Registered consignee or tax warehouse: which one fits you?

Both authorisations let you take delivery of spirits duty unpaid from another member state. That is why advisers often present them as alternatives. In practice they differ on exactly one point, and that point decides your cash position. It is the moment at which German alcohol duty arises.

The difference in one sentence

A registered consignee may accept goods under duty suspension, yet may not keep them duty unpaid. Acceptance into the business ends the arrangement and the duty arises. A warehouse keeper (Steuerlagerinhaber) may leave the goods duty unpaid for as long as they stay in the warehouse. Both routes require the movement to travel under the electronic system EMCS, because only a movement covered by an electronic administrative document counts as taking place under duty suspension (section 13 (1) AlkStG).

Registered consignee: duty on receipt

Registered consignees are persons allowed to receive alcohol products under duty suspension for commercial purposes at their premises in the German tax territory, either on an other than occasional basis or in a single case (section 6 (1) AlkStG). The duty arises through removal from the duty suspension arrangement when the goods enter the business (section 18 (2) no. 4 AlkStG). The registered consignee is the person liable. Whether the goods sell the same day or stand for six months changes nothing.

Tax warehouse: duty on removal

In a tax warehouse the duty arises on removal for consumption, unless a further duty suspension arrangement follows immediately (section 18 (2) no. 1 AlkStG). That lets you take the charge in portions. A customer calls off twenty cases, and only those twenty cases are released for consumption. The rest stays duty unpaid in stock, and where a pallet is exported or shipped within the EU, no German duty arises on it at all.

What the difference means in money

A shipment of 60 cases of six bottles of 0.7 litres at 40 percent ABV contains 100.8 litres of pure alcohol. At the rate of 13.03 euro per litre of pure alcohol (section 2 (1) AlkStG) that is 1,313.42 euro of alcohol duty. The registered consignee owes that amount on acceptance, whether the goods sell the same day or stand for a year.

In a tax warehouse the same amount only arises when the goods actually reach the German market, and then only in proportion. If ten cases are called off in the first month, duty falls on those ten alone. Where the pallet instead moves on under duty suspension to another member state (section 15 AlkStG) or leaves as an export to a non-EU country (section 16 AlkStG), no German alcohol duty arises at any point.

Guarantees and the temporary registered consignee

For other than occasional receipt the statute requires a registered consignee to provide a guarantee covering the duty arising in one month (section 6 (2) AlkStG). For a warehouse keeper the guarantee follows the duty value of the quantity expected to be released for consumption in 1.5 months on an annual average (section 5 (1) AlkStG). Both authorisations require fiscal reliability and proper books.

The reporting side is common to both routes. The consignor draws up the electronic administrative document (section 29 AlkStV), the consignee closes the movement with a report of receipt (section 33 AlkStV), and the duty is self assessed and declared monthly to the main customs office (Hauptzollamt) under section 19 (1) AlkStG. A registered consignee therefore saves the stock ledger and the annual stock report rather than the administration as such.

For one-off shipments there is a narrower variant, the temporary registered consignee (Einzelfallerlaubnis). The authorisation is then limited to a defined quantity, a single consignor and a defined period, and the guarantee covers only the duty arising in that case (section 6 (1) and (2) AlkStG). For a test market or a single bottling run that can be enough. For recurring deliveries from changing consignors the construction does not carry.

The comparison at a glance

How to decide in four steps

1. Check how long your goods typically stand between arrival and sale. Where that is a few days, the cash advantage barely registers.
2. Calculate the duty on an average shipment, meaning volume times strength divided by 100 times 13.03 euro per litre of pure alcohol (section 2 (1) AlkStG).
3. Establish whether shipments are meant to leave Germany for other member states or non-EU countries. If so, you need a tax warehouse.
4. Set the tied up guarantee against the running cost of someone else's tax warehouse and decide on your annual volume.

The third route

You do not have to hold the authorisation yourself. A warehouse keeper with their own authorisation accepts your shipments under duty suspension, keeps the stock ledger and files the duty return, while your goods stay duty unpaid until you call them off. What that covers is set out on our bonded warehouse page, and onward movements within the EU are described under EU shipping under EMCS. To talk your own situation through, write to us with the origin of the goods and their destination afterwards.

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