes a handbag; the resin becomes chipboard; the steel becomes a finished part). Generally fails. The new product is a different thing from the supplied goods, owned by the manufacturer, with the supplier reduced to a security interest over it. That security interest is treated as an unregistered charge under section 859H of the Companies Act 2006 and is void against an administrator. The leading cases are Re Peachdart Ltd [1984] Ch 131 (leather to handbags) and Borden (UK) Ltd v Scottish Timber Products Ltd [1981] Ch 25 (resin to chipboard). A narrow exception in Hendy Lennox v Grahame Puttick [1984] (diesel generators bolted into ships, still identifiable, still removable) shows that physical reversibility can keep title alive; once reversibility is gone, so is the clause.

4. Proceeds (tracing) clause

Attempts to claim the cash proceeds when the customer sub-sells the supplied goods to a third party. The original Romalpa case allowed a proceeds claim on the unusual facts (the buyer was an agent for the seller and held the proceeds in a separate account on trust), but the courts have largely refused to follow it. Compaq Computer Ltd v Abercorn Group Ltd [1991] BCC 484 held that a proceeds clause was a charge over book debts and, unregistered, void against the administrator. The practical position is that a proceeds claim only works if the clause is registered as a charge, which suppliers almost never do.

The practical hurdle

The identification problem

Even a properly drafted clause is useless if the goods cannot be identified at the customer's premises. The supplier must be able to point to specific goods and say "those are mine, here is the delivery note that shipped them, here is the invoice that remains unpaid". This is straightforward when the goods are large, distinctive, and serialised (machinery, electronics, branded packaging). It is much harder when the goods are bulk commodities that have been put into a common bin with stock from other suppliers.

The Sale of Goods (Amendment) Act 1995 partially helps by allowing the supplier to retain an undivided share in a bulk to which the supplied goods have been added (where they remain in the same physical state as supplied). This works for grains, liquids, and other fungibles. It does not save claims where the goods have been processed into something else.

Practical steps that protect identification: serial numbers on every unit, distinctive packaging or labelling, batch codes recorded on the delivery note, photographs of stock arrangements at the customer's premises during account reviews, and a contractual obligation on the customer to store the supplier's goods separately. The last of these is rarely complied with in practice but provides a useful argument that the customer was in breach of contract at the moment of mixing.

The process

What the administrator will require to release the goods

The administrator's first communication to creditors normally arrives within a week of appointment and includes a standard retention of title claim form. The form is the easiest route, but suppliers can also submit a free-form claim. Either way, the administrator will want:

  • The clause itself. The full text of the supplier's standard conditions of sale containing the retention of title clause.
  • Evidence the clause was incorporated. The accepted purchase order, the signed credit application, a course-of-dealing argument with copies of prior orders on the same terms, or whatever evidence supports the supplier's terms (not the customer's purchase-order terms) governing the relevant contracts.
  • Schedule of unpaid invoices. Invoice numbers, dates, amounts, due dates, and the goods they relate to. For an all-monies clause, the entire outstanding ledger balance.
  • Identification of the goods on site. Delivery notes, serial numbers, batch codes, photographs, and where possible a physical pointer to the location of the goods at the customer's premises.
  • Statement of claim. A clear written assertion that the supplier remains the legal owner of the identified goods and requires either return of the goods or payment in full.

The administrator will inspect the stock, cross-check the documentation, and either accept the claim and release the goods, accept the claim and pay the price (commonly where the administrator wants to sell the business as a going concern and needs the stock), or reject the claim with reasons. Administrators often charge a handling fee for segregating, inspecting and releasing reclaimed stock; the fee should be proportionate to the actual work done.

Where the administrator continues to use or sell goods after being notified of a valid retention of title claim, the supplier may have a personal claim against the administrator for conversion. In practice, most administrators take retention of title claims seriously precisely because of this risk.

The race against the buyer

Going-concern sales and the urgency of claiming early

A common pattern in administrations is that the administrator markets the business for sale as a going concern in the first few weeks. The acquirer typically wants the existing stock as part of the deal, because without stock the business cannot trade from day one of the new ownership. If the stock changes hands as part of the going-concern sale, the supplier's retention of title claim against the new owner is much harder: the new owner is usually a bona fide purchaser for value without notice of the supplier's claim, and section 25 of the Sale of Goods Act 1979 generally protects them.

The remedy is to claim early and claim loudly. A retention of title notice delivered to the administrator before the going-concern sale completes puts the administrator on notice of the supplier's title and ensures that any stock sold as part of the deal is sold subject to the supplier's claim (or, more commonly, that the supplier is paid out of the sale proceeds for the value of the reclaimed stock). A claim that lands two weeks after the sale completes is materially weaker.

If the worst has happened

A supplier's first 48 hours after a customer enters administration

The administration is published in the London (or Edinburgh/Belfast) Gazette under category 24 and on the customer's Companies House record within hours of the appointment. The supplier's window of useful action is short.

  • Stop all open shipments. Goods in transit can usually be diverted before delivery. Goods delivered but still on the loading bay are unmixed and clearly identifiable.
  • Pull the file. Identify the standard terms that govern each unpaid invoice, the dates of the contracts, and whether the customer ever signed an acknowledgement of the supplier's terms.
  • Quantify the unpaid balance. Total ledger exposure on the account, broken down by invoice and by physical delivery where possible.
  • Identify what is recoverable. Map the unpaid invoices to specific goods that ought still to be at the customer's premises, with batch codes or serial numbers.
  • Notify the administrator in writing. A formal retention of title claim, by email and registered post, with the clause text, the schedule of invoices, and the identification of goods. Mark it for the administrator's attention by name.
  • Request a stock inspection. The supplier or its agent has a reasonable right to inspect the stock to verify what is recoverable. Administrators normally facilitate this with a few days' notice.
  • Engage solicitors where the value at stake justifies it, especially if the administrator is pursuing a fast going-concern sale.
Catch it before it happens

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Frequently asked

Common questions about retention of title

What is a retention of title clause?
A retention of title clause (sometimes called a Romalpa clause) is a contractual term in the supplier's standard conditions of sale that says legal title to the goods does not pass to the buyer until the goods have been paid for. If the buyer goes into administration or liquidation before paying, the supplier remains the owner and can reclaim the goods, rather than joining the queue of unsecured creditors who typically recover 1p to 3p in the pound. The legal basis is section 19 of the Sale of Goods Act 1979, which allows the seller to reserve the right of disposal until conditions imposed by the seller are met.
What is a Romalpa clause?
A Romalpa clause is another name for a retention of title clause, taken from the 1976 Court of Appeal case Aluminium Industrie Vaassen BV v Romalpa Aluminium Ltd. The Dutch supplier sold aluminium foil to a British buyer on terms reserving title until payment. When the buyer went into receivership owing money, the Court of Appeal upheld the supplier's claim to recover the unmixed foil and the proceeds of the foil it had already sold on. The case established that retention of title clauses are enforceable as a matter of English law.
Does a retention of title clause survive administration?
Yes, if the clause is properly drafted, was incorporated in the contract, and the goods are still identifiable and unmixed. The administrator is bound by the supplier's superior legal title and must either return the goods or pay for them. A simple clause that reserves title until the price of those particular goods is paid is the most reliable; an all-monies clause that reserves title until all the buyer's debts to the seller are paid was upheld by the House of Lords in Armour v Thyssen Edelstahlwerke AG (1990). Claims to goods that have been mixed, transformed, or sold on without a registered charge generally fail.
What are the different types of retention of title clause?
There are four main types: (1) a simple clause reserves title to the specific goods until those goods are paid for; (2) an all-monies (or current-account) clause reserves title until all sums owed by the buyer to the seller, on any account, have been paid; (3) an extended (or aggregated) clause attempts to claim title to new products made from the supplied goods; (4) a proceeds clause attempts to claim the money the buyer has received from sub-selling the goods. The first two survive English insolvency law cleanly. The third and fourth almost always fail because they are treated as unregistered charges and are void against the administrator for non-registration under section 859H of the Companies Act 2006.
When does a retention of title clause fail?
A retention of title clause typically fails in four situations. First, the goods have been mixed with the buyer's own materials so that the supplier's goods can no longer be identified (Borden v Scottish Timber Products, 1981, where resin had been mixed into chipboard). Second, the goods have been transformed into a new product (Re Peachdart, 1984, where leather had become handbags). Third, the clause attempts to claim the proceeds of sub-sales without being registered as a charge (Compaq Computer v Abercorn, 1991). Fourth, the supplier cannot prove that the clause was incorporated in the relevant contract (a battle-of-the-forms problem). A clause that survives all four hurdles works.
What do I need to send the administrator to claim my goods back?
A retention of title claim sent to the administrator should include: a copy of the standard terms and conditions that contain the retention of title clause, evidence those terms were incorporated in the contract (an accepted order, a signed credit application, a course of dealing), a schedule of the unpaid invoices, identification of the goods on site (delivery notes, serial numbers, batch codes, photographs), and a clear statement that the supplier asserts ownership and requires either return of the goods or payment. The administrator will inspect and respond. Many administrators publish a standard retention of title claim form on their first communication to creditors.
Can the administrator refuse to return my goods?
The administrator can refuse where the claim is invalid (the clause was not incorporated, the goods cannot be identified, the goods have been mixed or transformed, or the clause is an unregistered charge). The administrator can also charge a reasonable handling fee for segregating, inspecting and releasing the goods, and can take time to verify the claim before releasing anything. The administrator cannot simply refuse a valid claim. If the administrator continues to use or sell goods that are subject to a valid retention of title claim after notice of the claim, the supplier may have a damages claim against the administrator personally for conversion.
Does retention of title apply if the goods have been resold?
Section 25 of the Sale of Goods Act 1979 protects the bona fide third-party buyer who purchases the goods in good faith without notice of the supplier's retention of title. So once the goods have been resold to an arm's-length buyer in the ordinary course, the supplier loses the right to recover the goods themselves. A clause that tries to capture the proceeds of the resale typically fails as an unregistered charge under section 859H of the Companies Act 2006. The practical effect is that retention of title protects unsold stock sitting in the buyer's warehouse, not finished sales already passed down the chain.
Is retention of title the same as a charge?
No. A retention of title clause keeps ownership with the supplier; a charge gives the chargeholder a security interest over an asset the buyer owns. The distinction matters because retention of title does not need to be registered at Companies House and survives administration cleanly, whereas a charge over the buyer's goods must be registered under section 859A of the Companies Act 2006 or it is void against an administrator. Where a clause tries to do the job of a charge (capturing proceeds of sub-sales, or claiming new products manufactured from the goods), the courts have generally re-characterised it as a charge and held it void for non-registration.
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