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Exporting alcoholic drinks from the EU

Beer, wine and spirits are excise goods. An authorised warehousekeeper or registered consignor can move them to the place of export under duty suspension, with an electronic administrative document in EMCS; customs match it to the export declaration, and a report of export closes the movement. Exported drinks must also meet EU food law unless the destination says otherwise.

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

Excise law
Council Directive (EU) 2020/262
Movement document
Electronic administrative document (e-AD) in EMCS
Who may dispatch
Authorised warehousekeeper, or registered consignor from import
Closing the movement
Report of export, once the goods have left the EU
Duty already paid
May be claimed back on export, under conditions
Food law on exports
Article 12 of Regulation (EC) No 178/2002

Before the goods leave

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

  1. 1Will the drinks leave a tax warehouse under duty suspension, or have they been released for consumption? Read more
  2. 2Is the e-AD in EMCS, and will its reference code be given with the export declaration? Read more
  3. 3Do the drinks meet EU food law, or has the destination asked for something different? Read more
  4. 4Do the drinks meet the agreement's list rule, and what proof of origin goes with them? Read more
  5. 5Who lodges the export declaration, and at which customs office? Read more

The rules, by area

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

Excise duty suspension and tax warehouses

How alcoholic drinks reach the border without excise duty being charged.

  • Excise duties are indirect taxes on products such as alcohol, tobacco and energy; EU law sets the structures and minimum rates for alcohol and alcoholic beverages (Directives 92/83/EEC and 92/84/EEC).
  • Duty becomes chargeable when goods are released for consumption, including when they depart from a duty suspension arrangement (Article 6 of Directive (EU) 2020/262).
  • Tax warehouses, authorised by national authorities, produce, receive, store and dispatch excise goods in duty suspension; authorisations can be consulted in the SEED register.
  • Excise goods may be moved under duty suspension from a tax warehouse, or by a registered consignor from the place of importation, to a place where they leave the EU (Article 16(1)).
  • Access2Markets says excise duty paid on alcoholic beverages can be claimed back, under certain conditions and in specific cases, such as when the goods are finally exported.

How we help: Compliant Always keeps the warehouse authorisation, excise numbers and any refund claim with the shipments they cover, dated. Ask about this

EMCS, the export declaration and the report of export

How the excise movement and the customs export are tied together.

  • Movements under duty suspension are documented in the Excise Movement and Control System (EMCS) with an electronic administrative document (e-AD); the member state of dispatch validates it and gives it an administrative reference code (ARC).
  • The content of the e-AD is laid down in Directive (EU) 2020/262 and Delegated Regulation (EU) 2022/1636, and the rules for its use in Implementing Regulation (EU) 2022/1637.
  • The declarant gives the customs authorities of the member state of export the ARC of the excise goods in the export declaration; they check, before release, that the e-AD matches the declaration (Article 21).
  • If the goods will no longer leave the EU, customs notify the member state of dispatch and the consignor cancels the e-AD or changes the destination.
  • Once the customs office of exit confirms the goods have left, the member state of export completes a report of export, which is forwarded to the consignor (Article 25).
  • The Automated Export System (AES) has an interface with EMCS for excise goods under duty suspension leaving the EU.

How we help: Compliant Always keeps the e-AD, its ARC, the export declaration and the report of export together for each shipment, and shows movements still waiting for their report. Ask about this

EU food law on exported drinks

Alcoholic drinks are food, and Article 12 of the general food law covers food made for export.

  • Food exported or re-exported from the EU for a third country's market must comply with the relevant requirements of EU food law, unless the importing country's authorities ask otherwise or its laws set different requirements (Article 12 of Regulation (EC) No 178/2002).
  • Food that cannot be placed on the EU market may be exported only where the destination's competent authorities have expressly agreed, after being fully informed; food injurious to health may not be exported.
  • Access2Markets advises checking which certificates the destination requires and accepts, and whether testing by an accredited laboratory in the EU is accepted.

How we help: Compliant Always keeps analysis reports and any certificates with the lot they cover, and reads them against what the destination asks for. Ask about this

Origin and proof of origin

Preferential origin under EU trade agreements, how it is proved, and certificates of non-preferential origin.

  • To get a lower or zero tariff under a trade agreement, goods must be wholly obtained in the EU or sufficiently worked or processed there under the product-specific 'list rules' of the agreement's origin protocol, read by HS heading.
  • The Commission's Rules of Origin Self-Assessment tool (ROSA), in Access2Markets' My Trade Assistant, helps check a product against the rules and explains which proof of origin to prepare.
  • Proof can be a movement certificate EUR.1 or EUR-MED issued by customs, or a self-declaration by the exporter on a commercial document: a statement on origin, or an invoice or origin declaration.
  • EU exporters must be registered in REX, with their national competent authorities, to make out statements on origin under agreements including those with Canada, Japan, Vietnam, Singapore, the UK, New Zealand and Chile, and the EU-MERCOSUR Interim Agreement.
  • Without a REX number, an exporter may make out statements on origin for consignments of originating products worth up to EUR 6 000 (EUR 10 000 for trade with the OCTs).
  • Suppliers' declarations let an exporter rely on the originating status of materials bought in the EU. Exporters keep copies of proofs of origin and related records for at least three years.
  • A Binding Origin Information (BOI) decision from customs fixes the origin of goods for up to three years, but does not replace the proof of origin.
  • A certificate of non-preferential origin may be required by the destination; Access2Markets says these are usually issued by the local chamber of commerce, and in some countries by ministries or customs.

How we help: Compliant Always keeps the REX number, suppliers' declarations and each statement on origin or certificate with the shipment it covers, and shows which proofs are missing or out of date. Ask about this

EORI and the export declaration

Who may export, the registration number every declaration carries, and the two stages of the export procedure: export and exit.

  • The export procedure (Article 269 UCC) is obligatory for EU goods leaving the EU customs territory, with very few exceptions, so that export measures such as restrictions are applied.
  • An EORI number is mandatory for customs operations in the EU, export included. It is assigned by the customs authority of the member state where the operator is established, and does not expire.
  • Access2Markets says an exporter normally needs to be established in the EU, including a VAT registration; a non-EU resident needs a person established in the EU, such as a logistics provider or customs agent, to act as exporter.
  • The export declaration is lodged electronically in the Automated Export System (AES), at the customs office for the place where the exporter is established or where the goods are packed or loaded (Article 221(2) UCC-IA).
  • It gives the origin of the goods, the destination country, commodity codes, customs procedure codes and the value. Customs may release the goods, ask for documents, or check them physically.
  • The goods and the Master Reference Number (MRN) are then presented at the customs office of exit, which supervises their departure. Goods stay under customs supervision until they leave.
  • Keep invoices, transport documents and packing lists for at least three years. Exports are exempt from EU VAT if records and the customs proof of export are kept.

How we help: Compliant Always keeps the EORI, invoice, packing list, MRN and proof of exit with each shipment, dated, and shows what is missing before the goods are declared. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Authorised warehousekeeper or registered consignorDispatching under duty suspension, the e-AD, any guarantee, and discharging the movement on the report of export.Open movements shown until their report of export is on file.
Exporter or declarantThe export declaration with the ARC, proof of origin, and the EORI number.The declaration and its excise reference kept together.
Member state excise and customs authoritiesValidating the e-AD, checking it against the declaration, and completing the report of export.Each authority's document kept with the shipment.
Buyer or importerUsually the destination's labelling, licences and import clearance, with the exporter's help.Importers' questions answered from the record.

Member states

The export rules are EU law, but member states run them. The EORI number, the export declaration, origin registrations such as REX and approved exporter status, and dual-use licences go through the national authorities of the member state concerned.

Export certificates for food, animal products and plants are issued by member states' competent authorities; the Commission supplies harmonised certificates through TRACES and guidance in its Export library. Certificates of non-preferential origin are usually issued by local chambers of commerce.

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 the EU?
Not if they move under duty suspension from a tax warehouse to the place of export. Duty is charged on release for consumption. Duty already paid can be claimed back in some cases, such as final export.
What is an e-AD?
The electronic administrative document that accompanies excise goods moving under duty suspension, recorded in EMCS. The member state of dispatch validates it and gives it an administrative reference code (ARC).
How does the e-AD link to the export declaration?
The declarant gives customs the e-AD's administrative reference code. Before releasing the goods, customs check that the e-AD matches the export declaration.
What is a report of export?
The record completed by the member state of export once the customs office of exit confirms the goods have left the EU. It is forwarded to the consignor, closing the duty-suspended movement.
Who can dispatch alcohol under duty suspension for export?
An authorised warehousekeeper from a tax warehouse, or a registered consignor from the place of importation. Tax warehouses are authorised by national authorities and listed in SEED.
Can I check a buyer's or warehouse's excise number?
Yes. SEED, the EU register of excise operators, shows whether an excise number is valid and which categories of goods the operator is authorised to trade.
Do EU food rules apply to wine or spirits made for export?
Yes, as a rule. Food, drinks included, exported from the EU must meet EU food law unless the destination's authorities ask otherwise or its laws set different requirements.
What proof of origin does EU wine need for a lower tariff in Japan or Canada?
A statement on origin by an exporter registered in REX. Without a REX number, one may be made out for consignments worth up to EUR 6 000.
What happens if the goods do not leave the EU after all?
Customs in the member state of export notify the member state of dispatch, and the consignor cancels the e-AD or changes the destination of the goods.
How does Compliant Always help with exporting from the EU?
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.

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