THE ARDUOUS ROUTE TO ITALIAN CERTIFIED CONSIGNEE STATUS
The introduction of Certified Consignee in Italy offers access, with a different document, to the same fiscal fortress.
Despite the implicit aim of the EU Directive 262/2020, in terms of procedural simplification for economic operators, the Italian legislator applied an onerous burden onto operators willing to receive excisable products (already) released in consumption in another Member State.
Focusing on alcoholic products, operators hoping to benefit from new opportunities, deluded themselves.
When performing intra-UE movement of duty paid products, since the full entry-into-force of Directive 262/2020 the products shall be dispatched by a Certified Consignor, who is also responsible for issuing an Electronic Simplified Accompanying Document (E-SAD) which will accompany the goods until arrival in the recipient Member State. In Italy, the goods must be sent to the physical place linked to the authorization of Certified Consignee. That means the option for direct delivery allowed in some Member States does not apply.
Unfortunately, there are further complications. Catering operators wishing to benefit from new opportunities for opening new supply from the EU market get stuck with the original procedure for obtaining, at least, a Registered Consignee status for receipt of product shipped duty suspended with the enduring E-AD document. In Italy the activity of a Certified Consignee is only allowed as an appendix of a Registered Consignee or Tax Warehouse authorization, which doubles requirements and, possibly, also the administrative/ compliance burden.