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New rules for drawing up e-DD

In the case of applying certain exemptions or the PLN 0 rate, the Excise Act provides for the obligation to include excise goods in monitoring. For this purpose, a packing slip shall be used. It shall be drawn up by the consignor of the excise goods and its receipt shall be confirmed by the consignee of the goods.



Despite the existence of an electronic delivery note (e-DD) generated in the EMCS PL2 system since 1 January 2019, movements of excise goods can still be carried out on the basis of paper documents. However, as of 1 February 2022, it will no longer be possible to use a paper packing slip.



e-DD extension of the product range


Until now, the electronic delivery note was to cover only movements carried out in Poland outside the duty suspension arrangement involving excise goods:

  • exempt from excise duty by virtue of their intended use, where a paper delivery note has been used so far,

  • taxed at a zero rate of excise duty due to their intended use (listed in Annex 2 to the Act).

One of the more significant changes is the extension of the catalogue of movements to be documented with e-DD. In accordance with the amendment of regulations introduced in February 2021, the above-mentioned movements should also include the sale on the territory of the country of coal products exempt from excise duty due to their intended use to the final coal buyer by for-an-eye">an intermediary coal entity that sold over 30 million kg of coal products in the previous calendar year. As a consequence, coal sellers who meet this quantitative criterion must additionally prepare for the implementation of e-DD.



Deadline for the implementation of e-DD


The amendment to the provisions on the electronic delivery note entered into force on 1 February 2021. However, on the basis of the transitional provision, the possibility of applying the existing regulations until 31 January 2022 has been introduced. Therefore, entities that have been using paper delivery notes so far and large coal intermediaries have little time to implement e-DD.


How to prepare?


In order to use the EMCS PL2 system, it is necessary to register or update the company's data on the PUESC platform and in the Central Register of Excise Entities.


Technical descriptions of messages generated in the EMCS PL2 system are included in the specification, which the Ministry of Finance has published at the following link. Due to the approaching deadline, it is worth choosing the right tool to handle e-DD today and substantively prepare people who will be involved in this process.


If you are interested in the e-DD application, please contact us. We are able to both support you in the implementation of the new e-DD regulations, as well as recommend appropriate IT solutions.


Check out our offer in the field of e-DD services.

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