Customs warehouse

A customs warehouse and a tax warehouse are two procedures with two authorisations, two legal bases and two different charges. The customs warehouse follows Union customs law and concerns import charges on non Union goods, meaning customs duty and import VAT. The tax warehouse follows the Alcohol Duty Act, is authorised by the main customs office and concerns excise duty, whatever the customs status of the goods (section 4 AlkStG).

On import the two levels meet. Alcohol duty arises on release for free circulation, but it does not arise where the products are placed under a duty suspension arrangement directly at the place of import (section 22 AlkStG). Only a registered consignor may create that link (section 7 AlkStG). They open an e-AD which ends in the tax warehouse with the report of receipt.

In practice: a customs warehouse defers customs duty and import VAT, but it does not keep alcohol duty open. Conversely a tax warehouse does not remove a customs debt. Anyone using only one of the two needs to know which charge is suspended and which falls due at once.

The most common mistake sits in the wording. Quotations describe a warehouse said to cover customs duty and excise duty at once, as if that were a single authorisation. There are two, and a service provider often holds only one of them. The question is therefore not whether there is a warehouse, but which authorisation stands behind it.

The second mistake costs money straight away: the consignment is imported without a registered consignor having been named beforehand. The goods then go into free circulation and alcohol duty falls due, even though the tax warehouse was ready.