Warehouse keeper (authorised warehousekeeper)

The authorisation attaches to the person, not to the building. The main customs office grants it subject to revocation and checks tax reliability and proper bookkeeping before it does (section 5 AlkStG). It covers a specific place and a specific range of goods, so storing other products requires an extension.

Liability is the real substance of the role. Duty arises on removal into free circulation, and the person liable is the warehouse keeper, whether or not they caused the removal themselves (section 18 AlkStG). A stock shortfall, a wrong removal, a pallet that cannot be found: the bill goes to them, not to the owner of the goods.

The running obligations follow from that: a file of supporting documents and a stock ledger on the officially prescribed form (section 10 (1) and (2) AlkStV), the monthly duty return (section 19 (1) AlkStG) and the EMCS messages for every inbound and outbound movement.

The most common misunderstanding confuses ownership with responsibility. The goods belong to the customer, the duty is owed by the warehouse keeper. Treating a stock discrepancy as the owner's problem gets the roles the wrong way round.

The second error is stock that only exists in the merchandise system. Every receipt and every removal has to be recorded without delay, and combining removals into free circulation for at most one calendar month needs an explicit permission from the main customs office (section 10 (3) AlkStV).

Third point: the guarantee gets underestimated. Where there are signs that the duty is at risk, the authorisation depends on security covering the duty value of the quantity stored (section 5 (1) AlkStG). It ties up capital or a guarantee line before the first pallet arrives, and it grows with the stock. Anyone planning around the value stored had better budget for it from the start.