Authorised warehousekeepers / registered consignors or consignees - trade with excise goods under a duty suspension arrangement

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Economic operators who wish to import excise goods or carry out intra-Union transactions with such goods while benefiting from an excise duty suspension arrangement must be registered:

  • as an authorised warehousekeeper;
  • or as a registered consignor or consignee.

Failing this, for one-off transactions, economic operators must register with the custom authorities in order to be authorised to act as a temporary registered consignee.

Upon registration, operators receive an excise number which is needed to import, deliver or purchase excise goods.

Economic operators without the necessary authorisation relating to excise duty may appoint a third-party operator who has the necessary authorisation to act on their behalf as a representative in excise duty matters.

It is important not to confuse the status of authorised warehousekeeper / registered consignee, which is required to trade in excise goods, with the status of authorised economic operator (AEO) which gives access to simplified customs procedures.

Who is concerned

Authorised warehousekeeper

An 'authorised warehousekeeper' is a natural or legal person that is authorised, as part of their professional activities, to produce, process, hold or receive, in a tax warehouse, or to dispatch goods subject to excise duty under the excise duty suspension arrangement.

Registered consignee

A 'registered consignee' is a natural or legal person who is authorised, in the context of their professional activities, to receive excise goods from another Member State under a duty suspension arrangement. They are not authorised to hold, dispatch, produce or process this type of goods.

Temporary registered consignee

A business may be authorised to act as a temporary registered consignee if it occasionally receives goods subject to excise duty. A maximum of 6 temporary authorisations will be granted per applicant per year.

Registered consignor

A natural or legal person may be authorised to act as a registered consignor to dispatch, under the duty suspension arrangement, excise goods imported from a third country and already released for free circulation.

Prerequisites

To become an authorised warehousekeeper or registered consignor or consignee, applicants commit to comply with the specific requirements related to their status and which are described in the information notice on the reception/dispatch of excise goods by the Customs and Excise Agency.

How to proceed

Duty suspension arrangement

Authorised warehousekeeper / Registered consignee / Registered consignor

Application for authorisation

To obtain the status of authorised warehousekeeper or registered consignee or consignor, you must contact the Customs and Excise Agency and submit:

  • either an application for authorisation - excise duty suspension arrangement (authorised warehousekeeper or registered consignee) signed electronically with a LuxTrust certificate (see 'Online services and forms');
  • or an application for authorisation - excise duty suspension arrangement (registered consignor) (without LuxTrust certificate) (see 'Online services and forms' - Autorisation en matière d’accise – régime suspensif – expéditeur enregistré).

You must enclose the following documents with your application (scanned if applying electronically):

  • a cadastral survey of the warehouse as well as blueprints of the warehouse where the excise goods are stored (only in the case of a tax warehouse);
  • the business permit;
  • an extract from the Trade and Companies Register;
  • a certificate of VAT registration from the Luxembourg Registration Duties, Estates and VAT Authority (Administration de l'enregistrement, des domaines et de la TVA);
  • the company’s articles of association and the decision to appoint the company manager;
  • the balance sheet for the previous calendar year or, in the case of newly created companies, the business plan;
  • the signatory's proxy (to be provided subsequently to the collector of customs and excise duty);
  • a domiciliation agreement (only for companies that have established their registered office with a domiciliation agent);
  • a declaration in which the represented person instructs the applicant to act as tax representative and certification of the represented person's signature (only for the tax representative);
  • a copy of the LuxTrust approval document (or proof that a LuxTrust application has been submitted).

In the case of an application submitted on paper, the manager of the company must state their full name and:

  • attach a copy of their identity card; or
  • ensure their signature has been legalised by a public authority.

For legal persons, the signatory must state their title and be duly authorised to bind the company.

Once your application is complete, you will be issued with a permanent excise number and the status you require.

Obligations for authorised warehousekeepers

Authorised warehousekeepers must:

  • deposit a guarantee, in principle limited to 10% of the amount of excise duty applicable to the average inventory of excise products produced, processed and held in their tax warehouse;
  • provide, either personally or jointly with the transporter, a guarantee valid throughout the EU which covers the excise duty applicable to the goods being moved under duty suspension; the collector sets the amount of this guarantee based on the volume of transactions;
  • present the goods upon request and submit to any inspections or inventory checks;
  • provide any document requested by the customs authorities for the purpose of control (invoice registers, invoices, copies of letters, cashbooks, inventories and any books, registers, documents and correspondence, etc.);
  • where applicable, present the collector with a power of attorney authorising their representative (e.g. fiduciary) to provide the documents mentioned above that are in their possession;
  • immediately inform the collector of any changes concerning:
    • the structure of the company (articles of association, management, premises, address, place of receipt of goods, etc.);
    • their VAT registration number or business permit;
  • ensure that the receipt and dispatch registers as well as the stock accounts are kept in compliance with the provisions included in the specific conditions attached to the authorisation;
  • at the time of placing an order, provide their excise number to the supplier who must be licensed to operate as an authorised warehousekeeper by the authorities in their home country;
  • respect the specific conditions of their authorisation relating to excise duty, in particular the electronic submission of the Report of Receipt (RoR);
  • submit an AC4 declaration of release for consumption via the LUCCS system within the set deadlines and pay the duties due.

Obligations for registered consignees

The registered consignee must:

  • deposit a guarantee, in principle limited to 10 % of the amount of excise duty applicable to the average inventory of excise goods produced, processed and held in their tax warehouse;
  • present the goods upon request and submit to any inspection or inventory checks;
  • provide any document requested by the customs authorities for the purpose of control (invoice registers, invoices, copies of letters, cashbooks, inventories and any books, registers, documents and correspondence, etc.);
  • where applicable, present the collector with a power of attorney authorising their representative (e.g. fiduciary) to provide the documents mentioned above that are in their possession;
  • immediately inform the collector of any changes concerning:
    • the structure of the company (articles of association, management, premises, address, place of receipt of goods, etc.);
    • its VAT registration number or its business permit;
  • ensure that a receipt register is kept in compliance with the provisions included in the specific conditions attached to its authorisation;
  • at the time of placing an order, provide their excise number to the supplier who must be licensed to operate as an authorised warehousekeeper by the authorities in their home country;
  • respect the specific conditions of their authorisation relating to excise duty, in particular the electronic submission of the Report of Receipt (RoR);
  • submit an AC4 declaration of release for consumption via the LUCCS system within the set deadlines and pay the duties due.

Obligations for registered consignors

Registered consignors must:

  • deposit a guarantee equal to the amount of excise duty applicable to the excise goods they dispatch under duty suspension arrangements. The guarantee must be valid across the whole of the EU. It can be deposited jointly with the transporter;
  • present the goods upon request and submit to any inspection or inventory checks;
  • provide any document requested by the customs authorities for the purpose of control (invoice registers, invoices, copies of letters, cashbooks, inventories and any books, registers, documents and correspondence, etc.);
  • where applicable, present the collector with a power of attorney authorising their representative (e.g. fiduciary) to provide the documents mentioned above that are in their possession;
  • immediately inform the collector of any changes concerning:
    • the structure of the company (articles of association, management, premises, address, place of receipt of goods, etc.);
    • their VAT registration number or business permit;
  • keep a register of consignments and the stock account in accordance with the provisions stated in the special terms and conditions of the authorisation.

Temporary registered consignee

Permit application

To obtain the status of temporary registered consignee, you must contact the collector of customs and excise duty and state:

  • the exact type, quantity and value of the goods to be imported;
  • the name and address of the supplier and, where applicable, their excise number;

Based on this information, the Customs Office determines the amount of the guarantee covering the duties in question which must then be deposited either in cash or by bank transfer.

Moreover, applicants must deposit a surety of EUR 75 in order to guarantee the submission of the declaration of release for consumption AC4.

Once the file is complete, you will receive:

  • either a temporary excise number (for one dispatch and for one product) as a temporary registered consignee (suspension arrangement);
  • or a certificate of guarantee (duty-paid arrangement).

Obligations for temporary registered consignees

Temporary registered consignees must:

  • at the time of placing an order, provide their temporary excise number or a copy of the certificate of guarantee to their supplier;
  • present the goods upon request and submit to any inspections;
  • respect the specific conditions of their authorisation relating to excise duty, in particular: submit an AC4 declaration of release for consumption within the set deadlines and pay the duties due.

Online services and forms

Who to contact

Excise Revenue Office - Luxembourg Centre

  • Customs and Excise Agency (ADA) Luxembourg Revenue Office - Department for Luxembourg Centre

    Address:
    Croix de Gasperich - Rue in Bouler L-1350 Luxembourg Luxembourg

Excise Revenue Office - Luxembourg North

  • Customs and Excise Agency (ADA) Luxembourg Revenue Office - Luxembourg North Department

    Address:
    2, rue de Clairefontaine L-9220 Diekirch Luxembourg

eDouane Helpdesk

General Customs and Excise Inspectorate

  • Customs and Excise Agency (ADA) General Customs and Excise Inspectorate

    Address:
    22, rue de Bitbourg L-1273 Luxembourg-Hamm Luxembourg

Related procedures and links

Procedures

Movement of excise goods (tobacco, alcohol, energy products) within the EU

Links

Further information

Legal references

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