HS 22.01 – 22.03 · 22.08

Beverages & spirits

Beverages are the category where the tax travels with the goods rather than with the invoice. A pallet of spirits can sit at nil duty in a tax warehouse for a year and turn into a large cash liability the moment somebody signs it out of duty suspension, which is why most of the work in this category happens before a container is ever booked.

Unlabelled spirit bottles and a cut-crystal tumbler on dark stone
§ What we trade

What we trade in this category

  • Distilled spirits in 700 ml glass the EU permitted range under Directive 2007/45/EC includes 700 ml and not 750 ml, so a fill built for the Americas cannot be sold in Europe, and travel retail wants its own litre
  • Rakija and other fruit distillates stone-fruit spirits carry an ethyl carbamate exposure and a methanol ceiling that only a certificate of analysis closes out
  • Malt beer in cans and glass cans travel and green or clear glass goes light-struck; unpasteurised beer needs a cold chain nobody costed
  • Natural mineral water the recognised source is the asset — it must be bottled at source and cannot be disinfected, so there is no second factory to fall back on
  • Carbonated soft drinks in PET PET is permeable, so carbonation loss sets the shelf life long before the liquid does, and that clashes with arrival-freshness rules in the Gulf
  • Energy and functional drinks caffeine above 150 mg/l pulls a mandatory warning statement in the EU, and selling the drink as an energy drink at all pulls the 100 % band in the GCC
  • Liqueurs and cream-based spirits the emulsion breaks at both ends of the temperature range, which rules out a top-tier stow on a Red Sea routing
§ How we select

How a supplier and a product get chosen.

01

Establish the right to sell

Before anything else we establish who owns the trade mark in the destination and whether the seller has the right to put the goods there. Genuine stock first placed on the market outside the EEA cannot be imported into the EU without the proprietor's consent, and removing or obscuring lot codes to hide the diversion gives the proprietor a legitimate reason to oppose the resale. We ask for the brand owner's authorisation in writing, or we treat the offer as a parallel line and price the risk openly.

02

Read the excise status

A quoted price means nothing until you know whether it is ex-works under duty suspension, duty-paid in the country of dispatch, or already released for consumption. Duty-paid stock moving cross-border needs a certified consignor, a certified consignee and an e-SAD, plus a refund claim in the dispatch state that often never lands, so we buy in bond wherever the seller holds a tax warehouse authorisation. Where they do not, we bring in a warehousekeeper who does and structure the movement through them.

03

Test the label against the destination

We build the destination label file before the order, not after the container arrives. For spirits that means the legal name and minimum strength under Regulation (EU) 2019/787, the actual alcoholic strength declared as "% vol" within the 0.3 tolerance, allergen declarations for sulphites over 10 mg/l and for milk in cream liqueurs, and a permitted nominal quantity. For the Gulf and the mainland it means an Arabic or Chinese back label agreed with the importer and the GACC registration number carried on both inner and outer packaging.

04

Sample and analyse

We take bottles from the intended production, not from the sales kit, and put them through a laboratory panel that matches the sub-category: methanol and higher alcohols for fruit spirits, ethyl carbamate for stone-fruit distillates, a microbiological and constituent panel for water including bromate where ozone-enriched air is used. Retention samples stay with us and with the supplier against the same batch codes. A certificate of analysis that does not name the batch is not a certificate of analysis.

05

Price the pallet, not the case

Beverages weight out long before they cube out. A twenty-foot box of glass or water hits its payload with the container half empty, glass adds tare that earns nothing, and breakage on a badly patterned pallet is charged to whoever signed the delivery note. We fix the case count, pallet pattern and container type at quotation stage so the landed cost per litre is real.

§ Development

Development and design.

Design

Liquid and specification

Own-label work starts with a written specification: base spirit or water source, target strength and the declared strength, sugar and acid profile, permitted additives and flavourings under the EU additive and flavouring regulations, and the analytical limits the batch must meet. We agree the tolerance band with the co-packer or distillery in the specification, because the label declaration is a legal statement and the fill line is what has to hit it. Where a geographical indication is involved we design the product to sit outside it or qualify for it, never near it.

Design

Bottle, closure and pack

Glass weight is a freight decision and a shelf decision at the same time, so we specify it deliberately rather than accepting the mould the factory already owns. Single-use plastic beverage containers up to three litres sold in the EU need closures that stay attached, glass and metal bottles sit outside that rule, PET has recycled-content obligations, and measuring-container bottles carry their own marking. Tamper evidence, capsule type, case count and pallet pattern are all fixed in the same document.

Design

Artwork and market versions

We hold one master artwork and a controlled variant per market, because a spirits label that is legal in Serbia has no route into Saudi Arabia at all and a soft drink label that passes in Portugal will not clear Chinese customs against GB 7718. Batch and best-before coding is designed into the artwork with a clear print area — laser on glass, ink on carton — since dates applied on a sticker are rejected outright in parts of the Gulf, and the date format is day, month, year. Every version is approved before the plates are cut.

Design

Shelf life you can defend

We set the declared shelf life from storage trials on the actual pack, not from a category rule of thumb: carbonation loss and acetaldehyde pick-up in PET, oxidation and light exposure in beer, chill haze in non-chill-filtered spirits. That declared life then drives the shipping calendar, because several destinations refuse consignments that arrive with less than half of it remaining. Getting this wrong destroys a container after it has already been paid for.

§ Our part

What we do that a broker does not.

A

We run the excise movement

We open the electronic administrative document, carry the ARC onto the export declaration so customs and excise reconcile, and chase the report of receipt or report of export until the movement closes. An undischarged movement leaves the guarantee engaged and the duty at risk against somebody's name, usually the consignor's. We treat closing the movement as part of the delivery, not as paperwork that follows it.

B

We order and reconcile duty stamps

Where the destination requires fiscal marks — Serbia's control excise stamps carrying a QR code are the live example on our lanes — we enter the importer in the Customs Administration's register, request the stamps through the e-excise system, and get them applied at the bottling line or in a customs warehouse before release. Stamps are serialised and every one has to be accounted for, including the ones destroyed in application. We count them back and file the reconciliation.

C

We hold the balance against inspection

We book a pre-shipment inspection against the specification and the approved artwork, photograph the loading and the container seal number, and put a temperature logger in the box on heat- or freeze-sensitive lines. The balance payment is released when the inspection passes, not when the booking is made. If the artwork on the line is not the approved version, the container does not load.

D

We own the destination file

We assemble and keep the importer's file: the certificate of origin and preferential origin proof, the certificate of free sale and, on aged spirits, the certificate of age and origin, the batch certificates of analysis, the registration or licence numbers the destination requires, and the label approval. When an inspector opens the file at the border it is complete and the numbers on the documents match the numbers on the pallets.

E

We stage stock in bond

For programmes with a seasonal peak we hold stock in a bonded or duty-suspended warehouse near the market and release for consumption only against confirmed orders, so the duty and the local tax fall due when the goods sell rather than when they land. Title and risk transfer are written into the arrangement rather than assumed. This is how a Q4 or a Lunar New Year programme is funded without paying tax on stock that is still on a rack.

§ Documents

What the paperwork actually is.

The document set below is what this category needs to clear. We raise it rather than forwarding a checklist.

  • EU excise: movements under Directive (EU) 2020/262, opened as an e-AD in EMCS against an ARC and discharged by a report of receipt or a report of export; duty structures and the small-producer certificate under Directive 92/83/EEC as amended.
  • Spirit drinks: legal name, category, minimum strength and permitted practices under Regulation (EU) 2019/787; geographical indications under Regulation (EU) 2024/1143; single malt Scotch may only be bottled in Scotland under the Scotch Whisky Regulations 2009.
  • Labelling and quantity: allergens, net quantity and actual alcoholic strength under Regulation (EU) No 1169/2011, including the high-caffeine statement above 150 mg/l; permitted nominal quantities under Directive 2007/45/EC; lot marking under Directive 2011/91/EU.
  • Water and non-alcoholic: natural mineral water recognised and marketed under Directive 2009/54/EC, with constituent limits, the fluoride statement and ozone-enriched air conditions under Directive 2003/40/EC; contaminant limits under Regulation (EU) 2023/915; additives and flavourings in soft drinks under Regulations (EC) No 1333/2008 and No 1334/2008.
  • Packaging: tethered closures and recycled-content obligations under Directive (EU) 2019/904, the Packaging and Packaging Waste Regulation (EU) 2025/40 applying from 12 August 2026, and national extended producer responsibility and deposit return registrations.
  • Destination files: GACC Decree 248 CIFER registration and Chinese label filing for the mainland; SFA importer registration and a TradeNet permit for Singapore; import and export declarations, a Customs and Excise import licence with a per-shipment permit for liquor above 30 % abv, and food importer registration for Hong Kong; GSO 9 Arabic labelling, with SFDA clearance for Saudi Arabia and Food Import and Re-export System registration for the UAE; no alcohol enters Saudi Arabia or Kuwait at all; importer registration and control excise stamps for Serbia.
§ Corridors

How it moves.

Spirits, beer and fruit distillates move out of the EU, Portugal and Serbia into Hong Kong, Singapore and Greater China, where Hong Kong charges on declared value above 30 % abv, Singapore charges per litre of alcohol and the mainland adds a consumption tax and where the gifting calendar — Christmas, Lunar New Year, Mid-Autumn — sets the sailing date months before the buying decision feels urgent. Water and soft drinks run on the opposite logic: weight-out freight on thin margins, so they only work as full containers into markets where the excise, sugar levy or GCC beverage tax is known in advance and priced into the landed cost rather than discovered at clearance.

See the lanes we run

§ Questions

What buyers ask first.

Can you sell us duty-paid, or does it have to move in bond?

Both, but they are different deals. In bond, the duty falls due where and when you release the goods for consumption, and the movement has to close properly in EMCS or the guarantee stays engaged. Duty-paid across a border still runs in EMCS, as an e-SAD between a certified consignor and a certified consignee, and the duty already paid has to be reclaimed in the country of dispatch — slow, and sometimes not recoverable, so we price it as a cost rather than as a receivable.

Who is the importer of record, and who holds the licence?

You do, in almost every case, because the liquor licence, the excise authorisation and the food importer registration are held locally and cannot be lent. We work behind a licensed importer or a bonded warehousekeeper in the destination and handle the supplier side, the documents and the movement. Where you do not have those permissions yet, we will tell you which ones you need before we quote, not after.

The brand owner will not authorise sales into our market. Can you still supply?

Not as an authorised line, and we will say so plainly. Into the EU, genuine stock first sold outside the EEA cannot be brought in without the proprietor's consent; Hong Kong and Singapore allow parallel imports under international exhaustion, so there the constraint is the supply contract, and interfering with batch codes to disguise the route hands the proprietor grounds to stop the goods. If a parallel line is what you want, we will source it as a parallel line, keep the batch codes intact, and let you decide with the risk visible.

How do you stop stock arriving with most of its shelf life gone?

By working backwards from the destination rule. Several markets refuse consignments arriving with less than half of the declared shelf life remaining, so the production date, not the sailing date, is what we book against. We fix a minimum remaining life in the purchase order, verify the coding at pre-shipment inspection, and refuse the load if the batch is older than agreed.

§ Other sectors

Moving beverages & spirits?

Tell us the product, the origin and the destination. We come back with the classification, the document set and a realistic timeline.

Open a file with us
§ Two minutes

Not ready to write a brief?

Leave three lines and we will come back with the corridor, the customs position and a realistic timeline for whatever you are moving.

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