EMCS 2.7: what changes for warehouse keepers and registered consignees

What EMCS 2.7 is

EMCS is the European system through which every movement of duty unpaid goods is declared and closed. It develops in releases, and each release implements a European development stage. Release 2.7 puts EU phase 4.2 into effect. What that means for you depends on how you are connected to EMCS.

Anyone using the internet application in the German customs portal notices little when a release changes, because the customs administration adapts the application itself. Anyone running their own software, or relying on an IT provider, has to act. For exactly these traders, the end of the soft migration on 28 June 2026 is what counts, since then the old version has definitively stopped being a fallback.

The timetable of the change

The soft migration was a transition window. Traders were allowed to keep communicating in the old format for a while although the customs systems had already moved. That window is closed, and traders who missed it find out through rejected messages rather than through a warning.

What changes on exports

EU phase 4.2 mainly concerns how customs and excise interlock on export consignments. Three messages carry that conversation between the systems. The accepted export message (ED829) confirms that the export declaration and the e-AD match. The export rejection message (ED839) reports the opposite case.

The genuinely new one is the message on invalidation of an export (ED836). It tells the excise side when an export declaration has been invalidated. Before that, the EMCS case simply hung there with no clear signal. If you export regularly, this is the change with the most practical effect.

Own software or the internet application

Taking part with your own software requires certification, carried out by the Federal Customs Directorate General (Generalzolldirektion). On top of that come registration for participation, the choice of communication channel and the application for a BIN, the identification number used to sign messages. Applications to change the BIN need at least two weeks lead time, which gets tight in a short notice software change.

The internet EMCS application in the customs portal is the simpler route. It was adapted for the functionality of release 2.7, all cases from the previous version can be carried on according to their processing status, and access rights remain. The price is manual entry, which becomes noticeable with many consignments a month.

Five checks on your connection

1. Get the release confirmed. Ask your software house to state in writing which release your installation communicates in.
2. Follow up the certification. Request the evidence of certification for exactly that version.
3. Review open cases. Every ARC without a report of receipt or export is a candidate for a query from the authority.
4. Reconcile master data. Compare excise number, categories of goods and address in the register against your authorisation.
5. Test the export messages. If you export, your software has to process and display the export messages.

The choice for warehouse keepers

Warehouse keepers with several premises can decide whether to hold communication master data centrally or separately per site. The second option suits decentralised processing, because each site then works with its own credentials. It also brings obligations with it, among them a separate logbook per site.

This decision is rarely taken deliberately and still has a long reach. Changing it means changing the connection, which is not a job for a Friday afternoon. It is worth checking once which variant is recorded for you, and whether it still matches how your operation is organised.

What applies to registered consignees

For registered consignees the scope is smaller, because they neither raise e-ADs nor accompany exports. Their main task in the system is the report of receipt. They are affected all the same, since their connection also has to run on the current release, and a rejected report of receipt leaves the consignor's case open.

A second point concerns master data. Changes to the authorisation, to the categories of goods or to the address have to be maintained in the SEED register, otherwise the entries in the e-AD will not match the recorded data. This regularly surfaces only when a consignor abroad cannot create the movement.

Beer in the e-AD and the role of degrees Plato

Anyone moving beer under duty suspension describes it not by alcoholic strength but by original gravity in degrees Plato. That follows from the tariff, because beer duty is assessed per hectolitre and degree Plato (section 2(1) BierStG). The value comes from the brewery and has to be carried into the declaration.

For businesses that have only moved spirits so far, this is a new data source. Fractions of a degree are disregarded, so the figure is rounded down. If the value is not maintained cleanly per product, it shows up when a consignor abroad has entered it differently from your own stock ledger. How the calculation works in detail is covered in the article on beer duty.

Hand EMCS over instead of running it

There is an answer to the migration question that many overlook, which is not to run EMCS yourself at all. Where your goods sit in a third party tax warehouse, its keeper raises the e-ADs as consignor and files the reports of receipt. They hold the authorisation of the main customs office for that (section 5 AlkStG) and are the party in the system that the movement runs on. Certification, BIN and release changes then stop being your problem.

That works out above all for importers and brand owners who move few but large consignments. What such a warehouse takes on is set out on the page about the bonded warehouse. If you want to weigh up whether running your own connection still pays, send us a short message.

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