Registered consignee

A registered consignee may take delivery under duty suspension but may not keep the goods duty suspended. Receipt into the business ends the procedure and the duty arises (section 18 (2) no. 4 AlkStG), with the consignee as the person liable. Whether the goods sell the same day or sit for six months makes no difference.

The selling rhythm therefore decides whether the status fits. A trader who passes a consignment on to a single buyer within days loses little. A trader who holds a range that is drawn down over months funds duty on goods nobody has bought yet. And anyone wanting to dispatch onward from Germany under duty suspension cannot do it on this authorisation.

It saves little administration. The authorisation assigns an excise number for each place of receipt (section 16 (3) AlkStV), the EMCS report of receipt and the monthly duty return remain mandatory, as do a file of supporting documents and records of the goods received (section 16 (5) AlkStV). Only the stock ledger falls away.

The status gets sold as the lighter version of a tax warehouse. It is not: the reporting stays and the duty arises at once. The difference becomes visible precisely when the goods sit still.

The second error is using the single case authorisation for ongoing imports. The application has to state the quantity, the type, the alcoholic strength and the consignor (section 16 (7) AlkStV), so the authorisation covers that one constellation only. It does not carry recurring deliveries from changing consignors, and that becomes clear once the second consignment is already on the road.

Third point: this route also requires security, with no exception. For other than occasional receipt the authorisation depends on security covering the duty arising within one month, and in a single case on the duty of that one case (section 6 (2) AlkStG). For a tax warehouse, by contrast, security is only required where there are signs that the duty is at risk.