Excise Movement and Control System (EMCS) EMCS Overview EMCS is a computerised system for monitoring movements of excise goods under suspension of excise duty within the EU. It replaces the paper control document, the Administrative Accompanying Document (AAD), with electronic messages from the consignor to the consignee via a central EU system fed by and feeding to the computer systems of the authorities in each Member State. EMCS: When and how? • 1 April 2010: EMCS became operational; • From 1 April to 31 December 2010: Migration period, dual running of paper and electronic • 1 January 2011: EMCS compulsory for relevant movements of excise goods; EMCS will mean • Simplification of procedures; • Reduced paper administration; • Secure movement of goods (Traders' data will be checked before the goods are dispatched); • Quicker release of the guarantee for traders (evidence that the goods arrived at their destination will come faster in a safer way), and • Effective monitoring, with real time information and checks during movements. This amounts to a major development for those who trade in alcohol and alcoholic beverages, tobacco or energy products. EMCS Roll out EMCS is being rolled out in stages as detailed below. In the UK a cautious approach is being adopted with the UK joining in each stage when required by law, rather than being an early adopter. Two Member States, Denmark and Poland have failed to meet the deadlines below and essentially for the foreseeable future will continue to use paper controls; this means that operators dealing with these two countries will need to continue raising and discharging AAD’s for the foreseeable future. Phase 1 – (Known as FS0) 1st April 2010 This phase is essentially "ground zero" ensuring that all Member States can electronically write off movements of excisable goods commencing in other Member States . The process allows for the download of the e-AAD in advance of goods receipt. Once received a "Report of Receipt" is returned electronically stating either the full receipt of the goods, or identifying discrepancies. The Report of Receipt enables the Consignor to finalise the movement concerned for Customs control purposes. Phase 2 – (Known as FS1) – January 2011 in the UK Under Phase 2 all transactions previously requiring a paper AAD must be cleared using EMCS. There will be some simplifications in the UK, primarily for inter company movements, where the current paper processes will be allowed to remain in place. Phase 3 – (Known as FS2) - December 2011 / January 2012 This will be an enhancement of the system to cater for split consignments, and all the other "complicated" issues missing from Phases 1 and 2! More precise details are awaited from HMRC.   e-customs and EMCS  Our latest developments e-customs® have attended all the software developer meetings arranged by HMRC and taken a lead role in developing a working EMCS solution. We have lobbied vociferously for the HMRC Software Developers Support Team (SDST) to improve their provision for third party suppliers and in house developers because this project has been subject to constant delays in the production of finalised specifications, last minute changes, and the discovery of errors extremely close to the due date, or even after the live implementation date. Despite these barriers e-customs® clients are connected to the UK end of the EMCS system and are receiving inbound messages created in other Memebr States. The task now is the finalisation of the FS1, despatching process. Our system "Webdecs" is already prepared and able to start initial testing; unfortunately the apparatus to test against, (the Local Test System (LTS)), has not yet been developed by HMRC / SDST. The available date we have been given by HMRC is 30 June 2010; this will leave a bare minimum of 6 months for testing to be completed; we do not feel this offers enough time on important matters such as EMCS. This timescale should be a major concern for any trader with large in house development teams or third party suppliers requiring long lead times. Notwithstanding this concern, we have been able to develop a draft specification for an interface file for users wishing to output data from their existing commercial systems. This file must of course remain at a draft status until we can test adequately with HMRC, however we are confident that the "spec" is 90% correct, hopefully more, so changes should be minimal. Against the back drop of a 30 June production of the LTS it will probably be best for users to at least commence their work of mapping current systems to the draft file ready for end to end testing in July. Please contact support@e-customs.com if you require a copy of the file specification. Implementation With regard to the live implementation of FS0 (receipts) this is currently a low key affair, which is fortunate bearing in mind we discovered errors in the HMRC Live application compared to the Local Test System. These errors have now (hopefully) been resolved but it does not bode well for the future with what was supposed to be a "test / confirm / switch to live process" proving not to be the actual case. As traders commence despatching their goods electronically we will be receiving the relevant messages and users can complete the report of receipt as required.     Issues arising from start of live operations Registration Clients of ‘Webdecs’ wishing to receipt and ultimately dispatch goods under EMCS must register with HMRC on the Government Gateway. Please note that where you are a warehousekeeper you must register at the "top level", and not at a specific warehouse level. This means that EMCS is an all or nothing process; every inbound consignment will be delivered electronically to the warehousekeeper, the Authorised Consignee, and we will display the consignments according to the place of delivery i.e. the specific warehouse. In order to receive the messages e-customs® will need to be shown by users as an "assistant" on the Government Gateway configured for EMCS only. The user reference and password allocated will need to be communicated to us so that we can poll for your messages. Excise measures It is becoming apparent that traders in other Member States are confused about the "Unit of measure" they need to declare ; this has a knock on effect when making the report of receipt. For wines, beers and spirits the unit of measure is bulk litres at 20° C. For tobacco products it is either kg of tobacco, or 1000s of finished product For Energy Products it is either KGs or litres at 15° C.    Future Updates We continue to develop our Excise Warehousing solution which will also allow for Registered Consignee \ Registered Commercial Importers and integrate with our EMCS module. We will continue to provide regular updates on progress on the project. If you would like to be added to the EMCS contact list and receive the updates, please e-mail the EMCS Project by clicking here EU EMCS News can also be found at http://ec.europa.eu/taxation_customs/taxation/excise_duties/circulation_control/index_en.htm