Ship and aircraft stores: an excise warehouse keeper who is the exporter no longer draws up an A-consignment note

From 01.11.2026 an excise warehouse keeper who is itself the exporter no longer has to draw up an A-consignment note when dispatching excise goods to an aircraft or ship leaving Estonia for a foreign country (ATKEAS § 45 lg 1 p 2) [1]. The excise exemption and the tax-stamp exception linked to the state alcohol register are also abolished [2] [3].

What changes

• Ship and aircraft stores: an A-consignment note is required when excise goods are dispatched under temporary excise exemption to an aircraft or ship leaving Estonia for a foreign country, „välja arvatud juhul, kui aktsiisilaopidaja on ise eksportija“ (translation: except where the excise warehouse keeper is itself the exporter) (ATKEAS § 45 lg 1 p 2) [1]. Until now there was no such exception [4]. According to the explanatory memorandum, the excise warehouse keeper had to draw up two documents for dispatching stores, the consignment note and the export declaration; after the change the export declaration is enough when exporting [5].
• Excise exemption abolished: the excise exemption is repealed for alcohol „mis esitatakse riiklikku alkoholiregistrisse kandmise eesmärgil akrediteeritud ja sõltumatusse laborisse analüüsimiseks“ (translation: submitted to an accredited and independent laboratory for analysis for entry in the state alcohol register) (ATKEAS § 27 lg 1 p 2¹) [6] [2].
• Tax-stamp exception abolished: the exception under which alcohol was not tax-stamped when submitted to the authorised processor of the state alcohol register for making a register entry is repealed (ATKEAS § 49¹ lg 4 p 4) [7] [3].
• According to the explanatory memorandum, both provisions are repealed because the alcohol register ceases to operate [2] [3], which happens on 1 November 2026 [8].

Who is affected

Excise warehouse keepers dispatching excise goods to aircraft or ships leaving for a foreign country [1], and businesses that submitted alcohol for analysis or for a register entry with a view to entry in the state alcohol register [6] [7].

What to do

• If the excise warehouse keeper is itself the exporter, according to the explanatory memorandum the export declaration is enough when dispatching stores [5]; if it is not the exporter, the A-consignment note must still be drawn up (ATKEAS § 45 lg 1 p 2) [1].
• From 01.11.2026 neither the excise exemption of ATKEAS § 27 lg 1 p 2¹ nor the tax-stamp exception of ATKEAS § 49¹ lg 4 p 4 applies to alcohol [2] [3].