Shipping spirits from the UK to Germany after Brexit: customs, excise duty and EMCS

Duty suspension stops at the border

Before Brexit, a whisky consignment from Scotland to Germany was one single case in EMCS. Today it is two. For excise purposes the United Kingdom is a third country, and a British movement in duty suspension can only end at a UK warehouse or as an export. A British e-AD never reaches your customer's German tax warehouse.

That sounds like more work than it is. The break happens at one clearly defined point, the moment the goods leave the UK. Once you know who picks up which part, the consignment runs as predictably as it did before. What matters is that the German side is ready before the goods arrive at the port.

What happens on the UK side

Your excise warehouse raises an e-AD in the UK EMCS before loading, naming the office of exit from the United Kingdom as the destination. In parallel it files an export declaration in the UK customs system and enters the ARC there. The movement ends when the goods leave the United Kingdom, and the report of export closes it.

Two entries matter most to your German buyer: the commodity code with the product description, and the quantities you declare. Those values feed through the commercial invoice into the German import declaration. If they differ from what is actually on the vehicle, the cheapest moment to fix that is before the trailer boards the ferry.

The German import declaration

In Germany the consignment is declared for import. That requires an EORI number, the commercial invoice, the packing list and the tariff classification. For goods originating in the United Kingdom the Trade and Cooperation Agreement provides a preference, which the importer has to claim and support with a statement on origin made out by you as the UK exporter.

Import VAT arises regardless, at the standard German rate of 19 per cent for spirits. It is deductible as input tax where the conditions are met, but it ties up cash first. How the import clearance plays out in detail depends on whether the goods are cleared at the port or inland.

From the place of importation into the tax warehouse

This is where it is decided whether alcohol duty has to be paid straight away. The duty arises in principle on release for consumption (section 22(1) AlkStG). It expressly does not arise where the products are placed under a duty suspension arrangement immediately at the place of importation.

Only a registered consignor may make that connection. This is a separate authorisation for persons allowed to dispatch alcohol products from the place of importation under duty suspension (section 7(1) AlkStG). They open a new e-AD with a new ARC, and that movement ends at the tax warehouse with the report of receipt. Only there do the goods sit duty unpaid.

Seven steps from the UK warehouse to the German shelf

1. Settle the contract and the Incoterms. Who exports, who imports, and who carries the import charges.
2. Prepare the UK export. The warehouse raises the e-AD and the export declaration and links them through the ARC.
3. Give the German side notice. The tax warehouse and the customs agent get the invoice, the packing list and the arrival time in advance.
4. Move to the place of importation. Either straight by road or under T1 transit from the port to the clearing office.
5. File the import declaration. Tariff, preference and import VAT are assessed.
6. Connect to duty suspension. The registered consignor opens the new e-AD and alcohol duty does not arise.
7. Take the goods into the warehouse. Unloading, reconciliation against the e-AD, report of receipt, entry in the stock ledger.

Documents that have to travel

Routes and what separates them

The quickest route is the trailer across the Channel, usually Dover to Calais and then up the motorway into the Rhineland. The goods are placed under transit at the border and cleared inland. That saves time at the port and moves the paperwork to a place where your buyer already has a contact.

Containers more often run through Rotterdam or Antwerp. There the goods first sit in temporary storage and then continue under transit. This route is cheaper on large volumes but needs more lead time. How we take in import consignments is set out on the page about importing from outside the EU.

What happens without a tax warehouse

With no duty suspension arrangement to follow the import, German alcohol duty falls due on the whole consignment at once. That hits importers hardest when they sell the stock down over several months. They end up financing duty on bottles that are still sitting on a shelf.

A registered consignee does not move that moment either, because duty arises there when the goods are received. Only in a tax warehouse, a place approved by the main customs office for storing and moving goods under duty suspension (section 4 AlkStG), does duty stay suspended until the goods are removed. The main customs office grants that authorisation to the warehouse keeper (section 5 AlkStG). If you are weighing up which set up your German partner should hold, send us a short message and we will walk through it.

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