Importing Wine and Alcohol from the UK to Poland — Excise Duty, Customs and Documents Required by HMRC

The UK as a Third Country Since Brexit — What Has Changed?

Since 1 January 2021, the United Kingdom has been a third country in relation to the European Union. For trade in alcohol between the UK and Poland, this means:

• Every consignment of alcohol from the UK to Poland requires full customs clearance (export in the UK + import in Poland)
• The free movement of goods within the EU single market no longer applies
• Goods are subject to customs duties (though often 0% if TCA conditions are met)
• The UK EMCS (UK excise movement and control system) is separate from the EU EMCS — goods move between two independent excise systems

Duty on Wine and Alcohol from the UK — Tariff Rates

Duty on Wine Imported from the UK into the EU

Standard EU duty on wine from third countries is:

• Still wine: from 22 to 136 EUR per hectolitre (depending on container size and tariff heading)
• Sparkling wine: 32 EUR/hl + additional ad valorem
• Whisky/gin/spirits: 0.0 EUR/hl (no ad valorem duty) in the case of the EU tariff for distilled spirits from the UK under the TCA

Zero Duty Under TCA — When Does It Apply?

The TCA (EU–UK Trade and Cooperation Agreement) provides for zero duty on alcohol of UK origin. "UK origin" means the goods were produced in the UK in accordance with TCA rules of origin. This applies principally to:

• Whisky (Scotch Whisky, Irish Whiskey, English Whisky)
• Gins produced in the UK
• Ciders and beers from British breweries

Wine imported into the UK from France/Italy/Spain and then re-exported to Poland does NOT have UK origin and does not benefit from TCA preferences. Standard EU duty applies in full.

How to Evidence UK Origin for Alcohol?

The UK supplier must provide a statement on origin on the commercial invoice or a separate document:

"The exporter of the products covered by this document declares that, except where otherwise clearly indicated, these products are of UK preferential origin."

For consignments above €6,000 in value, a REX (Registered Exporter) number from the UK exporter is required.

Excise Duty on Alcohol — EU EMCS and UK EMCS

EMCS — Two Separate Systems

EMCS (Excise Movement and Control System) is an IT system for controlling the movement of excise goods. Since Brexit:

• EU EMCS — covers the 27 EU member states. The system is operated by the European Commission and national tax authorities (in Poland by PUESC / e-ZEFIR)
• UK EMCS — a separate HMRC system for movements of alcohol within the UK

Alcoholic goods travelling from the UK to Poland leave the UK EMCS (with an EAD — Electronic Administrative Document, or its UK equivalent) and upon crossing the EU border enter the EU EMCS as an import from a third country.

e-AD — Electronic Administrative Document

In Poland, intra-Community transport of excise goods is conducted under the e-AD (electronic administrative document) procedure within the EMCS system. For imports from the UK to Poland:

1. The goods are cleared through customs in Poland (procedure 4000 or 4200)
2. The import declaration indicates that the goods will enter the excise duty procedure
3. The entity in Poland (authorised consignee — registered consignee) opens an e-AD in the EU EMCS system
4. After the goods are received in Poland, the e-AD is closed and the excise duty owed is accounted for with the tax authority

Who Can Import Excisable Alcohol into Poland?

Commercial imports of alcohol into Poland require one of the following statuses:

• Authorised consignee (registered consignee) — an entity registered with the National Revenue Administration (KAS), authorised to receive excise goods from other EU member states or third countries
• Registered consignor — if the entity itself initiates the movement
• Tax warehouse — a facility where excise goods may be stored under duty suspension

Importing alcohol without the appropriate status is a breach of excise legislation and may result in serious sanctions.

Procedure for Importing Alcohol from the UK to Poland — Step by Step

1. UK side — export declaration EX1: The UK supplier or their customs broker submits the export declaration. Easy Clearance can handle this side. The goods leave the UK with a confirmed EX1.
2. Transport: Typically by road (lorry, TIR) via Calais/Dover or the Channel Tunnel, then through EU countries to Poland. T1 transit (customs transit) through EU countries is also possible.
3. Polish side — import declaration: A customs broker in Poland submits the import declaration (procedure 4000 or 4200) in the AIS/IMPORT system. Customs duty and import VAT are accounted for.
4. e-AD in EU EMCS: The authorised entity in Poland opens an e-AD. The goods move under duty suspension or with duty accounted for.
5. Receipt of goods and closure of e-AD: After the goods are received at a tax warehouse or by an authorised consignee, the e-AD is closed. Excise duty is paid or remains suspended.

VAT on Alcohol Imports from the UK

Importing alcohol from the UK to Poland is subject to VAT at 23%. The VAT base = customs value + duty + excise duty. A VAT-registered business in Poland may recover import VAT (if it carries on a taxable activity). Reverse charge accounting (procedure 4200 — Regime 42) may be applicable where certain conditions are met.

Customs Clearance Costs — Indicative Price Ranges

• Export clearance in the UK (EX1): from £45 to £120
• Import clearance in Poland: cost of a Polish customs broker (separate)
• Duty: 0% (under TCA with UK origin) or standard EU tariff rates
• Excise duty: per Polish Ministry of Finance rates (depending on type of alcohol and alcoholic strength)
• Import VAT: 23% of base (customs value + duty + excise duty)

The price ranges shown are indicative — exact pricing provided after documents are submitted.

Documents Required for Importing Alcohol from the UK

• Commercial invoice with statement on origin (for UK origin)
• Packing list
• CMR (transport document)
• Product specification — alcoholic strength, volume, type of product
• UK EMCS document (if the goods were under an excise duty procedure in the UK)
• VI1 or VI2 certificate (for wine — the accompanying document required for wine imported into the EU, as required by EU regulations)
• e-AD number (opened by the Polish authorised consignee before receipt of the goods)

Official Sources

• GOV.UK: Moving excise goods from GB to EU — GOV.UK / HMRC, 2026
• EU Commission: Excise duties on alcohol in the EU — European Commission, 2026
• GOV.UK: Import wine to the UK — GOV.UK / HMRC, 2026

Frequently Asked Questions (FAQ)

What is the duty on wine imported from the UK to Poland?

The duty on wine from the UK depends on its origin. If the wine has confirmed UK origin (produced in the UK) and the supplier has provided a statement on origin, the duty is 0% under TCA. Without proof of UK origin, standard EU duty applies: from 22 to 136 EUR per hectolitre (depending on the type of wine and packaging).

Is excise duty payable when importing alcohol from the UK to Poland?

Yes — all alcohol imported into Poland from the UK is subject to Polish excise duty, accounted for through the EU EMCS system (e-AD). The importer must hold authorised consignee status or operate through a tax warehouse. Excise duty rates depend on the type of alcohol and alcoholic strength.

What is EMCS and why do the UK and EU have separate systems?

EMCS (Excise Movement and Control System) is an IT system controlling the movement of excise goods. Since Brexit, the UK and EU have separate, independent EMCS systems. Alcohol travelling from the UK to Poland leaves the UK EMCS (with an EAD document), crosses the border through customs import and enters the EU EMCS under an e-AD.

Does the TCA eliminate duty on whisky and gin from the UK?

Yes — whisky, gin and other distilled spirits produced in the UK (UK origin) benefit from zero duty under the TCA on import into the EU/Poland. The condition is that the supplier must provide a valid statement of origin on the invoice. For consignments above €6,000 in value, the exporter's REX number is required.

What documents are required when importing wine from the UK?

Required documents are: commercial invoice (with statement on origin for TCA), packing list, CMR, VI1 certificate (accompanying document for wine imported into the EU from third countries), product specification with alcoholic strength and an e-AD number opened by the Polish authorised consignee. HMRC may be the source of the VI1 certificate, or the wine must hold a certificate from an accredited body.