Guidance: Receiving, storing and moving excise goods

Moving excise goods in duty suspension

When excise goods are moving in excise duty suspension within the UK or EU (for Northern Ireland movements only), the movement must take place between persons and premises that have been approved for that purpose by the competent authorities in the UK or EU member state where they are based.

Excise goods may only be moved in excise duty suspension once they are in ‘free circulation’.

In the UK this covers goods that have been wholly produced in the UK, or goods that have been imported into the UK and for which all import formalities have been completed and any customs duties due have been paid.

For Northern Ireland, it can also mean goods imported into the EU for which all import formalities have been completed and any customs duties or associated charges due have been paid.

Movement guarantees

Generally, excise goods that are moving within the UK or between the EU and Northern Ireland in excise duty suspension, must be covered by financial security in the form of a movement guarantee.

It is the consignor’s responsibility to ensure that a valid movement guarantee is in place, with detail of the guarantee recorded on the appropriate movement documentation prior to the goods being dispatched in duty suspension.

Read about movement guarantees for duty-suspended removals from UK excise warehouses.

Excise Movement and Control System (EMCS)

All duty-suspended movements of excise goods taking place within the UK, or between the EU and Northern Ireland, must be recorded on the Excise Movement and Control System unless the goods are allowed to move under simplified procedures.

Read about how to register and use the Excise Movement and Control System.

Storing excise goods in duty suspension in the UK

If you’re based in the UK and intend to receive, store and dispatch ‘free circulation’ excise goods in duty suspension, you’ll need to have your premises approved as an excise warehouse, which is a specific type of tax warehouse. As the operator of the excise warehouse, you will also need to be approved as an authorised warehousekeeper.

An excise warehouse is any place of security approved by HMRC, where goods liable for excise duty can be stored without payment of the duty, for such periods and subject to such conditions as they see fit.

Excise duty is suspended whilst goods are held in an excise warehouse, but you must get permission from HMRC if you intend to store duty-suspended and duty-paid goods in the same premises, this is known as co-storage.

The 3 categories of excise goods that can be held in an excise warehouse in duty suspension are:

• alcohol products including beers, wines and spirits
• tobacco products including cigarettes, cigars, loose tobacco and tobacco for heating
• energy products including hydrocarbon oils and biofuels for use as motor or heating fuel

HMRC does not allow UK-manufactured tobacco products intended for use in the UK to be stored in an excise warehouse.

Such goods can only be warehoused if they are intended for a duty-free purpose such as:

• goods for export
• for sale from an export shop
• for supply to embassies within the UK
• for use by visiting forces
• for use as ships’, aircraft or train stores

General storage and distribution warehouses

These are premises used for the general storage and dispatch of alcohol and tobacco goods in duty suspension.

In order for these premises to have been considered for approval before 1 June 2022, they must have met the minimum throughput levels:

• a minimum potential duty liability of £500,000 on the average monthly stockholding of duty-suspended excise goods
• a duty liability of at least £2 million on an annual throughput of duty-suspended excise goods

To be considered for approval from 1 June 2022, you must be able to demonstrate that:

• there is a real economic need to store goods under excise duty suspension arrangements at these premises
• you will have enough clients or business to run the excise warehouse as a viable going concern

Changes to throughput requirements and storage times in excise warehousing approvals from 1 June 2022.

Read the guidance on Registration and approval of excise goods held in duty suspension (Excise Notice 196) for further information.

Trade facility warehouses

These are premises where excise goods can be stored in duty suspension for one of the following purposes:

• the maturation of spirits
• goods which will not bear UK excise duty, for example, goods for export, goods used in pharmaceuticals, goods used in foodstuffs, goods to be removed for use as ship, aircraft or train stores
• performing an allowable operation on the goods
• any other purpose allowed by HMRC

Trade facility warehouse approval is restricted to the specific trade need applied for, for example, the warehouse approval may be limited to the storage of spirits for bottling.

Changes to throughput requirements and storage times in excise warehousing approvals from 1 June 2022.

Read the guidance on Registration and approval of excise goods held in duty suspension (Excise Notice 196) for further information.

Motor and heating fuels warehouses

These are premises where mineral (hydrocarbon) oil, biofuels and special energy products may be stored in duty suspension.

Changes to throughput requirements and storage times in excise warehousing approvals from 1 June 2022.

Read the guidance on Registration and approval of excise goods held in duty suspension (Excise Notice 196) for further information.

Excise warehouse premises guarantees

HMRC may require a financial security (in the form of a guarantee) relating to the storage of duty-suspended excise goods in an excise warehouse.

Read about excise warehouse premises guarantees.

Can you store goods in an excise warehouse

If you own excise goods and you want to store them in duty suspension, you’ll need to be approved by HMRC in order to deposit those goods in an excise warehouse.

If you’re a UK-based owner of excise goods, you will need to be approved by HMRC as a registered owner.

If you’re an overseas owner without a fixed UK address, you’ll need to appoint someone who is approved by HMRC as a duty representative to act on your behalf.

In general, only the warehousekeeper of the warehouse concerned, a registered owner, or an overseas owner with a duty representative acting on their behalf can deposit goods in an excise warehouse.

Read more about owners and duty representatives.

Apply for approval

You should apply for approval by using:

• form EX60 if you’re a registered owner
• form EX64 if you want to act as a duty representative
• form EX61 if you want to apply for approval as an authorised excise warehousekeeper, as well as:
  • form EX68 for a general storage and distribution warehouse
  • form EX69 for a trade facility warehouse for alcohol and tobacco
  • form EX70 for a motor and heating fuels warehouse

Read about how to register as a warehousekeeper of motor and heating fuel.

Read more about HMRC approval, authorisation and registration.

Move goods into and out of an excise warehouse

Excise warehousekeepers are responsible for accounting for all excise goods entering or leaving their warehouse premises.

Read about receipt into and removal from an excise warehouse.

Importing excise goods — registered consignors

If you’re an authorised warehousekeeper receiving excise goods that have been imported and the intention is to store those goods free of all duties, you must hold customs warehouse approval for your premises.

If the person importing the goods wants to suspend the excise duty only, they must arrange for the goods to be placed in an approved excise warehouse. However, this can only be done once the excise goods have been released to free circulation on completion of all import formalities and payment of any customs duties.

Read about customs procedures for imports into the UK from non-EU countries.

The excise duty-suspended movement from the place where the goods are released to free circulation, for example a port or airport in the UK, to the excise warehouse must be carried out by someone who is approved as a registered consignor.

HMRC will generally only consider approving the import agent for the goods, the authorised warehousekeeper receiving the goods from the place of release for free circulation, or the person who dispatches duty-suspended goods to a place of exit from Great Britain (England, Scotland and Wales), for the purposes of exporting those same goods out of the UK at a place of exit in Northern Ireland as a registered consignor.

If any of these persons wants to apply for approval, they must complete and submit:

Where excise duty-suspended goods move directly from a warehouse in Great Britain to a warehouse in Northern Ireland, HMRC will deem the warehousekeeper who provided the movement guarantee as the registered consignor for entry into Northern Ireland.

Duty-suspended movements of excise goods from registered consignors are subject to Excise Movement and Control System (EMCS) procedures. If you’re approved as a registered consignor, you will also need to register and enrol for the Excise Movement and Control System.

Read about excise duty-suspended movements from registered consignors.

Remove or dispatch goods from an excise warehouse

As an excise warehousekeeper, you may remove goods from your excise warehouse for:

• home use on payment of duty (sometimes referred to as the goods being ‘released for consumption’ in the UK)
• dispatch under duty suspension to other approved UK warehouses
• dispatch under duty suspension to approved persons or premises in EU member states — Northern Ireland only
• exports in duty suspension

You may also be allowed to carry out the following miscellaneous removals:

• supplies to diplomats and visiting forces within the UK
• supplies to entitled international organisations, embassies and visiting forces
• supplies to HM ships
• removal of goods for use as ships, aircraft or train stores
• removals to authorised duty-free spirits users
• delivery of spirit-based flavourings and essences that are exempt from excise duty

Read about receipt into and removal from an excise warehouse.

Exports

If you’re the dispatching warehousekeeper exporting duty-suspended excise goods from the UK you must ensure that you fully comply with all excise requirements, as well as any separate customs export declaration requirements.

Read about exporting excise goods from an excise warehouse in the UK to other countries and movements between Northern Ireland and EU member states.

Read about export procedures.

Excise warehouse returns

All authorised warehousekeepers (except those currently operating certain trade facility warehouses such as export shops and aircraft store floors) are required to submit a W1 excise warehouse return for each set of premises they operate, in respect of alcohol and tobacco goods.

You can submit your W1 returns electronically using the Alcohol and Tobacco Warehousing Declaration (ATWD) online service.

Read about registering, enrolling and activating to use the Alcohol and Tobacco Warehousing Declaration (ATWD) online service.

Pay or defer duty when moving excise goods

When goods are released from an excise warehouse for consumption, you must ensure that the excise duty has been paid or accounted for prior to the removal of the goods.

For immediate payment of duty you must use cash or an equivalent method such as:

• a banker’s draft
• Bacs (Bankers Automated Clearing System)
• CHAPS (Clearing House Automated Payment System)

If payment is being made by cash or equivalent, you should submit the following payment warrants to HMRC along with the remittance:

• form W5 for the removal of alcohol goods
• form W6 for the removal of tobacco goods
• form W50 for the immediate payment of excise duty including Mineral (Hydrocarbon) Oil Duty

You can submit forms W5 and W6 using the Alcohol and Tobacco Warehousing Declaration (ATWD) online service.

Form W50 is not available on GOV.UK, but you can order supplies by contacting HMRC.

Excise duty deferment

Duty can only be deferred if you have been authorised to do so by HMRC.

Find out more about applying for a duty deferment account in:

If you’ve been approved to defer payment of the excise duty and want to account for the duty under deferment arrangements, you must submit the following warrants to HMRC:

You can also submit forms W5D and W6D using the Alcohol and Tobacco Warehousing Declaration (ATWD)online service.

Read about excise duty deferment, VAT and other charges.

Excise Payment Security System

In order to defer duty, you’re normally required to take out a guarantee to cover your total monthly liabilities. Under the Excise Payment Security System you may be able to defer payments of excise duty without a guarantee.

Registered consignees

Registered consignees are revenue traders who are approved and registered by HMRC to receive and account for the duty on duty-suspended excise goods from EU member states.

These approval types will only apply to Northern Ireland businesses from 1 January 2021 and will no longer apply to businesses based in Great Britain.

They must account for the UK excise duty when the goods are received in the UK.

They cannot receive duty-suspended excise goods from outside the UK or EU (not to be confused with registered consignors) and they cannot hold or dispatch goods in duty suspension.

Read more about registered consignees.

Temporary registered consignees

Temporary registered consignees are excise traders that are registered and approved by HMRC to import duty-suspended excise goods into the UK from EU member states on a consignment-by-consignment basis.

These approval types will only apply to Northern Ireland businesses from 1 January 2021 and will no longer apply to businesses based in Great Britain.

They are not permitted to hold or dispatch excise goods in duty suspension or to receive excise duty-suspended goods from UK suppliers or from outside the EU.

Read more about temporary registered consignees — Northern Ireland only.

Dealing in duty-paid excise goods

If you intend to import into Northern Ireland, or arrange the importation of, excise goods that are duty-paid, or released for consumption, in an EU member state for a commercial purpose, the goods will be liable to excise duty in Northern Ireland.

There are 3 different ways in which duty-paid excise goods can be imported into Northern Ireland from the EU for a commercial purpose:

• the standard duty-paid scheme for unregistered commercial importers
• the registered commercial importer scheme
• distance selling arrangements for sales to private individuals

Unless the goods are being dispatched under distance selling arrangements, movements of duty-paid excise goods between Northern Ireland and EU member states must be covered by a 3-part document known as a Simplified Accompanying Administrative Document (SAAD).

The Standard Duty-paid Scheme — Northern Ireland only

You do not need to be registered with HMRC to use this scheme. However, before commercially importing any duty-paid excise goods, you should notify HMRC by submitting a form HM4 at least 15 working days in advance of the intended date of each dispatch.

You must secure the UK excise duty that is due on the goods by submitting your payment, in the form of a banker’s draft, postal order or cheque, along with the form HM4. HMRC will return the form HM4 to you, endorsed with a unique reference number for that particular consignment.

Your supplier should not dispatch the goods until you’ve notified them of the unique reference number, which should then accompany the goods along with a completed Simplified Accompanying Administrative Document (SAAD). Under the standard scheme, the goods can only be delivered to your business premises, as stated on the form HM4.

You must inform HMRC of any changes to the information you’ve supplied as soon as they occur, and certainly before the goods arrive in the UK.

You must notify HMRC as soon as you receive the goods and then, within 4 working days, return the form HM4 to HMRC along with a copy of the receipted Simplified Accompanying Administrative Document and, if appropriate, payment for any outstanding duty or VAT.

Read about your requirements when receiving duty-paid excise goods.

The Registered Commercial Importer Scheme — Northern Ireland only

This scheme allows you to import duty-paid excise goods into Northern Ireland and defer payment of the duty using your own or someone else’s duty deferment account.

This approval type will apply to Northern Ireland businesses from 1 January 2021 and will not apply to businesses based in Great Britain.

Under this arrangement the duty is guaranteed by the duty deferment guarantee.

Apart from the difference in the duty payment method and the ability to have the goods delivered to other business addresses, the same procedures apply to registered commercial importers as to those traders using the standard duty-paid scheme.

If you want to apply for approval as a registered commercial importer — this applies to Northern Ireland and you’ll need to meet certain criteria, for example, you must have a place of business in Northern Ireland and be able to demonstrate a business need and suitability to be a registered commercial importer.

You should apply for approval by completing and submitting form HM3.

You’ll have to provide a Deferment Approval Number (DAN) on the form HM3, this can be your own or someone else’s.

If you intend to use someone else’s, you will also need to submit a completed form HM8 authority to use another trader’s Deferment Approval Number, for each deferment account you intend to use.

Distance selling of excise goods — Northern Ireland only

Distance selling takes place when a trader in Northern Ireland or EU member state supplies goods to a private individual in Northern Ireland or EU member state and the vendor (seller) is responsible, directly or indirectly, for delivery of the goods. Distance selling includes mail order and internet sales.

When excise goods are being supplied under distance selling arrangements, they must be taken from duty-paid stock. The vendor is liable to pay the excise duty and VAT in Northern Ireland, of the member state of destination at the time of delivery. The excise duty must be guaranteed to the satisfaction of the fiscal authority of destination before the goods are dispatched.

In Northern Ireland, it’s a tax representative approved by HMRC, who guarantees to pay the excise duty on the vendor’s behalf. Following the dispatch, the tax representative must account for and pay the full amount of excise duty and VAT due on the goods sent by the vendor.

When making distance sales to Northern Ireland, it’s the vendor’s responsibility to make sure that a Northern Ireland tax representative is appointed.

Northern Ireland tax representatives are traders who are approved and registered in Northern Ireland, to account for excise duty on distance sales to private individuals in Northern Ireland, on behalf of vendors in EU member states.

If you want to apply for approval as Northern Ireland tax representative, you must have a place of business in Northern Ireland and you must have your own deferment account in place as you’ll need to use it to account for the duty. You are not permitted to use anyone else’s deferment account to account for the duty on distance sales.

You should apply for approval by completing and submitting form HM9.

The requirement to submit a form HM4 for each import of duty-paid excise goods also applies to Northern Ireland tax representatives.

Read about commercial importers and tax representatives.

If you’re a Northern Ireland vendor supplying excise goods to private individuals in EU member states under distance selling arrangements, you’ll be responsible for paying the excise duty and VAT in the member state of destination. You should find out from the authorities in that member state how you must do this, including whether you will need to appoint a tax representative in that member state.

Although there’s no requirement for any official documentation to accompany excise goods moving under distance selling arrangements, it’s advisable that commercial documentation accompanies the consignment showing details of the tax representative in the member state of destination who is to account for the duty.

EU suppliers should also be aware of the rules about registering for VAT when making distance sales to other member states and Northern Ireland.

Read about the UK’s requirements relating to VAT and distance selling.

Read about the statutory VAT obligations for dispatches to EU member states.

UK duty stamps and fiscal marks

If you make or import retail containers of spirits, wine or made-wine, you may need to affix a duty stamp or include one on your label.

You’ll also need to include a fiscal mark if you import or manufacture certain tobacco products in the UK.

Excise duty drawback

Excise duty drawback is a refund of UK excise duty. It’s made when UK duty-paid excise goods have not been and will not be consumed in the UK, providing certain conditions and requirements are met.

Read more about excise duty drawback.