Ethyl alcohol and denatured spirit under CN 2207 from 500 l

What heading 2207 covers

Heading 2207 in the SENT list is undenatured ethyl alcohol of 80 % vol. or higher and ethyl alcohol and other spirits of any strength, denatured, not marked with excise stamps (art. 3 ust. 2 pkt 1 lit. a of the SENT Act). Vodka in bottles with a Polish excise stamp is not covered, because it is marked. Two system codes sit alongside. Code 0002 is fully denatured alcohol, including alcohol contained in products not for human consumption, from 500 l. Code 0003 is goods of any CN code containing over 50 % ethyl alcohol denatured with isopropanol or denatonium benzoate, from 500 kg or 500 l (§ 1 pkt 3 of the goods regulation).

When carriage of 2207 is under SENT

Threshold: over 500 kg gross or over 500 litres per consignment. Unit packages up to 5 l are excluded for 2207 and for code 0002 (art. 3 ust. 4 pkt 2 lit. a and art. 3 ust. 5), for code 0003 the limit is 1.5 l (§ 2 ust. 3 pkt 2 of the regulation). PUESC takes a delivery of spirit from a distillery to a company using it under an excise exemption. Over 500 l in drums or IBCs is filed by the distillery as consignor, and the consignee completes the notification with confirmation of receipt (FAQ 02.08).

Is a disinfectant with 70 % ethanol in 5-litre canisters under SENT? Yes, under code 0003, if the alcohol is denatured with isopropanol or denatonium. The exclusion covers packages only up to 1.5 l, and a 5-litre canister is larger. Consignment over 500 kg or 500 l.

When 2207 is not covered

Alcohol with Polish excise stamps. Packages up to 5 l (for 0003 up to 1.5 l). Movement under excise duty suspension with an e-AD in EMCS (art. 3 ust. 6 pkt 3, FAQ 03.10). The customs procedures of transit, storage, temporary admission, processing, export or re-export (art. 3 ust. 6 pkt 2). Postal parcels.

What it means for a Ukrainian carrier

Spirit is an excise good and in practice almost always travels either with an e-AD between tax warehouses or under a customs procedure. Both cases are outside SENT but not outside control: the inspector checks the e-AD or the MRN as carefully as a SENT number. Transit of duty-paid alcohol without a customs procedure from an EU state to Ukraine is art. 7, SENT300 from the carrier. The RMPD is filed separately, and code 2207 in it must match the CMR.