Change description : 2025-04-07 00:30:00: The ‘Distance selling of excise goods – Northern Ireland only’ has been updated to reflect the new process explained in Excise Notice 204b. [Guidance and regulation]
When excise goods are moving in excise duty suspension within the UK or EU (for Northern Ireland movements only), the movement must take place between a person and premises that have been approved for that purpose by the competent authorities in the UK or EU member state where they are based.
Excise goods may only be moved in excise duty suspension once they are in ‘free circulation’.
In the UK this covers goods that have been wholly produced in the UK, or goods that have been imported into the UK and for which all import formalities have been completed and any customs duties due have been paid.
For Northern Ireland, it can also mean goods imported into the EU for which all import formalities have been completed and any customs duties or associated charges due have been paid.
Movement guarantees
Generally, excise goods that are moving within the UK, or between the EU and Northern Ireland in excise duty suspension, must be covered by financial security in the form of a movement guarantee.
It is the consignor’s responsibility to make sure that a valid movement guarantee is in place, with detail of the guarantee recorded on the appropriate movement documentation prior to the goods being dispatched in duty suspension.
All duty-suspended movements of excise goods taking place within the UK, or between the EU and Northern Ireland, must be recorded on the Excise Movement and Control System unless the goods are allowed to move under simplified procedures.
If you’re based in the UK and intend to receive, store and dispatch ‘free circulation’ excise goods in duty suspension, you’ll need to have your premises approved as an excise warehouse, which is a specific type of tax warehouse. As the operator of the excise warehouse, you will also need to be approved as an authorised warehousekeeper.
An excise warehouse is any place of security approved by HMRC, where goods liable for excise duty can be stored without payment of the duty, for such periods and subject to such conditions as they see fit.
Excise duty is suspended whilst goods are held in an excise warehouse, but you must get permission from HMRC if you intend to store duty-suspended and duty-paid goods in the same premises, this is known as co-storage.
The 3 categories of excise goods that can be held in an excise warehouse in duty suspension are:
alcoholic products including beers, wines and spirits
tobacco products including cigarettes, cigars, loose tobacco and tobacco for heating
energy products including hydrocarbon oils and biofuels for use as motor or heating fuel
HMRC does not allow UK-manufactured tobacco products intended for use in the UK to be stored in an excise warehouse.
Such goods can only be warehoused if they are intended for a duty-free purpose such as:
goods for export
for sale from an export shop
for supply to embassies within the UK
for use by visiting forces
for use as ship, aircraft or train stores
General storage and distribution warehouses
These are premises used for the general storage and dispatch of alcoholic products and tobacco goods in duty suspension.
In order for these premises to have been considered for approval before 1 June 2022, they must have met the minimum throughput levels:
a minimum potential duty liability of £500,000 on the average monthly stockholding of duty-suspended excise goods
a duty liability of at least £2 million on an annual throughput of duty-suspended excise goods
To be considered for approval from 1 June 2022, you must be able to demonstrate that:
there is a real economic need to store goods under excise duty suspension arrangements at these premises
you will have enough clients or business to run the excise warehouse as a viable going concern
These are premises where excise goods can be stored in duty suspension for one of the following purposes:
the maturation of spirits
goods which will not bear UK excise duty, for example, goods for export, goods used in pharmaceuticals, goods used in foodstuffs, goods to be removed for use as ship, aircraft or train stores
performing an allowable operation on the goods
any other purpose allowed by HMRC
Trade facility warehouse approval is restricted to the specific trade need applied for, for example, the warehouse approval may be limited to the storage of spirits for bottling.
You can also receive, store and dispatch ‘free circulation’ alcoholic products in duty suspension if you are an alcoholic products producer and have the appropriate authorisation under your Alcoholicalcoholic Productsproducts Producerproducer Approvalapproval (APPA).
Excise warehousekeepers are responsible for accounting for all excise goods entering or leaving their warehouse premises.
Importing excise goods — registered consignors
If you’re an authorised warehousekeeper receiving excise goods that have been imported and the intention is to store those goods free of all duties, you must hold customs warehouse approval for your premises.
If the person importing the goods wants to suspend the excise duty only, they must arrange for the goods to be placed in an approved excise warehouse. However, this can only be done once the excise goods have been released to free circulation on completion of all import formalities and payment of any customs duties.
The excise duty-suspended movement from the place where the goods are released to free circulation, for example a port or airport in the UK, to the excise warehouse must be carried out by someone who is approved as a registered consignor. Read more about the requirements for excise goods held in duty suspension in a warehouse.
HMRC will generally only consider approving the import agent for the goods, the authorised warehousekeeper receiving the goods from the place of release for free circulation, or the person who dispatches duty-suspended goods to a place of exit from Great Britain (England, Scotland and Wales), for the purposes of exporting those same goods out of the UK at a place of exit in Northern Ireland as a registered consignor.
If you want to apply for approval, you must complete and submit:
Where excise duty-suspended goods move directly from a warehouse in Great Britain to a warehouse in Northern Ireland, HMRC will deem the warehousekeeper who provided the movement guarantee as the registered consignor for entry into Northern Ireland.
If you’re the dispatching warehousekeeper exporting duty-suspended excise goods from the UK you must make sure that you fully comply with all excise requirements, as well as any separate customs export declaration requirements.
All authorised warehousekeepers (except those currently operating certain trade facility warehouses such as export shops and aircraft store floors) are required to submit a W1 excise warehouse return for each set of premises they operate, in respect of alcohol and tobacco goods.
You can submit your W1 returns electronically using the Alcohol and Tobacco Warehousing Declaration (ATWD) online service.
When goods are released from an excise warehouse for consumption, you must make sure that the excise duty has been paid or accounted for prior to the removal of the goods.
For immediate payment of duty you must use cash or an equivalent method such as:
a banker’s draft
Bacs (Bankers Automated Clearing System)
CHAPS (Clearing House Automated Payment System)
If payment is being made by cash or equivalent, you should submit the following payment warrants to HMRC along with the remittance:
If you’ve been approved to defer payment of the excise duty and want to account for the duty under deferment arrangements, you must submit the following warrants to HMRC:
In order to defer duty, you’re normally required to take out a guarantee to cover your total monthly liabilities. Under the Excise Payment Security System you may be able to defer payments of excise duty without a guarantee.
Registered consignees
Registered consignees are revenue traders who are approved and registered by HMRC to receive and account for the duty on duty-suspended excise goods from EU member states.
These approval types only apply to Northern Ireland-based businesses. They do not apply to businesses based in Great Britain.
They must account for the UK excise duty when the goods are received in the UK.
They cannot receive duty-suspended excise goods from outside the UK or EU (not to be confused with registered consignors) and they cannot hold or dispatch goods in duty suspension.
Temporary registered consignees are excise traders that are registered and approved by HMRC to import duty-suspended excise goods into the UK from EU member states on a consignment-by-consignment basis.
These approval types only apply to Northern Ireland-based businesses. They do not apply to businesses based in Great Britain.
They are not permitted to hold or dispatch excise goods in duty suspension or to receive excise duty-suspended goods from UK suppliers or from outside the EU.
If you intend to import into Northern Ireland, or arrange the importation of, excise goods that are duty-paid, or released for consumption, in an EU member state for a commercial purpose, the goods will be liable to excise duty in Northern Ireland.
There are 3 different ways in which duty-paid excise goods can be imported into Northern Ireland from the EU for a commercial purpose:
the Temporary Certified Consignee Scheme
the Certified Consignee Scheme
distance selling arrangements for sales to private individuals
The Temporary Certified Consignee Scheme — Northern Ireland only
Before commercially importing any duty-paid excise goods, you should notify HMRC by submitting form HM4HM4b at least 15 working days in advance of the intended date of each dispatch.
You must secure the UK excise duty that is due on the goods by submitting your payment, in the form of a banker’s draft, postal order or cheque, along with the form HM4.HM4b. HMRC will return the form HM4HM4b to you, endorsed with a unique reference number for that particular consignment.
You must inform HMRC of any changes to the information you’ve supplied as soon as they occur, and certainly before the goods arrive in the UK.
The Certified Consignee Scheme — Northern Ireland only
This scheme allows you to import duty-paid excise goods into Northern Ireland and defer payment of the duty using your own or someone else’s duty deferment account.
This scheme applies to Northern Ireland-based businesses only. It does not apply to businesses based in Great Britain.
Under this arrangement the duty is guaranteed by the duty deferment guarantee.
Apart from the difference in the duty payment method and the ability to have the goods delivered to other business addresses, the same procedures apply to certified consignees as to temporary certified consignees.
Distance selling of excise goods — Northern Ireland only
Distance selling takes place when a trader in Northern Ireland orsupplies EUgoods memberto statea private individual in the EU, and when a trader in the EU supplies goods to a private individual in Northern IrelandIreland. orIn EUeach membercase, statein anda thedistance vendorselling (seller)arrangement the consignor is responsible, directly or indirectly, for the delivery of the goods.Distancesellingincludesmailorderandinternetsales.
When excise goods are being supplied under distance selling arrangements, they must be taken from duty-paid stock. The vendorconsignor is liable to pay the excise duty and VAT in Northern Ireland, ofor the EU member state of destination at the time of delivery. The excise duty must be guaranteed to the satisfaction of the fiscal authority of destination before the goods are dispatched.
In Northern Ireland, it’s a tax representative approved by HMRC, who guarantees to pay the excise duty on the vendor’sconsignor’s behalf. Following the dispatch, the tax representative must account for and pay the full amount of excise duty and VAT due on the goods sent by the vendor.consignor.
When making distance sales to Northern Ireland, it’s the vendor’sconsignor’s responsibility to make sure that a Northern Ireland tax representative is appointed.appointed to account for the duty on your behalf. Alternatively, the consignor could submit a completed HM4c form along with the necessary payment to secure the duty in the UK.
Northern Ireland tax representatives are traders who are approved and registered in Northern Ireland, to account for excise duty on distance sales to private individuals in Northern Ireland, on behalf of vendorsconsignor’s in EU member states.
If you want to apply for approval as Northern Ireland tax representative, you must have a place of business in Northern Ireland and you must have your own deferment account in place as you’ll need to use it to account for the duty. You are not permitted to use anyone else’s deferment account to account for the duty on distance sales.
If you’re a Northern Ireland vendorconsignor supplying excise goods to private individuals in EU member states under distance selling arrangements, you’ll be responsible for paying the excise duty and VAT in the member state of destination. You should find out from the authorities in that member state how you must do this, including whether you will need to appoint a tax representative in that member state.
Although there’s no requirement for any official documentation to accompany excise goods moving under distance selling arrangements, it’s advisable that commercial documentation accompanies the consignment showing details of the tax representative in the member state of destination who is to account for the duty.duty or evidence that the duty has been paid in Northern Ireland or the member state of destination.
EU suppliers should also be aware of the rules about registering for VAT when making distance sales to other member states and Northern Ireland.
If you make or import retail containers of spirits, wine or other fermented products (previously called made-wine), you may need to affix a duty stamp or include one on your label.
You’ll also need to include a fiscal mark if you import or manufacture certain tobacco products in the UK.
Excise duty drawback
Excise duty drawback is a refund of UK excise duty. It’s made when UK duty-paid excise goods have not been and will not be consumed in the UK, providing certain conditions and requirements are met.
The 'Can you store goods in an excise warehouse' and 'Apply for approval' sections have been updated.
1 February 2025
Information about Alcoholic Products Producer Approval (APPA) has been added to the section 'Storing excise goods in duty suspension in the UK'.
24 March 2023
References to 1 January 2021 have been removed.
10 February 2023
You can now use the Temporary Certified Consignee Scheme and the Certified Consignee Scheme to import duty-paid excise goods into Northern Ireland from the EU.
18 May 2022
The sections on 'General storage and distribution warehouses' and ‘Trade facility warehouses’ have been updated to include changes being introduced from 1 June 2022, and a link added to tell you about those changes. General storage and distribution approval throughput requirements are being replaced with a requirement to show a genuine economic need for the approval. Trade facility warehouse conditions concerning storage times are also updated.