Apply for your own German tax warehouse or use a provider?

Anyone bringing spirits into Germany regularly reaches the same question sooner or later. Is your own authorisation as a warehouse keeper worth having, or is it smarter to place the goods in someone else's tax warehouse? The answer depends less on the value of the goods than on the quantity you hold inside the procedure permanently, and on your appetite for running a small administrative apparatus.

What the authorisation requires

A warehouse keeper (Steuerlagerinhaber) is anyone operating one or more tax warehouses, and that requires an authorisation (section 5 (1) AlkStG). It is granted on application, subject to revocation, to persons whose fiscal reliability raises no concerns and who, where they are obliged to do so, keep proper commercial books and prepare annual accounts on time. The authorisation attaches to the person rather than to the building. The glossary entry on duty suspension explains what the procedure achieves.

The route to the authorisation in five steps

1. File the application on the official form with the competent main customs office (section 5 (1) AlkStV).
2. Attach site plans of the premises in duplicate, with addresses and the function of the rooms, areas and installations (section 5 (2) AlkStV).
3. Add a statement of operations describing the production, processing and storage of alcohol products in the planned warehouse.
4. Supply the company details, meaning representatives and their powers, any excise authorisations already granted, excise numbers, the EORI number, the competent tax office, the tax number and the VAT identification number.
5. Allow time for the review and the inspection of the premises, because the authorisation only follows afterwards and may depend on a guarantee.

The forms sit in the German federal finance administration's form management system and in the customs portal. Later communication with the main customs office runs through that portal anyway, and registration there takes a few days of its own, so the one-off step is worth completing before you file the application.

The guarantee

Where there are signs that the duty is at risk, the authorisation depends on a guarantee. It is measured on the duty value of the pure alcohol expected to be released for consumption undenatured in 1.5 months on an annual average, calculated at the standard rate of 1,303 euro per hectolitre of pure alcohol (section 5 (1) AlkStG, section 2 (1) AlkStG). The main customs office sets the amount and reviews it regularly (section 7 AlkStV).

An example gives the order of magnitude. A business releasing 50,000 litres of pure alcohol into the German market each year reaches a duty value of 651,500 euro. Divided by twelve months and multiplied by 1.5, the guarantee comes to 81,437.50 euro. That is either tied up capital or a bank guarantee carrying an ongoing commission, and it grows with your sales.

The guarantee is also not a fixed figure. Where fiscal interests are at risk, the main customs office can require security up to the duty value of the actual stock in the warehouse and up to the amount of duty that has arisen but not yet been paid (section 7 (2) AlkStV). Anyone starting with a thin equity base should plan for that case.

What runs on afterwards

The authorisation opens the obligations side. The warehouse keeper maintains a file of documents and a stock ledger on the official form covering every receipt and every removal (section 10 AlkStV). Once a year stock must be taken, and book and physical stock reported within one month together with comments on any discrepancies (section 12 AlkStV). Each month the duty return follows by the tenth day (section 19 (1) AlkStG).

On top of that sits every movement under duty suspension (sections 13 to 16 AlkStG), meaning opening an electronic administrative document on dispatch (section 29 AlkStV) and filing the report of receipt on arrival (section 33 AlkStV). The authorisation must be revoked where fiscal reliability lapses or a requested guarantee is not provided, and it may be revoked where a guarantee provided no longer suffices (section 5 (3) AlkStG). The apparatus therefore runs permanently rather than only at the start.

The comparison at a glance

When your own application pays off

Your own warehouse works out where you already run a building, have enough volume for permanent occupancy and employ staff who handle customs law confidently. The advantage lies in independence and in unit costs that fall as volume rises. The price is a tied up guarantee alongside fixed staff costs. On top of that sits personal responsibility for every entry in the tax warehouse records.

When a provider is the better choice

For importers with fluctuating volumes, for brand owners without their own logistics and for a first entry into the German market, the route through someone else's tax warehouse is usually faster. You tie up no capital in a guarantee and pay only for what is actually moved and stored. The services involved are set out on our bonded warehouse page. If you want to compare the two routes with real numbers, write to us with the volumes you plan for the year.

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