Guidance

Exporting excise goods to the EU in a no-deal Brexit

In a no-deal Brexit, there'll be changes to how you export and declare excise goods (alcohol, tobacco and certain oils).

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After Brexit, exports of excise goods from the UK to the EU will be treated the same as exports to the rest of the world. This includes moving excise goods to a place of export in the UK.

Exporting excise duty paid goods

After Brexit you’ll need to submit an electronic export declaration. If you’re a business, you may be able to recover the excise duty on the exported goods by claiming excise duty drawback.

Exporting excise duty suspended goods

After Brexit you cannot use the Excise Movement and Control System (EMCS) to move excise duty suspended goods directly from the UK to the EU. If you move goods without following the relevant customs export procedures at the place they are exported from, you may be liable for excise duty and penalties. Your goods may also be seized.

If you raise a movement on EMCS to an EU member state 7 days before Brexit with a dispatch date after Brexit the movement will be rejected by EMCS and HMRC.

Moving excise duty suspended goods to the place of export from the UK

You must use EMCS to move excise duty suspended goods from within the UK to the place they are being exported from.

You’ll need to either:

  • ensure the authorised warehousekeeper declares the movement on EMCS when the goods are held in excise duty suspension in their warehouse
  • appoint a registered consignor to move the goods or become a registered consignor - when the goods are being released from a customs control for re-export

The authorised warehousekeeper or registered consignor must:

  • complete and submit an electronic administrative document (eAD) through EMCS before the movement takes place
  • get a unique Administrative Reference Code (ARC) for that specific movement (that EMCS generates)
  • complete a customs export declaration using the National Export System (NES) and enter the ARC in box 40
  • receive an ‘accepted for export’ notification on EMCS after the goods are cleared by customs - this should be generated if the ARC on EMCS matches the details in Box 40 of the customs export declaration
  • receive a ‘report of export’ to ensure the export is closed on EMCS

If the ARC does not match the customs export declaration within 30 days of the customs export declaration being submitted, the warehousekeeper or registered consignor will receive a ‘rejected for export’ notification to remind them that the movement is still open on EMCS. You’ll need to establish why this has happened and take corrective action.

EMCS status Description
‘Accepted’ The customs export declaration has been accepted
‘Rejected for export’ The ARC does not match the customs export declaration on CHIEF
‘Exporting’ The ARC matches the customs export declaration on CHIEF and the goods have been cleared by customs
‘Delivered’ The goods have departed the UK

If you’re a registered excise business or use authorised destinations

After Brexit, the following registered excise businesses and some authorised destinations will no longer be authorised to receive or dispatch excise goods:

  • registered consignee (including movements for direct delivery)
  • temporary registered consignee
  • unknown destination for energy products
  • tax representative (for excise duty on distance sales from the EU)
  • registered commercial importer
  • unregistered commercial importer

Movements to exempt consignees will also no longer be able to take place on EMCS.

If this impacts your business, you’ll need to take steps so that you can continue trading.

If your goods are dispatched before Brexit but received after Brexit

You do not need to complete a customs export declaration in the UK if:

  • the goods are travelling under a recognised excise scheme at that time
  • you can show that the movement started before Brexit

The requirements and any sanctions that may apply to these goods will be based on current UK excise legislation and duty points that apply to EU movements.

HMRC or Border Force may ask for evidence of the date and time your goods were dispatched. You can show this by providing:

If you cannot prove the date and time your goods were dispatched, the movement will be treated in the same way as one that started after Brexit and customs export procedures will apply.

Closing duty suspended movements that started before Brexit but received after Brexit

If your goods arrive at their EU destination after Brexit but were dispatched from the UK before this time (or have not left the EU but were dispatched before Brexit as an indirect export):

  • you will not get a report of receipt or report of export on EMCS
  • the movement will remain open in the system
  • you’ll need to provide an alternative proof of receipt

If you do not receive an endorsed copy of the SAAD back from the EU business for excise duty paid goods, you’ll need to provide an alternative proof of receipt.

Excise duty drawback claims

If you provide HMRC with an EX75 Notice of Intention (NOI) before Brexit but the drawback claim is made after this date, the way you can claim duty drawback will change. HMRC will provide more information about these changes before a no-deal Brexit.

Published 10 October 2019
  1. Step 1 Make sure your business has an EORI number that starts with GB

    You'll need an Economic Operator Registration and Identification (EORI) number starting with GB to continue exporting goods.

    1. Get an EORI number
  2. and Check your importer has an EU EORI number

    Your importer will need an EU EORI number.

    You'll need to get an EU EORI number if you're exporting to your own business within the EU. You can get one from the customs authority in any EU country.

  3. Step 2 Decide who will make the export declarations

    You can hire someone to deal with customs for you, or you can do it yourself.

    1. Find out how to hire someone to make customs declarations for you
    2. Find out how to make customs declarations yourself
  4. and Decide if you want to export your goods using transit

    You may be able to use the Common Transit Convention (CTC) to simplify how your goods pass through customs and when your importer pays customs duties.

    1. Find out if you can use the CTC
  5. Step 3 Check the rate of tax and duty for your goods

    Your importer will need to pay tax and duty on your goods after Brexit. This will depend on the classification of the goods.

  6. Step 4 Check what you need to do for the type of goods you export

  7. Step 5 Find out how changes to VAT will affect you

  8. Step 6 Decide who will transport your goods outside the UK

    You can hire someone to transport your goods, or you can do it yourself.

    1. Find out how to transport goods outside the UK yourself
  9. Step 7 Get help and support