For any winery exporting to European markets, understanding excise duties is not optional. These taxes, levied on the production and consumption of alcohol, vary dramatically across EU member states and can represent a significant portion of the final retail price.
What Are Excise Duties?
Excise duties are indirect taxes levied on the production, processing, or consumption of specific goods deemed to have a particular societal impact: alcohol, tobacco, and energy products. For wine and spirits exporters, these taxes are a day-to-day operational reality.
Unlike VAT (which applies to almost all goods), excise duties are product-specific and calculated per unit of volume or per degree of alcohol — not on the value of the goods.
Key point
Excise duties are due in the destination country, at the moment goods are released for consumption (consumed or commercialized). During transit, goods moving under suspension of duties generate no tax.
The European Legal Framework
The European Union has harmonized the excise duty regime around several founding texts:
- Directive 92/83/EEC: minimum rates for alcoholic beverages (still in force, amended several times)
- Directive 92/84/EEC: rate approximation — sets the minimum floors that member states cannot lower
- Regulation 2020/262/EU (the 'Horizontal Directive'): modernizes movements of excise goods, in force since February 13, 2023
- EMCS: Excise Movement and Control System — electronic tracking system for movements under suspension
The 2020/262 reform notably made mandatory the use of the e-AD (electronic Administrative Document) for all intra-EU movements under suspension, definitively replacing paper documents.
Wine Excise Duty Rates: European Comparison
The EU sets a MINIMUM rate. Member states can — and often do significantly — apply rates well above the minimum. Here is the situation for still wine (≤ 15% ABV):
| Country | Still wine rate |
|---|---|
| Germany 🇩🇪 | €0/hl |
| France 🇫🇷 | €3.77/hl |
| Italy 🇮🇹 | €0/hl |
| Spain 🇪🇸 | €0/hl |
| Belgium 🇧🇪 | ~€48/hl |
| Netherlands 🇳🇱 | ~€57/hl |
| Denmark 🇩🇰 | ~€115/hl |
| Sweden 🇸🇪 | ~€295/hl |
| Finland 🇫🇮 | ~€330/hl |
| United Kingdom 🇬🇧 | £2.67/bottle |
* Indicative rates 2025-2026. Always verify official rates with national tax authorities.
The EMCS: The Excise Tracking System
The Excise Movement and Control System (EMCS) is the EU electronic platform for tracking movements of excise goods between member states under suspension of duties.
Here is how a typical movement works:
Create the e-AD
The consignor (authorized warehouse keeper or registered consignor) creates an electronic administrative document in their national system connected to EMCS.
ARC code generation
The EMCS generates an Administrative Reference Code (ARC) — a unique code identifying the movement. This code accompanies the goods.
Transit
Goods travel under suspension of duties. The ARC allows any control authority to instantly identify the movement.
Receipt and closure
The consignee (registered consignee or authorized warehouse keeper) acknowledges receipt in the EMCS within 5 working days. Closure releases the consignor from liability.
DAE and GAMMA2: The French Wine Specificity
In France, the DAE (Document d'Accompagnement Électronique) is the national implementation of the European e-AD, managed via the GAMMA2 system of the DGDDI (French Customs and Indirect Taxes Directorate).
GAMMA2 is the management system for wine and certain fermented beverage movements. It is specific to France and complements the EMCS for wine industry specificities (harvest declarations, production declarations, stock management).
What GAMMA2 manages for a wine consignor:
- Creation of the DAE (e-AD) for each suspended movement to another member state
- Management of internal movements (between authorized warehouses)
- Stock and production declarations (annual and monthly)
- Tracking of ARCs and EMCS closures
Who Pays What, and When?
The timing of excise duty payment depends on the fiscal regime under which the movement takes place:
Under suspension of duties
No excise paid at dispatch. The consignee (authorized warehouse keeper or registered consignee in their country) pays the duties when releasing goods for consumption. Standard regime for B2B professional intra-EU transactions.
Duty-paid
Excise duties are paid in France before dispatch, at the French rate. A reimbursement procedure can be initiated with the destination country if it is the member state where duties must ultimately be settled. Complex in practice — avoid except in specific cases.
Post-Brexit UK: A Separate Regime
Since January 1, 2021, the United Kingdom applies its own excise duty regime, entirely disconnected from the EMCS. Since August 2023, the British system moved from a flat-rate regime to an ABV-based system.
- Still wine 11.5-14.9% ABV: £2.67 per 75cl bottle
- Sparkling wine 11.5-14.9% ABV: £2.67 per 75cl bottle (harmonized with still wine since 2023)
- UK import: C88 declaration to HMRC is mandatory
- UK importer must hold AWRS (Alcohol Wholesaler Registration Scheme) approval for commercial purchases
- No EMCS/e-AD: the movement is entirely governed by UK law
Common Mistakes and How to Avoid Them
✕ Not creating the DAE before goods depart
Customs infringement that can lead to seizure and a fine. The DAE must be created and the ARC generated BEFORE the physical movement begins.
✕ Shipping to a non-authorized consignee
The consignee must be either an authorized warehouse keeper or a registered consignee in their member state. Shipping to a private individual without a DAE means excise duties are due in France.
✕ Incorrect HS code (2204 vs 2208)
Wines fall under 2204, spirits under 2208. Confusion leads to an incorrect declaration and potentially a tax reassessment.
✕ ABV mismatch between label and declaration
Grounds for customs hold. The declared rate must exactly match the label.
✕ Non-closure of EMCS by the consignee
The consignor remains liable for suspended duties until closure is confirmed. Actively monitor the status of your movements.