e-AD and ARC explained: how a movement under duty suspension works

What the e-AD is and who issues it

The electronic administrative document, e-AD for short, declares a movement of goods that still carry unpaid excise duty. German law calls it the elektronisches Verwaltungsdokument, or e-VD. It runs through EMCS, the Excise Movement and Control System, and replaced the old paper accompanying document. The legal basis is Article 20 of Directive (EU) 2020/262. For alcohol products, sections 13 to 16 AlkStG govern the movement under duty suspension, while the procedure itself sits in section 28 AlkStV for taking part in the system and in section 29 AlkStV for issuing the document.

The consignor always issues it. That is either the dispatching tax warehouse (Steuerlager) or a registered consignor who takes the goods over at the place of importation. A consignee cannot create the document and only sees it once their main customs office (Hauptzollamt) passes it on. For you as the buyer that has one consequence: whoever dispatches owns the data.

How the ARC is built

Once the system has validated the draft, it issues the Administrative Reference Code. The ARC has 21 characters and is the key under which every party finds the same movement. The first two digits give the year, the next two the member state, and then follow an identifier for the customs office and a sequential number.

Since 1 January 2023 the twentieth character is a letter marking the sub-procedure. An S means a movement under duty suspension, a P stands for goods already released for consumption. The final character is a check digit. A German ARC therefore reads like 23DE405500000000078P5. This official sample number therefore shows a movement that has already been duty paid, a movement under duty suspension would carry an S at that twentieth position instead.

Six steps through a movement

1. Draft the movement. The consignor records consignee, product, quantity and alcoholic strength. The draft may be submitted no earlier than seven days before the stated date of dispatch.
2. Wait for validation. EMCS checks the entries against the registered master data, above all the authorisations held by consignor and consignee.
3. Receive the ARC. With validation the draft becomes a valid e-AD, and the ARC is returned to the consignor.
4. Load and depart. The driver gets the accompanying document showing the ARC, plus the consignment note and the commercial papers.
5. Take the goods in. The consignee unloads, counts and reconciles against the e-AD. Discrepancies are documented before anything is booked.
6. Report receipt. The consignee reports the receipt through EMCS. Only then does the movement end and the consignor's guarantee is released.

The main messages in plain English

Checking SEED before you dispatch

SEED is the European register of traders authorised to send or receive goods in duty suspension. Look into it before every movement, because an authorisation can have lapsed without the trading partner mentioning it. The check runs through SEED on Europa, the public enquiry service of the European Commission.

Three things get checked: the excise number, its validity, and the categories of goods it covers. A number issued for wine will not help you with a spirits consignment. If the check fails, EMCS rejects the draft anyway and the load sits in the yard. That is why the reconciliation is worth doing before the truck is booked.

Deadlines that drive the case

The report of receipt is due without delay, and at the latest five working days after the movement ends (section 33(1) AlkStV). The main customs office can extend that deadline on request where the delay would otherwise cause undue hardship. In practice the deadline is rarely the problem. Sorting out discrepancies, which has to happen first, is what takes the time.

If the report never arrives, the consignor's guarantee stays tied up, and after a while the authority starts asking. EMCS sends the consignee a reminder before that, which is easy to miss in a busy inbox. Anyone dispatching regularly should review open ARCs once a week. It is a short check that saves a lot of correspondence later.

A second deadline bites earlier. The consignor states a journey time in the e-AD, and if it is exceeded an explanation of delay is due. On ferry routes and long hauls it therefore pays to declare the duration generously rather than optimistically.

When EMCS is unavailable

If the system is down, the goods may still move. The fallback procedure (Ausfallverfahren) then applies, using a paper fallback document that carries the same data as the e-AD. The competent main customs office has to be told about the outage before the first movement begins (section 36 AlkStV), and it may require the papers to be presented in advance.

As soon as EMCS is back, the case is entered retrospectively. The consignor submits the draft late, and the ARC that comes back is noted on the fallback document. The report of receipt follows without delay. The fallback procedure is not a different route, only a different order of events.

Mistakes that keep coming back

The most common one is a wrong excise number for the consignee, copied across from an earlier consignment. The second most common source of trouble is a quantity difference between the e-AD and the actual delivery, often because one pallet stayed behind. Those differences belong in the report of receipt, not in a correction email three weeks later.

A third classic is a product description that works in the trade but tells customs nothing. If the field holds a category instead of the brand and the expression, it will surface at the first inspection. How we handle EU dispatches for customers is set out on the page about shipping within the EU under duty suspension. If you would like to walk through a specific consignment, send us a short message.

Last updated 21 September 2026. This article is not legal or tax advice.