Compliant Always
Get in touch

Exporting alcoholic drinks from Canada

Under the Excise Act, 2001, non-duty-paid packaged spirits and wine can be removed from an excise warehouse for export by the licensee without duty, if proof of export is kept for the CRA. Duty already paid is not refunded on export. A CFIA licence is needed only if the exporter wants a CFIA export certificate.

Updated · Each section links to the official source it comes from

Excise duty
Not payable on packaged alcohol removed from an excise warehouse for export (section 147)
Proof of export
Obtained within three months of reporting the goods as exported (CRA EDM9-3-1)
Duty-paid alcohol
No refund on export (section 180)
CFIA licence
Only to obtain a CFIA export certificate or other export permission
Export declaration
To the CBSA, for most destinations other than the US

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Is the alcohol leaving from an excise warehouse without duty paid? Read more
  2. 2Which documents will show the CRA that it left Canada? Read more
  3. 3Does the destination ask for a CFIA export certificate? Read more
  4. 4Is an export declaration needed at the border? Read more
  5. 5Will the importer claim a preferential duty rate? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Excise duty on exported spirits and wine

How the Excise Act, 2001 treats spirits and wine that leave Canada, and who may export them.

  • Duty is not payable on non-duty-paid packaged alcohol removed from an excise warehouse for export by the excise warehouse licensee (section 147(1)(b)).
  • Spirits in a marked special container, and wine imported in one, are also free of duty when removed for export by the excise warehouse licensee, if the container was imported (section 147(2) and (3)).
  • Bulk alcohol may be exported only by the alcohol licensee responsible for it, the licensed user who imported it, or a person required to do so under section 101 (section 76).
  • Duty paid on alcohol entered into the duty-paid market is not refunded when the alcohol is exported (section 180).
  • An excise warehouse licensee is liable to a penalty of 200% of the duty if packaged alcohol removed for export is not exported (section 237).

How we help: Compliant Always keeps the removal records and the export evidence for each consignment together, dated, and shows a removal that has no proof of export yet. Ask about this

Proof of export for the CRA

The documents the Canada Revenue Agency accepts as evidence that non-duty-paid spirits and wine left Canada.

  • Proof of export must be available to the CRA, and must let the whole shipment be traced from its origin in Canada to its destination outside Canada.
  • The exporter must obtain enough evidence of export within three months of reporting the goods as exported.
  • Generally no single document is enough. A combination may include the CERS or G7-EDI export declaration, a commercial invoice, a bill of lading or waybill, broker or forwarder invoices, and the destination's import documents.
  • For exports to the United States, US customs forms such as CBP Form 7501 (Entry Summary) or 3461 may serve.
  • Copies of documents are kept for audit; paper and electronic records are both acceptable.

How we help: Compliant Always keeps the invoice, transport document, declaration and import papers for each consignment in one record, and shows when the three-month window is running out. Ask about this

CFIA licences and export certificates

When the Safe Food for Canadians Regulations apply to exported alcoholic beverages.

  • No licence is needed to import, or to manufacture, process, package or label, an alcoholic beverage regulated under the Importation of Intoxicating Liquors Act for export or trade between provinces.
  • A licence and preventive control plan are not required to make or export alcoholic beverages unless you want an export certificate or other export permission from the CFIA.
  • To obtain one, the exporter needs a licence and a preventive control plan first.
  • The CFIA issues certificates only for products still in Canada.

How we help: Compliant Always keeps the licence and preventive control plan with the products they cover, so a certificate request has them to hand. Ask about this

Export declaration and reporting to the CBSA

How commercial goods are reported to the Canada Border Services Agency before they leave Canada, and what the exporter keeps afterwards.

  • In most cases an export declaration is needed for commercial goods. The most common exceptions are goods exported for consumption in the United States and non-restricted goods valued at less than CAN $2,000.
  • Goods moving through the United States to another destination, including goods entering the US on a transportation and exportation (T and E) bond, need a declaration.
  • Restricted goods, those controlled, regulated or prohibited under Canadian law, need their permit, certificate or licence whatever their value; going to the US they need no declaration, but the permit must still be presented.
  • Declarations are made through the Canadian Export Reporting System (CERS) or G7 EDI, with a business number and RM export program identifier. The exporter gives the carrier the proof of report number.
  • Minimum time limits: 2 hours before loading for air and rail, 48 hours before loading for marine, 2 hours before delivery to the post office, and immediately before export by highway.
  • The exporter may delegate reporting to a customs service provider but remains responsible for the information, and keeps export records in Canada for 6 years.

How we help: Compliant Always keeps the proof of report number, permits and export records with each shipment, dated, and shows what is missing before the goods are loaded. Ask about this

Certificates of origin under trade agreements

The document that lets the importer claim a preferential duty rate under one of Canada's free trade agreements, such as CUSMA, CETA or CPTPP.

  • A certificate of origin certifies that the good meets a free trade agreement's rules of origin; the importer must have it to claim preferential tariff treatment.
  • Under CETA, the Canada-UK TCA, CEFTA and CUFTA it is an origin declaration on an invoice or other commercial document. Canadian exporters enter their Business Number in the CETA declaration.
  • Under CUSMA and CPTPP it is a set of minimum data elements with no prescribed format, which the importer, exporter or producer may complete.
  • A certificate can cover one shipment, or identical goods over a blanket period of up to 12 months. It is valid for four years from signature.
  • Whoever certifies origin keeps the certificate and supporting records for six years, and must tell everyone they gave it to of any change affecting its accuracy.

How we help: Compliant Always keeps each origin declaration with the products and shipments it covers, shows when a blanket period runs out, and answers importers' origin questions from the record. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Excise warehouse licensee or spirits licenseeRemoving non-duty-paid alcohol for export, and the proof that it left Canada.Removals and export evidence kept together for each consignment.
ExporterThe export declaration, any CFIA certificate request, and origin documents.Declarations and certificates kept with each shipment, dated.
Customs service provider or freight forwarderReporting on the exporter's behalf where delegated, and transport documents.Bills of lading and forwarder invoices kept with the export record.
Canada Revenue AgencyVerifying that non-duty-paid alcohol was exported.The evidence an auditor asks for, in one place.

Where are the goods going?

Most of what alcoholic drinks have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Do I pay excise duty on wine or spirits exported from Canada?
Not on non-duty-paid packaged alcohol removed from an excise warehouse for export by the excise warehouse licensee, under section 147 of the Excise Act, 2001, provided proof of export is available to the CRA.
Can I get excise duty back on alcohol I already paid duty on and then exported?
No. Section 180 of the Excise Act, 2001 says duty paid on alcohol entered into the duty-paid market is not refunded on its exportation.
What proof of export does the CRA accept for spirits and wine?
Usually a combination of documents tracing the whole shipment, such as the export declaration, commercial invoice, bill of lading or waybill, broker or forwarder invoices and the destination's import documents. EDM9-3-1 lists them.
How long do I have to get proof of export for alcohol?
Three months from reporting the goods as exported, according to CRA Excise Duty Memorandum EDM9-3-1.
Who can export bulk alcohol from Canada?
Under section 76 of the Excise Act, 2001, only the alcohol licensee responsible for it, the licensed user who imported it, or a person required to export it under section 101.
What happens if alcohol removed for export is not exported?
Section 237 of the Excise Act, 2001 makes the excise warehouse licensee liable to a penalty equal to 200% of the duty on packaged alcohol removed for export and not exported.
Do I need a CFIA licence to export wine or beer?
Not to make or export alcoholic beverages regulated under the Importation of Intoxicating Liquors Act, unless you want a CFIA export certificate or other export permission. For that, a licence and a preventive control plan come first.
Do I need an export declaration for wine going to the United States?
Not for non-restricted goods exported for consumption in the United States. Shipments elsewhere worth CAN $2,000 or more need one, and the CRA lists the declaration among acceptable evidence of export.
Which certificate of origin applies to Canadian spirits going to the EU?
Under CETA, an origin declaration on the invoice or another commercial document, in the wording of Annex 2 of the CETA Protocol on Rules of Origin, with the exporter's Business Number.
How does Compliant Always help with exporting from Canada?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in Canada and what your paperwork needs to show.

Get in touch

No card, no account, and no call to book. Tell us what you make and where you sell it, and we will come back to you.

Get in touch