Excise warehouse and registered consignee licences

Producing alcohol, tobacco products or (with exceptions the act names) fuel in Estonia, or storing and receiving them before the excise duty is paid, requires an activity licence from the Estonian Tax and Customs Board¹²¹⁵. This page explains the excise warehouse licence and the registered consignee licence: who needs one, what the act requires, which documents are filed and how long the Board has to decide.

Information as of 11 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-11. The page is general information, not legal advice; the authority decides on every application.

What the activity is

The Alcohol, Tobacco, Fuel and Electricity Excise Duty Act (alkoholi-, tubaka-, kütuse- ja elektriaktsiisi seadus, ATKEAS) taxes alcohol, tobacco products, fuel and electricity, which the act calls excise goods together¹. An excise warehouse is a place where an excise warehousekeeper may produce, store, receive and dispatch excise goods under temporary excise duty exemption (duty suspension)². The excise warehousekeeper is the person who has been given that right³. Duty suspension means that the excise duty liability is suspended while excise goods with Union customs status are produced, stored, dispatched and transported as the act provides⁴.

A registered consignee is a person who has been given the right, under § 40 of the act, to receive for business purposes excise goods dispatched under duty suspension from another EU Member State⁵. A registered consignee may not store or dispatch excise goods under duty suspension⁵.

Covered, for example: producing alcohol (making, processing and bottling it⁶). Not covered: beer, wine and fermented drinks made in a private household for one's own non-commercial use are not treated as excise goods⁷; duty-paid goods moved between Member States for business purposes need a separate certified consignee registration⁸. Retail sale of excise goods in an excise warehouse is prohibited⁹.

The legal act and the authority

The act is the Alcohol, Tobacco, Fuel and Electricity Excise Duty Act, version in force from 1 November 2026; its Chapter 3 (§§ 34–44) governs both licences¹⁰.

The tax authority for excise duty is the Estonian Tax and Customs Board (Maksu- ja Tolliamet, MTA)¹¹. Both licences are granted by decision of the tax authority¹². When a licence is granted, the tax authority registers the applicant in its electronic information system and gives it an excise warehousekeeper or registered consignee number¹³; that information system is part of the register of taxable persons under the Taxation Act¹⁴.

Who must apply

Excise goods may be produced in an excise warehouse¹⁵, and duty suspension applies to production and storage there¹⁶. Which of the two licences a particular business needs is specified for the client's situation.

Exceptions and lighter regimes the act names:

A person that uses processed alcohol only to make a product other than alcohol, and the holder of an alcohol excise exemption permit, may process (but not denature) alcohol outside an excise warehouse if the ethanol content does not increase¹⁷.
A registered consignee that receives duty-suspended goods only occasionally, and has not provided wholesale or storage services in the same kind of goods during the previous 12 months, receives a separate licence for each consignment¹⁸.
An excise warehousekeeper that operates outside a town, borough or small borough as an accommodation and catering business, under the conditions of § 35(1), is exempt from § 34(1) points 1 and 3 and from the Commercial Register and VAT registration condition of § 40(1) point 1¹⁹, and needs no guarantee²⁰.

Requirements for the applicant

The licence is granted if all of the following are met²¹:

the person is entered in the Commercial Register and registered as a VAT payer in Estonia;
no bankruptcy or liquidation proceedings have been initiated against it, and it has no tax debt, including scheduled tax debt;
the MTA has not revoked its licence on the grounds named in § 43(1) point 1 or § 43(2) during the year before the application;
the premises meet § 34 (or § 35) and the internal accounting rules meet the Accounting Act;
records show excise goods by the eight-digit Combined Nomenclature (CN) code;
the ATKEAS § 39 documents and the guarantee have been accepted by the MTA.

Management. The licence may be refused if the person, or a member of the management or control body of a legal person, has committed during the 12 months before the application month certain tax misdemeanours punished with a fine above 100 fine units (natural person) or 2,000 euros (legal person), or certain Penal Code offences²².

Premises. The excise warehouse and the registered consignee's place of business must be used exclusively by the licence holder on the basis of a document confirming the land-use right; the warehouse territory must be surrounded by a permanent fence; the premises must be separated from those of other persons; and it must be possible to fit customs seals on entrances, exits and tanks²³.

Guarantee. The excise warehousekeeper provides a guarantee for the excise goods produced, stored and dispatched under duty suspension, and the guarantee must also cover duty that may arise in another Member State²⁴. A registered consignee provides a guarantee for the goods received at its place of business²⁵. The MTA sets the amount, based on the liability that may arise as calculated by the applicant²⁶; when activity starts, that liability is calculated from the business plan in cooperation with the MTA²⁷. The guarantee may not exceed that liability²⁸; the bases and minimum rates are set by regulation of the responsible minister²⁹. A small independent producer of only beer, wine and fermented drinks (up to 40,000 litres of beer and 15,000 litres of wine and fermented drinks a year) provides a guarantee only on the tax authority's demand³⁰.

Measurement. A producing warehousekeeper must measure raw materials, semi-finished products and output, and for alcohol the ethanol content³¹; traceability of results must be proven, with exceptions the act names³².

Ongoing duties include separate records, work rules, topping up the guarantee within 14 working days when the MTA raises it, and access for MTA supervision³³. The warehousekeeper files a monthly report on the movement and stock of excise goods by the 20th day of the following month³⁴.

Whether further requirements, such as share capital or anti-money-laundering (AML/CFT) rules, apply to the client's business is specified for the client's case.

Documents filed with the application

The applicant files the following with the MTA³⁶:

Application and business plan

a written application with the reason for setting up the warehouse or place of business, its address, the applicant's contact details and bank details;
data on the place where excise goods are received;
a business plan describing the goods to be produced and stored (for a consignee, received) under duty suspension, the production capacity and maximum storage volume, and the calculation of the tax liability that may arise³⁷.

Premises

a site plan and building plans with areas, entrances and exits;
a document signed by the owner proving the applicant's exclusive right of use;
a description of how the rooms are used;
tank location diagrams and volumes; for production, equipment and pipeline diagrams.

Internal rules and measurement

the internal accounting rules;
the work rules of the warehouse or place of business;
a description of the production process and of storage;
for a warehouse, consumption norms, and loss limits;
the competent measurer's certificate;
a contract with an independent accredited laboratory for measurements.

The applicant or its representative signs the documents³⁸; the MTA may ask for more³⁹. An occasional registered consignee files a shorter application⁴⁰.

State fee and processing time

Whether a state fee applies is specified for the client's situation.

The MTA decides to grant or refuse the licence within 30 days, or within 60 days where excise goods will be produced, from the day the ATKEAS § 39 documents are filed; the time may be extended by up to 30 days because of an expert examination, and the licence is issued at the latest on the day after the guarantee is accepted⁴². An occasional registered consignee receives its licence within seven days of filing the guarantee and the documents⁴³. Before operations start, an MTA commission takes an inventory⁴⁴. These time limits are the law's, not a promise; the MTA may ask for more documents³⁹.

What LexorCorp Global OÜ does and how to order

The service "Activity licence application documentation" covers: the requirements of the act for the activity, from its official text; the application and the documents it needs; and the submission and the written follow-up of the authority's questions. The client describes the activity and provides what the act requires of the company.

Price: from €3,500, one-time, for one licence of ordinary scope; more work is agreed in writing first. LexorCorp Global OÜ is not registered for VAT, so no VAT is added. Not included: legal advice, tax advice, an audit, meeting the guarantee, premises or measurement requirements of the act, and any decision of the MTA. The licence, its date and the MTA's decision cannot be promised; the MTA issues or refuses the licence.

Order: order form

Sources

ATKEAS § 1(1) — text in force from 2026-11-01
ATKEAS § 2 — text in force from 2026-11-01
ATKEAS § 3 — text in force from 2026-11-01
ATKEAS § 4 — text in force from 2026-11-01
ATKEAS § 4² (1)–(2) — text in force from 2026-11-01
ATKEAS § 21(1) — text in force from 2026-11-01
ATKEAS § 21(6) — text in force from 2026-11-01
ATKEAS § 21¹(1) — text in force from 2026-11-01
ATKEAS § 34(2) — text in force from 2026-11-01
ATKEAS header; chapter 3 runs from § 34 to § 44 (Inventuur) — text in force from 2026-11-01
ATKEAS § 23 — text in force from 2026-11-01
ATKEAS § 38(2) — text in force from 2026-11-01
ATKEAS § 41(1) — text in force from 2026-11-01
ATKEAS § 41(3) — text in force from 2026-11-01
ATKEAS § 21(4) — text in force from 2026-11-01
ATKEAS § 26(1) p 1 — text in force from 2026-11-01
ATKEAS § 21(5) — text in force from 2026-11-01
ATKEAS § 40(1¹) — text in force from 2026-11-01
ATKEAS § 35(1) — text in force from 2026-11-01
ATKEAS § 35(2) — text in force from 2026-11-01
ATKEAS § 40(1) p 1–9 — text in force from 2026-11-01
ATKEAS § 40(1²) — text in force from 2026-11-01
ATKEAS § 34(1) — text in force from 2026-11-01
ATKEAS § 31(1) — text in force from 2026-11-01
ATKEAS § 31(1¹) — text in force from 2026-11-01
ATKEAS § 31(4) — text in force from 2026-11-01
ATKEAS § 31(6) — text in force from 2026-11-01
ATKEAS § 31(8) — text in force from 2026-11-01
ATKEAS § 31(9) — text in force from 2026-11-01
ATKEAS § 31(1⁵) — text in force from 2026-11-01
ATKEAS § 33(1) — text in force from 2026-11-01
ATKEAS § 33¹(2)–(3) — text in force from 2026-11-01
ATKEAS § 36(1) p 1, 3, 6, 13 — text in force from 2026-11-01
ATKEAS § 37(1) — text in force from 2026-11-01
ATKEAS § 39(1) — text in force from 2026-11-01
ATKEAS § 39(2) — text in force from 2026-11-01
ATKEAS § 39(4) — text in force from 2026-11-01
ATKEAS § 39(5) — text in force from 2026-11-01
ATKEAS § 39(2¹) — text in force from 2026-11-01
ATKEAS § 40(2) — text in force from 2026-11-01
ATKEAS § 40(2¹) — text in force from 2026-11-01
ATKEAS § 40(3) — text in force from 2026-11-01

Official sources

The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Taxation Act — Riigi Teataja, English translation
Accounting Act — Riigi Teataja, English translation

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.

Excise warehouse and registered consignee licences in Estonia