Private Labels Vodka for Beginners (EU)

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1. Economic Operator Registration (EORI Number)

Before you can move alcoholic beverages between EU member states, your business must be registered as an economic operator. This is done by obtaining an EORI (Economic Operators Registration and Identification) number. The EORI number is required for customs and excise duties tracking.

• EORI Number: This is used for tracking all imports and exports within the EU. You need this number to engage in cross-border trade within the EU.
  Check your EORI number validation

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2. Excise Duty and Movement of Goods Under Excise Supervision

Even though the EU Customs Union eliminates customs duties between member states, excise duties (taxes on alcohol) must still be paid on alcoholic beverages as they move across borders.

Key Points:

• Excise Duty Suspended in Transit: When alcoholic beverages are moved from one EU member state to another, excise duty is generally suspended if the goods are being moved under the excise duty suspension procedure. This means no excise duty is paid during the transit between member states as long as the alcohol remains in “suspension.”
• This procedure ensures that excise duties are only paid when the goods reach their final destination in the destination member state.
• Excise Movement Control System (EMCS): The EMCS is a computer system used to track goods under excise duty suspension as they move within the EU. The system allows you to send electronic documents to customs authorities to track the movement and confirm that the alcohol has reached its final destination.
• The system ensures that excise duties are paid in the destination country and helps prevent fraud, such as diversion of goods to markets where excise duty has not been paid.
• Registered Consignee: If you are the recipient of the alcohol in another EU member state, you must be a registered consignee with the local customs authority in the destination country. A registered consignee is a business authorized to receive alcohol in the excise duty suspension regime.
  
  Double check your SEED – Excise Authorization Verification once you obtain your Certificate for Registered Consignee. For the moment you can try with our excise duty bonded warehouse registration No.: BGNCA00272001

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3. Value-Added Tax (VAT) and Intra-EU Sales

While excise duties are handled through the excise system, the movement of goods between EU countries is also subject to VAT (Value Added Tax) regulations:

• VAT Exemption for Intra-EU Movements: In general, when alcoholic beverages are moved from one EU member state to another, VAT is not charged at the point of sale between businesses. Instead, the recipient is responsible for paying VAT in their country of establishment, under the reverse charge mechanism.
• The goods are considered an intra-community supply, which means the seller doesn’t charge VAT, but the buyer may need to account for VAT under their local rules.
• The transaction is typically exempt from VAT in the country of origin if both parties are VAT-registered businesses. The buyer accounts for VAT in their country via the reverse charge mechanism.
• VAT Reporting: Businesses must report these transactions on their VAT returns and Intrastat reports (if applicable, depending on the size of the business and the volume of goods moved). These reports track the movement of goods and help ensure proper tax compliance.
  
  Check whether your VAT (Value-Added Tax) is valid.
  KETI 94 OOD VAT Rer. No.: BG200458633

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4. Documentation Requirements

When moving alcoholic beverages between EU member states, you must have the appropriate documentation to comply with excise and VAT regulations:

Required Documents:

• Excise Movement Control System (EMCS) Document: When transporting alcohol under excise duty suspension, you will need to generate an EMCS e-AD (electronic administrative document), which serves as proof that the goods are being transported under excise duty suspension.
• Commercial Invoice: A document listing the goods, their value, and their destination.
• Proof of Receipt: The recipient in the destination member state must confirm receipt of the goods, often through the EMCS system or other local reporting requirements.
• VAT Identification Number (VAT ID): Both the seller and buyer need to be VAT-registered businesses, and both must provide their VAT ID numbers for intra-EU transactions.

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5. Excise Duty Payments and Compliance in the Destination Country

While excise duties are suspended during the movement of alcoholic beverages, the excise duties must eventually be paid in the destination country once the alcohol reaches its final destination. The rules governing excise duties vary slightly across EU member states, so it’s important to understand the specific rules of the destination country.

Key Considerations:

• Excise Duty Rates²: Each EU member state has its own excise duty rates for alcoholic beverages (which differ by type of alcohol—spirits, beer, wine, etc.). Ensure that the correct rates are applied when the alcohol reaches its final destination and excise duty is paid.
• Excise Duty Payment: Once the alcohol reaches the destination country, excise duty must be paid, usually by the importer or registered consignee, before the goods can be sold or distributed.
• Customs Inspections: Authorities in the destination country may conduct inspections to verify that the products are correctly declared and the appropriate excise duties have been paid.

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6. Labelling and Packaging Compliance

Though there is free movement of goods, labelling and packaging requirements for alcoholic beverages may differ across EU member states. Make sure that your alcoholic beverages comply with the following:

• EU-wide Labelling Requirements: All alcoholic beverages within the EU must meet basic EU labelling requirements (e.g., alcohol content, country of origin, ingredients list, health warnings).
• Local Language Requirements: Some member states may require labelling in the local language, or may have specific requirements for health warnings or other product information.
• Product-Specific Labels: Certain types of alcohol (like wine or spirits with geographical indications) may have additional labelling rules (e.g., Protected Designation of Origin or PDO, Protected Geographical Indication or PGI for wines and spirits).

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7. Warehousing and Storage

If alcohol is moving under excise duty suspension, it may need to be stored in a tax warehouse (a facility authorized by the tax authorities to store alcohol under duty suspension) until excise duty is paid in the destination country. KETI 94 OOD is both registered as bonded warehouse and tax warehouse.

• Bonded Warehouses: If the goods are not immediately sold, they may be stored in a bonded warehouse, where excise duties are deferred until the goods are moved or sold.
• Registered Tax Warehouse: Both the sender and the receiver may need to store goods in registered tax warehouses depending on the regulations of the destination country.

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8. Excise Duty Reporting and Record-Keeping

• Record-Keeping: Both the sender and recipient of the alcoholic beverages must keep detailed records of all excise duty movements and VAT transactions.
• Excise Duty Returns: You may need to file regular excise duty returns to report the quantity and type of alcohol moved, as well as the duty paid.

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Summary Checklist for Moving Alcoholic Beverages within the EU:

1. Obtain an EORI number and register as an economic operator.
2. Ensure your business is a registered consignee in the destination country if necessary.
3. Set up and use the EMCS to move alcohol under excise duty suspension.
4. Ensure compliance with excise duty and VAT regulations in both the origin and destination countries.
5. Keep proper documentation: invoices, EMCS documents, proof of delivery, and VAT ID numbers.
6. Be aware of local labelling and packaging requirements in the destination country.
7. Pay excise duty in the destination country and comply with local customs and excise regulations.
8. Ensure that alcohol is stored in a bonded warehouse if needed, under excise duty suspension.

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By adhering to these steps, you can legally and efficiently move alcoholic beverages across EU member states while complying with all necessary tax and regulatory requirements.

Warning Statement: Consult your Local Authorities Before you GO!

Before beginning any activities involving excise goods, especially creating your private label vodka, including the production, distribution, or sale of alcohol, it is essential to consult with your local authorities responsible for excise regulations. Excise goods, such as alcoholic beverages, are strictly regulated, and compliance with local, national, and EU-level legislation is mandatory.

Engaging in early consultation with these authorities provides critical guidance on licensing requirements, tax obligations, safety standards, and other regulatory procedures. Failure to comply with these regulations can result in significant legal and financial consequences, including fines, license suspension, or operational shutdowns.

To ensure your business operates legally and efficiently, reach out to your local excise authority before proceeding with any plans.

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Find out who your local Authorities are

Within the European Union, the responsibility for regulating excise goods, such as alcohol, tobacco, and energy products, primarily lies with national tax and customs authorities in each member state. These agencies enforce EU-wide excise directives while also implementing country-specific regulations and procedures. Here’s an overview of the types of authorities you would contact in the EU:

1. National Tax Authorities: Most EU countries have tax authorities that oversee excise duties, including the licensing, collection, and compliance aspects for excise goods. They are typically the first point of contact for businesses needing information on excise tax rates, licensing processes, and tax filing requirements.
2. Customs Authorities: Customs offices in each EU member state play a key role in regulating the movement of excise goods, particularly across borders within the EU. They ensure that the Excise Movement and Control System (EMCS) is followed, which is the EU-wide system for tracking excise goods under duty suspension.
3. Revenue and Excise Departments: In some EU countries, excise responsibilities are part of a larger governmental department focused on revenue collection or customs and excise. These departments provide guidance on excise taxes, registration, and record-keeping obligations for alcohol producers and distributors.
4. Ministries of Finance or Economy: In several countries, excise duties fall under the Ministry of Finance or Economy. These ministries provide resources and regulatory updates related to excise duties and work alongside tax and customs authorities to oversee excise goods compliance.
5. Local Chambers of Commerce or Industry Bodies: Although not regulatory authorities, local chambers of commerce or industry associations can be valuable resources for businesses entering the excise market. They often offer advisory services, connect businesses with relevant authorities, and help with compliance training.

For specific contact information, you would typically consult the official government websites for tax and customs authorities in your country or seek advice from local professional services familiar with excise regulations in the EU.

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1. In this article we have taken the most popular alcoholic beverage – vodka, but principles are the same and applicable for all other types of alcoholic beverages with HS code that starts with 2208, such as gin, whiskey, brandy, spirits, liqueurs and other liquors… ↩︎
2. Excise duty rates for products made of ethyl alcohol starts from page 34-37. If you want to know what is the excise duty rate for your country please contact us and provide following information: Country – Glass bottle L. – % alc. vol. ↩︎