Implementation of EMCS 4.1

On 13 February 2024, Customs will implement EMCS 4.1. This has consequences for customers who apply the Export process and use the Customs Management System (DMS) in combination with the Excise Goods Transport under Excise Duty Suspension process in the Excise Movement and Control System (EMCS).

Export of excise goods in an excise warehouse (AGP)

Are you an AGP holder? From 13 February 2024, this is what you need to do when exporting excise goods outside the EU that are held in an AGP:

  • You first report the excise goods movement in EMCS. The transport is monitored between the AGP of departure and the office of export using the electronic administrative document (e-AD), provided with an Administrative Reference Code number (ARC number).
  • You then submit an export declaration in DMS. You must also state the ARC number. The transport is monitored between the office of export and the office of exit on the basis of the export declaration, provided with a Master Reference Number (MRN).

The excise movement is temporarily suspended for the movement between the office of export and the office of exit. Once the effective exit has been determined and registered in DMS, the exit confirmation will be communicated to EMCS as well. You will be informed of the actual exit of the goods through this system.


From 13 February 2024 onward, an automatic cross-check will be introduced between the e-AD and the export declaration when validating the export declaration. For example, the Combined Nomenclature codes (CN codes) and the net weight on the export document must be the same as those in the e-AD. If the data of both documents match, DMS will accept the declaration. If the information does not match, DMS will reject the export declaration. Being the declarant, you must correct your export declaration and resubmit it.

For DMS customers

Have excise goods been declared in the export declaration? In that case, you must include at least 1 of the following data sets in the declaration at item level:

  • if the AGP holder has drawn up an e-AD for export under suspension:
    C651 (ELECTRONIC ADMINISTRATIVE DOCUMENT FOR EXCISE GOODS) in data element (GE) 12 01 002 000 ‘Preceding document/Type’ (SI)
  • if EMCS does not work and the AGP holder has drawn up an Emergency e-AD for export under suspension:
    C658 (EMERGENCY DOCUMENT (FAD) in GE 12 01 002 000 ‘Preceding document/Type’ (SI)
  • if the goods are subject to Dutch excise duty and a refund request will be made:
    N5021 (REFUND REQUEST (NATIONAL)) in GE 12 02 000 000 ‘Additional information’ (GS/SI)
  • if goods are in free circulation and are to be exported without a request for excise duty refund being made:
    N5020 (EXPORT EXCISE GOODS WITHOUT SUSPENSION AND REFUND REQUEST) in GE 12 02 000 000 ‘Additional information’ (GS/SI)

Pay close attention to the following

  • Code C651 must be followed by the ARC number (21 characters) and the body record unique reference number (3 digits) of the goods must correspond to the item number in the export declaration.
  • An export declaration can contain multiple items. Each item may contain only 1 ARC number. An ARC number cannot therefore be split over different export declarations. You must create a separate item number on the export declaration for each body record unique reference of the e-AD.
  • The commodity code (CN code), net weight, gross weight and office of export on the e-AD and on the export declaration must be the same.
  • In GE 12 01 002 000 ‘Preceding document/Type’ of the export declaration, a maximum of 1 document code with C651 is permitted per item in the export declaration. An exception to this rule applies to collective export shipments in ship supplies, among others (with commodity codes starting with 9930 and 9931). In the latter case, multiple document codes with C651 are permitted per item.
  • If the ARC number (C651) is included in GE 12 01 002 000 ‘Preceding document/Type’ of the export declaration, DMS checks whether the data of the excise goods in the export declaration matches the data of the e-AD from EMCS. The export declaration will only be accepted if the data match.

For EMCS customers: 3 new messages

There will be 3 new messages to more accurately monitor the progress of an excise movement with export destination:

  • Upon acceptance or release of the export declaration, you will receive an ‘IE829 - report of accepted export’. You do not have to respond to this.
  • If the export declaration is not accepted, you will receive an ‘IE839 - Customs rejection of e-AD’. In this case, the cross-check was not successful. You will have to determine where the cause lies. First check what is stated under ‘Pay close attention to the following matters’ as referred to above. Is the e-AD correct? In that case, have the export declaration corrected.
  • When invalidating an export declaration (even after release for transport) in DMS, you will receive an ‘IE836 invalidation of export declaration’. In that case, you must draw up a new export declaration or change the destination of the excise goods movement.

S2S customers

Are you a System-to-System (S2S) customer? If so, you should be able to accept and process the 3 new messages according to the specifications of the Message Implementation Guide (MIG).

For DMS and EMCS customers: What happens after release for export?

The export movement between the office of export and office of exit is further monitored via the Automated Export System (AES). The office of export sends an Anticipated Export Record (AER) to the office of exit. After that, the goods can be presented to the office of exit. The office of exit sends an exit confirmation message to the office of export when it is determined that the excise goods have left the customs territory of the European Union. The office of export will change the status of the e-AD to ‘delivered’ based on the exit confirmation it received from the office of exit.