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In line with what we previously reported[1] regarding the expanded obligation to maintain electronic registers, a series of new rules were rolled out on 13 February 2023 which will make the taxation of alcohol, tobacco and energy products fully paperless across the EU. They are part of a wider expansion of the common excise duty provisions in the EU.

The aim of this new standardised electronic system is to alleviate some of the rigorous procedures faced by energy suppliers and small producers of alcohol. Under these new measures, all traders moving excise goods from one Member State to another will only need to submit digital transaction information into the already existing EU Excise Movement and Control System (“EMCS”) which was previously reserved for goods moved under duty suspension.

With this measure comes a series of documentary requirements for all excise goods which are transported between Member States. Starting 13 February 2023, goods under duty paid must be accompanied by an Electronic Simplified Administrative Document (eSAD). As a transitional measure, for movements of goods under duty paid initiated before 13 February 2023, a paper-form Simplified Administrative Accompanying Document (SAAD) can be used to finalise the movement until 31 December 2023. The Electronic Administrative Document (eAD) for goods which are under duty suspension remains.

The new standardised electronic system is aimed at simplifying life for traders and helping authorities fight excise duty fraud. The hope is that the processing and validation in real-time of the movements, dispatch and receipt of these excise goods will achieve this goal.  

The rules establishing the content and structure of required electronic documents can be found here.

[1] Based on the following update: All excise duty transactions in the EU become fully electronic as of 13 February (


Thomas Kukanza is a Senior Trade Advisor in Baker McKenzie, Brussels office.


Johanna Asplund is an associate at the Firm’s London office in the Competition, Trade and Foreign Investment Practice Group. She completed her degree in International Relations from London School of Economics then a Graduate Diploma in Law and Legal Practice Course (LLM) from BPP University in 2019.

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