Section 25 — removal of alcoholic product from approved premises in Northern Ireland to EU countries
Guidance about approved producers removing duty suspended and duty paid alcoholic product from approved premises in Northern Ireland. This guidance only applies to producers approved with an alcoholic products producer approval (APPA), and approved premises in Northern Ireland.
You may remove either duty suspended or duty-paid alcoholic product to EU member states, but the procedures and requirements are different.
All movements of alcoholic product between Northern Ireland and an EU member state will need to be submitted through Excise Movement and Control System (EMCS).
Find more information about this system in receive goods into and remove goods from an excise warehouse (Excise Notice 197) and Certified traders and tax representatives: EU trade in duty-paid excise goods (Excise Notice 204b).
You must follow the detailed procedures set out in receive goods into and remove goods from an excise warehouse (Excise Notice 197) which include the following requirements:
- you must have financial security (guarantee) in place, the minimum level of security for movements is £20,000
- you must make sure that you’re sending the alcoholic product to a warehouse or a registered consignee which the fiscal authorities in that member state have approved to receive that type of alcoholic product
- you must access EMCS and raise an electronic administrative document (eAD) before the movement starts and obtain an administrative reference code that’ll uniquely identify the movement
- you must receive a valid report of receipt confirming that the consignee received the alcoholic product
If you are sending the alcoholic product direct to a trader without an alcoholic products producer approval (APPA) (in this case, an unapproved trader) then you must make sure that the duty is paid prior to the alcoholic product leaving your approved premises. You may be able to reclaim the duty as drawback — read excise duty drawback (Excise Notice 207).
If the unapproved trader appoints an agent who is authorised to receive duty-suspended excise goods, then the UK duty does not need to be paid. However, the movement must be submitted through EMCS the agent showing as the consignee on the electronic administrative document.
If you are sending alcoholic product to a private individual (rather than a trader) this is known as distance selling. You must make sure that the duty is paid prior to the alcoholic product leaving your approved premises. You may be able to reclaim the duty as drawback — read Excise duty drawback (Excise Notice 207).
Additionally you as the seller are responsible for ensuring that the duty is paid in the EU member state of destination.
More information on distant selling can be found in receive goods into and remove goods from an excise warehouse (Excise Notice 197).
The duty in the EU member state of destination must be secured before the dispatch of the goods and then paid on receipt. How this is done depends on the rules in the receiving EU member state.
Unless the goods are being dispatched to a private individual the movement of duty paid excise goods between Northern Ireland and the EU, from one business to another, must move under the cover of EMCS. Further information on the movement requirements can be found in certified traders and tax representatives — EU trade in duty-paid goods (Excise Notice 204b).
You may be able to reclaim the UK duty on the goods that you dispatched. In order to reclaim the duty, you must observe the conditions of the drawback system which are contained in Excise duty drawback (Excise Notice 207). Drawback is a relief that provides the repayment of excise duty-paid goods that have not and will not be consumed in the UK.
Producers with an alcoholic products producer approval (APPA) should offset the amount of drawback claimed during the accounting period by completing their Alcohol Duty return. The claim should be completed for movements only and supported by the necessary documentary evidence as required by Excise duty drawback (Excise Notice 207).