Registered consignor

The role closes a gap at the external border. Release into free circulation for customs purposes ends the customs procedure, and the excise duty would arise at that moment. A registered consignor may instead dispatch the products from the place of import under duty suspension (section 7 (1) AlkStG), so they reach a tax warehouse without duty being paid.

Technically this is an ordinary EMCS movement. The consignor draws up the electronic administrative document before departure (section 29 AlkStV), the movement runs under an ARC and is only discharged by the consignee's report of receipt (section 33 AlkStV).

The main customs office grants the authorisation subject to revocation and checks tax reliability and proper commercial bookkeeping (section 7 (2) AlkStG). The role is only needed where the place of import and the warehouse are not the same: if the import is declared at the warehouse itself, there is no movement left to cover.

The role gets mixed up with the registered consignee. A consignor stands at the start of a movement, not at the end of it. They may not receive goods, let alone store them duty suspended.

The second error is the order of events at the place of import. The electronic administrative document has to exist when the goods set off; finish the customs declaration and only then think about excise, and the duty has already arisen. Without a report of receipt at destination the movement stays open, and the responsibility for that sits with the consignor.