Council Directive 2020/262/EU establishing the general regime of excise taxes provides:

• Explanation of reasons: "...progress is being made in the coordination of customs procedures and special taxes 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 a circulation in suspensive regime of special taxes...

• Art.16 General provisions relating to the place of issue and destination of circulation

1. Products subject to excise duty may be moved under suspensive arrangements between the following places within the territory of the Union, including through a third country or territory:

   1. from a tax warehouse destined for:

   2. 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 Beginning and ending of the circulation of products subject to excise taxes under suspensive regime...

   3. in the cases referred to in Article 16, paragraph 1, letter a), paragraph v), at the time the products are included in the external transit procedure."
      Since the The deadline for the national transposition and entry into force of this procedure was December 31, 2021, pending the same, and in order not to harm economic operators who wish to use this procedure, it has been considered necessary to inform and clarify the same.

In short:

1. From the warehouse or tax warehouse, merchandise will circulate under the suspensive regime with the corresponding IIEE Electronic Administrative Document (eDA), which will be destined for the export customs office.

2. An export declaration will be submitted, whose preceding document, current box 40, will be the eDA, with the customs office of exit the same as the customs office of departure of the transit, current box 29 of the declaration.

3. External transit (T1) must include the export declaration in box 44. In those cases in which it is considered that an indirect departure has occurred, the EAL message must have been presented prior to the presentation of the transit.

   The suspensive regime of II.EE. 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.