Export of products subject to IIEE under a suspension regime followed by transit
Council Directive 2020/262/EU establishing the general regime of excise taxes provides:
-
Statement of reasons: "...progress is being made in the coordination of customs procedures and excise duties and, in order to allow the use of the external transit regime after the export regime, the customs office of exit is enabled as a possible destination for circulation under the excise duty suspension regime...
-
Art.16 General provisions relating to the place of issue and destination of circulation
-
Excise goods may move under duty-suspension arrangements between the following places within the territory of the Union, including via a third country or territory:
-
from a bonded warehouse to:
-
the customs office of exit, where provided for under Article 329(5) of Implementing Regulation (EU) 2015/2447, which is at the same time the customs office of departure for the external transit procedure where provided for under Article 189(4) of Delegated Regulation (EU) No 2015/2446/;
- Article 19 Commencement and termination of circulation of products subject to excise duty under a suspension regime...
-
in the cases referred to in Article 16, paragraph 1, letter a), point v), at the time when the products are placed under the external transit procedure."
Since the deadline for the national transposition and entry into force of this procedure was 31 December 2021, pending the same, and in order not to harm economic operators wishing to use this procedure, it has been considered necessary to inform and clarify it.
-
In short:
-
From the warehouse or bonded warehouse, merchandise will be transported under a suspension regime with the corresponding Electronic Administrative Document of IIEE (eDA), which will be destined for the export customs office.
-
An export declaration must be submitted, the preceding document of which, current box 40, will be the eDA, with the customs office of departure the same as the customs office of departure of the transit, current box 29 of the declaration.
-
External transit (T1) must include the export declaration in box 44. In cases where an indirect departure is considered to have occurred, the EAL message must have been submitted prior to the submission of the transit.
The II.EE. suspension regime. It will be finalized when both regimes, export and transit, are in turn finalized.
Therefore, in this case the e-AD will have an export regime and the export Customs office will be the destination.