Moving and declaring excise goods in a no-deal Brexit
In a no-deal Brexit, there'll be changes to how you move and declare excise goods (alcohol, tobacco and certain oils).
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The UK will leave the EU on 31 October. This page tells you how to prepare for Brexit. It will be updated if anything changes, including if a deal is agreed.
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Importing excise goods from the EU
After Brexit, imports of excise goods from the EU will be treated the same as imports from the rest of the world. This includes moving imported excise goods within the UK.
Importing excise duty-paid goods
After Brexit excise duty-paid goods imported to the UK will not be covered by:
- a Simplified Accompanying Administrative Document (SAAD)
- EU distance-selling arrangements
You’ll need to follow the relevant customs import procedure.
Importing excise duty-suspended goods
If your excise goods are dispatched from an EU member state on or after Brexit, you must use the relevant customs procedures when they arrive at the place they enter the UK. You cannot use the Excise Movement Control System (EMCS) to move the goods.
You can use transitional simplified procedures to import excise goods. This means you’ll be able to transport your goods into the UK without having to make a full customs declaration in advance. HMRC will write to you about this before Brexit.
To use transitional simplified procedures, you’ll need:
- to register for transitional simplified procedures
- to follow the controlled goods procedure
- a duty deferment account
Moving imported excise goods within the UK
Use EMCS to move excise duty-suspended goods from the place they enter the UK to their final destination.
You’ll need to appoint a Registered Consignor to move the goods, or become a registered consignor.
The Registered Consignor must:
- complete and submit an electronic administrative document (eAD) through EMCS before the movement takes place
- get a unique Administrative Reference Code (ARC) for that specific movement (that EMCS generates)
The ARC must travel with the goods at all times. You must supply the person accompanying the goods (for example, the driver of the vehicle transporting the goods) with a printed version of the eAD or any other commercial document which clearly states the ARC.
Once the goods are received and checked into the excise warehouse, the consignee will:
- confirm that the goods have arrived
- complete and submit a ‘report of receipt’ and send it to the Registered Consignor
Become a Registered Consignor
If you want to become a Registered Consignor, you’ll need to:
It can take up to 45 days to register, so you should appoint someone who is already a Registered Consignor to move your goods whilst your application is being approved.
Exporting excise goods from the UK
After Brexit, exports of excise goods from the UK will be treated the same as exports to the rest of the world. This includes moving excise goods to a place of export in the UK.
Exporting excise duty-paid goods
After Brexit you’ll need to submit an electronic export declaration.
If you’re a business, you may be able to recover the excise duty on the exported goods by claiming excise duty drawback.
Exporting excise duty-suspended goods
After Brexit you cannot use EMCS to move excise duty-suspended goods from the UK to the EU. If you move goods without following the relevant customs export procedures at the place they are exported from, you may be liable for excise duty and subject to seizure and penalties.
From 24 October 2019, if you raise a movement on EMCS to an EU member state with a dispatch date later than 31 October 2019 the movement will be rejected by EMCS and HMRC.
Moving excise goods to the place of export from the UK
Use EMCS to move excise duty-suspended goods from within the UK to the place they are exported from.
You’ll need to either:
- appoint a Registered Consignor to move to goods or become a Registered Consignor - when the goods are being released from a customs control
- ask an authorised warehouse keeper to declare the movement - when the goods are held in excise-duty suspension in their warehouse
The authorised warehousekeeper or Registered Consignor must:
- complete and submit an electronic administrative document (eAD) through EMCS before the movement takes place
- get a unique Administrative Reference Code (ARC) for that specific movement (that EMCS generates)
- complete a customs export declaration using the National Export System (NES) and enter the ARC into box 40
- receive an ‘accepted for export’ notification on EMCS after the goods are cleared by customs - if the ARC matches the customs export declaration
- receive a ‘report of export’ before the export is closed on EMCS
If the ARC does not match the customs export declaration within 30 days of the customs export declaration being submitted, the warehousekeeper or Registered Consignor will receive a ‘rejected for export’ notification to remind them that the movement is still open on EMCS. You’ll need to establish why this has happened and take corrective action.
| EMCS status | Description |
| ‘Accepted’ | The customs export declaration has been accepted |
| ‘Rejected for export’ | The ARC does not match the customs export declaration on CHIEF |
| ‘Exporting’ | The ARC matches the customs export declaration on CHIEF and the goods have been cleared by customs |
| ‘Delivered’ | The goods have departed the UK |
If you’re a registered excise business or use authorised destinations
After Brexit, the following registered excise businesses and some authorised destinations will no longer be authorised to receive or dispatch excise goods:
- Registered Consignee (including movements for direct delivery)
- Temporary Registered Consignee
- Exempt consignee
- Unknown destination for energy products
- Tax representative (for excise duty on distance sales from the EU)
- Registered Commercial Importer
- Unregistered Commercial Importers
If this impacts your business, you’ll need to take steps so that you can continue trading.
If your goods are dispatched before Brexit but received after Brexit
You do not need to complete a UK customs declaration or pay customs duty in the UK if:
- the goods are travelling under a recognised excise scheme at that time
- you can show that the movement started before Brexit
- the goods are consigned to a UK destination before Brexit
The requirements and any sanctions that may apply to these goods will be based on current UK excise legislation and duty points that apply to EU movements.
HMRC or Border Force may ask for evidence of the date and time your goods were dispatched. You can show this by providing:
- for excise duty-suspended goods - the eAD or a commercial document containing the ARC
- for excise duty-paid goods, either:
- the request to import excise goods bought duty-paid in another EU member state (HM4)
- the Simplified Accompanying Administrative Document (SAAD) form
If you cannot prove the date and time your goods were dispatched, the movement will be treated in the same way as one that started after 31 October 2019 and customs import procedures will apply.
Imports dispatched from the EU before Brexit but received in the UK after
If your goods arrive in the UK after Brexit but were dispatched from the EU before this time:
- you cannot use EMCS to create reports of receipt
- the movement will remain open in the system
- you’ll need to provide a paper document that includes the same information as an EMCS report of receipt
For excise duty-paid goods, you must still approve and return copy 3 of the SAAD to the EU business if they requested it. Copy 1 stays with the despatching business and copy 2 is kept by the UK receiving company.
Exports dispatched from the UK before Brexit but received in the EU after
If your goods arrive in the EU after Brexit but were dispatched from the UK before this time:
- you cannot use EMCS to create reports of receipt
- the movement will remain open in the system
- you’ll need to provide an alternative proof of receipt
If you do not receive an endorsed copy of the SAAD back from the EU business for excise duty-paid goods, you’ll need to provide an alternative proof of receipt.
Excise duty drawback claims
If you provide HMRC with an EX75 Notice of Intention (NOI) before 31 October 2019 but the drawback claim is made after this date, the way you can claim duty drawback will change. HMRC will provide more information about these changes before a no-deal Brexit.