This has serious consequences for operators holding a French excise number.
Since February 18th 2022, the EMCS-GAMMA system (Excise Movement and Control System) has been subject to a national malfunction. This system allows the movement of products subject to excise duty. These are alcohol, tobacco and energy products. EMCS is thus used by operators holding an excise number (authorised warehousekeeper, registered consignee and registered consignor).
EMCS introduces computerised monitoring of the movement of products under suspension of excise duty within the European Union, where products are under cover of an electronic accompanying document (EAD). Within GAMMA (its French version), it offers the possibility of issuing simplified accompanying documents (SAD) completed electronically for French operators carrying out movements of products subject to excise duty within the national territory.
EMCS - GAMMA is regularly updated. Following the delivery of a new version of the System of Exchange of Excise Data(SEED), a system malfunction occurred.
SEED: what is it?
Unfortunately, since this delivery of this new version, the SEED-FR and SEED-UE systems are no longer able to exchange the creation and updating of operator and warehouse excise approval numbers. This can therefore affect the functioning of EMCS-GAMMA and the computerised reverberation of exchanges within the system.
SEED can be defined as: "a database listing all European authorised warehousekeepers and registered traders authorised to carry out intra-Community movements of products under suspension of excise duty, as well as tax warehouses". It is therefore the equivalent of what is "VIES" for VAT, but for excise duties. It allows:
- Verification of the validity of traders' excise numbers,
- Verification of the product categories for which they are approved.
This malfunction has serious consequences for the issuance and discharge of EADs to or from French excise numbers that have been created or modified since 18 February 2022, the date of delivery of the latest version of SEED by the European Commission.
Impact of this anomaly on the issue and discharge of the AED by a French sender to an EU consignee:
- If the EU consignee's (non-French) excise number has been created or modified after 18/02/2022, this number will not be known to the French electronic system. It will not be possible to create the EAD.
- Resolution action: a fallback procedure should therefore be used.
- If the French excise number of the consignor (or warehouse) has been created or modified from 18/02/2022, this number will be known by the French system, but not by the systems of the other countries, which could lead to the rejection of the AED and prevent the trading partner from transmitting the certificate of receipt.
- Resolution action: time... only after this synchronization failure can your AEDs be cleared.
Consequences of this anomaly on the French reception of an AED issued by an EU consignor :
- If the French consignee approval number has been created or changed as of 18/02 the trading partner will be unable to issue an AED, however the administration in the country of dispatch may allow the supplier to use the fallback procedure.
- Resolution action: contact the local authorities in the Member State of dispatch to validate the appropriateness of using the rescue procedure in that country.
- The EU consignor approval number has been created or modified as of 18/02: the French system does not recognise this number, the consignor may be able to issue the AED, but the consignee will not be able to issue a certificate of receipt.
- Resolution action: time... only after this synchronization failure can your AEDs be cleared.
The Commission's teams and the Member States concerned are doing their utmost to restore the functioning of the system. Please note that not all changes are likely to block the issuance of AEDs.
If you have experienced difficulties in recent weeks with the movement of goods under suspension of excise duty, you now know the probable reason! For any further information or assistance in declaring products subject to excise duty - ALCOHOLS or ENERGY PRODUCTS, do not hesitate to contact us!