HMAG80300 - Exporting excise goods: Exporting excise duty suspended goods

When excise duty suspended goods are being exported, there are obligations under the customs export procedure that must be followed in addition to separate requirements for the excise duty suspended movement.

In most cases, excise duty suspended goods for export will be dispatched from a UK excise/tax warehouse by an excise warehousekeeper responsible for those premises.

However, a UK registered consignor can also dispatch excise duty suspended goods for export from the place where the goods are imported into the UK. This can only happen when excise goods are simultaneously released to free circulation (or authorised use) and excise duty suspension on importation and, immediately following their importation, the excise duty suspended goods are dispatched to a place of export (from where they will leave the UK) by a registered consignor. In the rare event that this situation should occur, HMRC officers are advised to investigate why the excise goods have been released to free circulation when there was no intention for them to remain in the UK.

When excise duty suspended goods are being dispatched from an excise/tax warehouse for export, they may be subject to one of the following two export procedures:

  • standard export procedure
  • Customs Supervised Exports (CSE) procedure

Note: Registered consignors can only use the standard export procedure when dispatching excise duty suspended goods for export.

The dispatching warehousekeeper (or registered consignor) must enter the consignment details (including detail of the movement guarantee provider) on the Excise Movement and Control System (EMCS) using movement type DTC 6 before the excise goods are dispatched.

Once an electronic accompanying document (eAD) has been accepted on EMCS and an Administrative Reference Code (ARC) generated for the consignment, the warehousekeeper (or registered consignor) can dispatch the excise goods to the place of export.

If EMCS is not available at the time of dispatch, the warehousekeeper (or registered consignor) must follow the fallback procedure until EMCS becomes available, at which point the excise duty suspended movement should be retrospectively entered on EMCS.

  • The warehousekeeper (or registered consignor) must provide the ARC (or the Local Reference Number (LRN) for the Fallback Accompanying Document (FAD) if the excise duty suspended movement remains under fallback) to the exporter or the customs agent representing the exporter. The ARC (or the LRN for the FAD) should be recorded on the customs export declaration in CDS data element DE 2/3 (using document code C651 for an eAD or C658 for a FAD)

CDS will be updated with the relevant departure message by the export loader to certify that the goods have left the UK. This departure message automatically generates a report of export on EMCS.

CSE is a customs authorisation that allows a dispatching warehousekeeper to submit a customs export declaration and present the goods for export at their warehouse premises. This means that checks (either documentary or physical) can be completed by HMRC before the excise goods are loaded into a container or vehicle. This reduces the requirement for any checks (other than seal checks) to be completed at the port, although HMRC and Border Force may still decide to complete checks, if required.

Under CSE, the requirement to use EMCS is removed by virtue of regulation 63A of the Excise Goods (Holding Movement and Duty Point) Regulations 2010. This exemption only applies to direct exports from the UK and is subject to the following conditions:

  • the dispatching warehousekeeper has a valid CSE authorisation
  • a full customs export declaration is submitted (not a simplified export declaration)
  • a valid excise movement guarantee is declared on the customs export declaration in data elements DE 8/2 and DE 8/3

As there will be no report of export generated on EMCS, the dispatching warehousekeeper must hold commercial documentation to demonstrate that the excise goods were exported.