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Moving alcohol products excise-unpaid


This page explains:

  • when alcohol can be moved without paying excise duty
  • how to apply for approval to move alcohol excise-unpaid
  • record keeping obligations when moving goods.

When alcohol products can be moved excise unpaid

Licensed manufacturing Customs-controlled areas (LMAs)

LMAs can move alcohol products, excise-unpaid, to:

  • another LMA for further manufacture (this includes bottling and labeling for the first time)
  • the product owner’s CCA following contract manufacturing
  • another CCA held by the same legal entity or its trading entities (which are part of the same legal entity)
  • an off-site storage CCA, with approval from Customs
  • a CCA licensed as a duty-free shop or export warehouse.

Off-site storage Customs-controlled areas (OSSs)

OSSs can move alcohol products, excise-unpaid, to:

  • another LMA for further manufacture (this includes bottling and labeling for the first time)
  • another CCA held by the same legal entity or its related trading entities
  • a CCA licensed as a duty-free shop or export warehouse.

When excise-unpaid alcohol is removed for home consumption, it must be accounted for in an excise entry, regardless of where it is removed from.

Approval required to move goods excise-unpaid for any other reason

Approval from Customs is required to move product excise-unpaid under circumstances not listed above and when moving goods to an OSS. Approval must be obtained prior to the movement, as approvals cannot be retrospectively applied to a movement that has already happened. If goods are moved in any other situation without approval, the goods must be included in the CCA's excise entry for the corresponding period.

Apply to move alcohol products excise unpaid

Ongoing approvals to store alcohol in an OSS

Customs might provide LMAs ongoing approval in their AEP to store excise-unpaid alcohol in an OSS, if:

  • there is insufficient storage space to keep the product in the manufacturing area
  • no manufacturing takes place at the off-site location (bottling and labeling are classified as manufacturing processes and cannot occur in off-site storage locations)
  • the manufacturer and OSS have adequate record keeping systems to track the product movement
  • the OSS has appropriate facilities to securely store the product.

Request approval to store alcohol at an OSS

To request approval to store goods at an off-site storage CCA, the manufacturer of the goods must send a completed NZCS 247 (DOC 238 KB) form to Excise-Licensing-National@Customs.govt.nz

One-off and temporary approvals

In exceptional circumstances, CCAs may be permitted to move product duty-unpaid:

  • to an off-site storage CCA, as a one-off
  • to an unlicensed premises, temporarily.

Examples of situations that may be approved:

  • Your CCA unexpectedly needs repairs, and you need to temporarily store product at another CCA.
  • Your product needs to be urgently relocated due to an emergency.
  • Infected product needs to be quarantined.

Request a one-off or temporary approval

To request approval, the manufacturer of the goods must complete and send to Excise-Licensing-National@Customs.govt.nz either:

  • NZCS 249 (DOC, 252 KB) for temporary permission to move goods to a location that is not a Customs-controlled area.
  • NZCS 250 (DOC, 251 KB) for one-off permission to move goods to an OSS.

Record keeping obligations

When moving goods between CCAs, you must:

  • Notify the destination CCA, in writing, of the products being sent to them. 
  • Keep a record of all movements under this authorisation, including:  
    • which products were removed from the CCA
    • date products were removed from the CCA
    • destination CCA name and address
    • transport carrier details
    • relevant consignment notes
    • date products were received at the destination CCA
    • confirmation that the destination CCA has received the products.

These records must be kept in addition to your usual business records and may be audited by Customs.

Moving fuel and tobacco products excise-unpaid

For fuel or tobacco excise clients, details about moving products are outlined in the CCA's Procedure Statement. If further information is required, contact Customs for assistance.  

Contact us for help

If you are unsure whether a movement is allowed, contact Excise-Licensing-National@customs.govt.nz