Under Bond vs Duty Paid: Choosing the Right Movement Regime for Spirits

When spirits cross borders, they move under one of two fundamental regimes: under bond (suspension regime) or duty paid. Choosing the right regime can significantly affect cash flow, documentation burden, and delivery speed.

Under-bond movement (suspension regime)

Under this regime, spirits circulate between approved tax warehouses without payment of excise duty. The duty liability is temporarily suspended.

Requirements:

• Both sender and recipient must be registered tax warehouse operators or registered consignees
• Each movement must be pre-declared via EMCS and an electronic administrative document (e-AD) must be opened before departure
• The sender must maintain a valid customs guarantee

Advantages:

• Deferred excise duty payment — lower working capital requirements
• Spirits can be re-exported outside the EU without incurring duty
• Flexibility for consolidation and redistribution across the region

Duty-paid movement

Spirits have been released for free circulation and excise duty has been paid. Further movement to another EU member state for commercial purposes requires a Simplified Administrative Accompanying Document (SAAD).

Suitable for:

• Small commercial movements and B2C sales
• Situations where the recipient is not a tax warehouse operator
• Fast deliveries without EMCS pre-registration requirements

Choosing the right regime

Use the Route & Documents Planner to verify documentation requirements for your specific route and regime.

This information is indicative. We recommend consulting a customs adviser before your first cross-border operation.

Verify documentation for your route

The Route & Documents Planner generates a mandatory document checklist for your specific case. For a detailed analysis, contact our advisory team.