消费税、附加征费与 2026 年改革议程

Excise duty taxes the production, holding or use of specific goods. It shares the three

defining features of VAT: the base is the value of consumption net of tax, the rate is

specific or ad valorem, and the tax is charged once, at production or in the distribution chain.

Three EU instruments (the numbering trips people up)

Note: Directive 2011/92/EU is the environmental impact assessment directive, not the

alcohol excise directive. The alcohol minimum rates are in Directive 92/84/EEC and the

structure in Directive 92/83/EEC.

Excise territory versus customs territory: the excise territory is in principle the EU

customs territory, with territorial exclusions such as the French overseas departments. Import

excise is due when goods cross the excise border. So three questions decide any excise

problem: are the goods excisable? is the excise border crossed? where are they consumed?

The excise event (tax point): excise is not computed once at import. It arises when goods

leave customs or tax supervision and enter consumption. Goods in a licensed warehouse remain

under supervision, so the tax can be deferred - which is exactly the Estonian model in

section 17.3.

Exam warning: energy excise under Directive 2003/96/EC has a different tax point from

alcohol and tobacco, which is the classic way to compare the timing of three taxes on the

same consignment.

Alcohol excise rates come in three shapes: ad valorem (a percentage of the price),

specific (a fixed amount per hectolitre or per litre) and mixed (a fixed amount per

% vol per hectolitre). Where several rules apply to the same product, the highest of them

governs - the exam memory aid is the MUST formula:

**Duty per unit = max{ ad valorem amount (price x ad valorem rate), specific amount per % vol

per hl x alcohol content x volume, specific amount per hl of product x volume }**

The EU sets a minimum rate for each category (Directive 92/84/EEC, official Commission

table):

Worked MUST examples

• Spirits, 1 hl at 40 % vol: minimum = 550 / 100 x 40 = EUR 220.00. If the Member State

charges EUR 350.90 per % vol per hl (the Estonian 2026 rate), the duty is 40 x 350.90 =

EUR 14 036.00, far above the floor.

• Beer, 1 hl at 12.5 degrees Plato and 5 % vol: minimum = max(0.748 x 12.5, 1.87 x 5) =

max(9.35, 9.35) = EUR 9.35. Estonia's 2026 rate of EUR 15.40 per hl is above it.

• Wine, 1 hl: the EU minimum is nil; Estonia charges EUR 76.82 per hl for fermented drinks

and wine of 6 % vol or less in 2026.

Exam warning: in a MUST question, compute all three candidate amounts and then take the

maximum; computing only one is the standard trap. And remember the floor: a Member State may

charge more than the minimum but never less.

Template for this chapter: `duty = max(ad valorem amount, specific per % vol per hl x

alcohol x volume_hl, specific per hl x volume_hl)`.

Deferred excise duty: when an authorised warehousekeeper imports or produces excisable

goods, the tax is not paid immediately; it is deferred until the goods are **removed from the

warehouse for consumption**. This is the general approach in BE, NL, DE and FR.

The Estonian model is structural: in Estonia the excise liability (maksukohustus) arises

**only when the goods are released from the excise warehouse (aktsiisilaopaja) for

consumption**. EMTA's own wording is that alcohol is taxed only once it is taken out of the

excise warehouse for consumption without temporary relief. Warehouses run under a **licence

(tegevusluba), and there is a relief for väiketootja** (small producers).

Estonian alcohol excise rates (EMTA official table)

Key fact: Estonian alcohol and tobacco excise rose by 10 % from 1 January 2026 (the table

confirms it: 14.00 x 1.10 = 15.40 and 319.00 x 1.10 = 350.90; a further rise of about 5 %

follows in 2027). A small brewer producing no more than 15 000 hl per year pays beer excise at

50 % of the rate.

Exam warning: Estonian rates are expressed per hectolitre and per % vol, so unit

conversion is where marks are lost: 1 hl = 100 litres, and 1 hl of 40 % spirit contains

40 litres of pure alcohol.

For tobacco and fuel rates, quote the EMTA pages rather than reciting from memory.

The CBAM (Regulation (EU) 2023/956) applies definitively from 1 January 2026 to the

Annex I goods: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.

Who is liable? Article 4: goods may be imported **only by an authorised CBAM

declarant**, and Art. 25 forbids the customs authorities from allowing anyone else to import.

Article 5 decides who applies: an importer established in a Member State applies in its own

name; where the importer appoints an indirect customs representative (Art. 18 UCC) and

that representative agrees to act as authorised CBAM declarant, the representative applies;

where the importer is not established in the Union, the indirect representative must

apply. Art. 17: the authorisation is granted by the authority of the Member State of

establishment and is recognised throughout the Union.

The certificate mechanism: Art. 6 requires the authorised declarant to submit a CBAM

declaration in the CBAM registry by 31 May each year (first time in 2027, for 2026),

stating the quantities imported, the embedded emissions and the number of certificates to be

surrendered. Art. 22 requires the surrender of the corresponding certificates by the same

date; at the end of each quarter the account must hold certificates equal to at least

80 % of the embedded emissions of the goods imported since the start of the year.

De minimis: Art. 2(3) disapplies the Regulation to goods whose intrinsic value per

consignment does not exceed the value specified for goods of negligible value (Art. 23

of Reg. (EC) No 1186/2009) - EUR 150 in the customs duty context. Note carefully: what was

abolished on 1 July 2026 is the duty exemption; the CBAM reference still points at the

negligible-value threshold in Art. 23, so check the current value on the official CBAM pages

(VERIFY). Quantity thresholds expressed in tonnes and MWh also exist (VERIFY).

Exam warning: the CBAM obligor is the authorised CBAM declarant at the import stage - not

the third-country producer and not the carrier. Start every question by identifying the

importer of record and then ask whether that party holds the authorisation.

Legal basis: Council Regulation (EU) 2026/382 (adopted 11 February 2026, amending Reg. (EC)

No 1186/2009). This is the change that matters most to retailers in 2026.

Three linked rules

• Duty feeds the import VAT base. The EUR 3 duty and the EUR 2 handling fee are import

charges, so import VAT = (customs value + transport + duty + handling fee) x the VAT rate of

the Member State of import.

• The EUR 3 is charged per goods line. EMTA warns explicitly that if the same goods are

declared on several lines, each line is taxed separately: three shirts on three lines cost

EUR 9, not EUR 3.

• The EUR 150 threshold survives, but only for duty. Import VAT is still collected and the

IOSS scheme (intrinsic value up to EUR 150) still works.

Official EMTA example (Estonia, 24 %): shirt EUR 10 + transport EUR 2 + duty EUR 3 -> VAT

(10 + 2 + 3) x 24 % = EUR 3.60; T-shirt EUR 5 + 2 + 3 -> EUR 2.40; jeans EUR 20 + 2 + 3 ->

EUR 6.00. For the whole consignment: EUR 21 = EUR 9 of duty + EUR 12 of VAT.

Official Dutch example: EUR 199 + 25 + 10 = EUR 234; duty at 3 % = EUR 7.02; the parcel is

one product category, so the handling fee is EUR 2; VAT at 21 % on (234 + 7.02 + 2 = 243.02) =

EUR 51.03. The cash actually paid at the border is 7.02 + 2 + 51.03 = EUR 60.05.

Exam warning: keep one order - duty first, then the handling fee, then the rate - because

the fee also sits inside the VAT base.

ViDA (VAT in the Digital Age): the Council adopted the package on 11 March 2025. It

comprises 12 directives amending the VAT Directive and moves in three directions:

e-invoicing and e-reporting, platform rules (platforms must check the tax identity of

the counterparty and report transactions) and the **simplification of import VAT handling for

the 2030s** (replacing repeated declarations with a single declaration linked to the customs

systems). The staged application dates are an item the reference card flags as VERIFY - check

the official timetable before you put a date in an exam answer.

France's generalisation of e-invoicing (a retail-tax development): from **1 September

2026, all businesses must be able to receive e-invoices; large companies and

ETIs must issue them; SMEs and micro-businesses must issue them from 1 September

2027**. Source: the French Ministry of Economy and service-public (see the country notes).

Checklist for a retailer importing consumer goods from China in 2026

• Two new charges per low-value parcel: the EUR 3 duty (from 1 July 2026) and the EUR 2

handling fee (from 1 November 2026), and both of them enlarge the import VAT base;

• The per-line trap: splitting one product over several declaration lines multiplies

both the EUR 3 duty and the handling fee;

• The EUR 150 duty exemption is gone - do not build a margin model on duty-free

low-value parcels;

• IOSS still works (intrinsic value up to EUR 150, no excise goods), but check that the

goods are not alcohol or tobacco, which IOSS expressly excludes;

• US-origin goods are treated under Regulation (EU) 2026/1455 from 1 July 2026, so check

the EU non-preferential origin rules;

• If you import aluminium or steel articles, check the CBAM authorisation and certificate

obligations as well;

• Wine and spirits carry excise duty on top, and the Estonian rates rose by 10 % on

1 January 2026.

Exam warning: this is the "translate the rules into money" question type: give the goods value,

freight, number of lines and the destination rate, and ask for the **total payable at the

border** (duty + handling fee + VAT).