Exporting wine. The excise is zero, the paperwork isn't.

Wine leaves Italy with a folder no other food carries. Not because it costs more: because it is monitored.

This piece is part of the guide to export operations for the small food producer and covers wine everywhere, not a particular country. For the part wine has in common with any food, that is, the shipment folder and the rules of the market of arrival, there are the documents that accompany the shipment and the country pages linked below.

What changes compared with any other food

Three things, and none of the three appears in a generic guide to food export. Wine is a product subject to excise, so its movement is tracked by a system of its own. It has a mandatory accompanying document that other foods don't have. And it has labelling rules of its own, which the Union imposes even when wine leaves the Union.

The rest is identical: export invoice, packing list, transport document, customs declaration, proof of preferential origin where there is an agreement. Whoever comes to wine after exporting oil or preserves already has half the work done, and has to add the tax layer.

The excise is zero, and that is exactly why it confuses

The table of national rates published by the Italian Customs and Monopolies Agency, in the version updated to 19 March 2026, shows €0.00 for wine, with reference to Annex I of Legislative Decree 504 of 1995. The same figure applies to fermented beverages other than wine and beer. By comparison, in the same table ethyl alcohol stands at €1,035.52 per hectolitre of pure alcohol and intermediate alcoholic products at €88.67 per hectolitre.

A zero rate doesn't mean outside the system. Wine remains a product subject to excise, and the practical consequence is that the winery, for the tax authorities, is a fiscal facility. The Agency says so when listing which facilities can operate under the tax warehouse regime in the alcohol sector: among these, verbatim, «wineries and production plants (wine and fermented beverages other than wine and beer)».

The suspension regime, the same source explains, applies to the production, processing, holding and movement of excise goods until the moment the duty becomes chargeable. Opening a tax warehouse requires an authorisation, and for products other than tobacco a licence too: the procedure ends with the assignment of an excise number.

Whoever bottles and sells wine in Italy already has this piece, and often doesn't connect it with export. It is that number that makes the electronic document escorting the goods to the Union exit work.

The accompanying document, and why abroad it counts twice

Delegated Regulation (EU) 2018/273 establishes in Article 8 that every transport of wine products between winegrowers, producers, processors, traders and retailers is escorted by an accompanying document, and that the operator must be able to produce it at any time during transport. The document covers a single consignment.

The exemptions in Article 9 are narrow and concern internal movements: transport from the vineyard to the winery, or between two premises of the same business, provided there is no change of ownership, within 70 kilometres by road and within a single Member State. A shipment to a buyer falls under none of these.

The part almost nobody explains is in Article 12. When the authorities of the third country of destination ask for the certification provided for in Article 11, that is, the attestation of origin or provenance, quality and characteristics, vintage, grape varieties and PDO or PGI, that certification can take the form of the electronic administrative document already used for movement.

In practice: the sheet you need anyway to move the wine can be the same one the country of arrival demands as a certificate. The consignor certifies the accuracy of the information and writes it in a specific box of the document. Whoever doesn't know this does two procedures where one is enough, and discovers the duplicate at the third order.

The EU label doesn't stop at the border

It is the difference that most surprises those coming from the rest of food. For any other food going outside the Union, the label normally follows the rules of the market of arrival. Not for wine, and Article 119 of Regulation (EU) 1308/2013 says so in its first line:

«Labelling and presentation of the products referred to in points 1 to 11, 13, 15 and 16 of Part II of Annex VII marketed in the Union or for export shall contain the following compulsory particulars»

The particulars are ten, and two arrived with the revision in force since 8 December 2023: the nutrition declaration and the list of ingredients, both linked to Article 9 of Regulation (EU) 1169/2011. The other eight are the category of the product, the PDO or PGI where there is one, the actual alcoholic strength, provenance, the bottler, the importer for imported wines, sugar content for sparkling wines, and for de-alcoholised wines below 10% the date of minimum durability.

From this follows something operational: the destination market's label is built on top of the EU one, not instead of it. How it changes country by country is in the export label, market by market, and that page's rule applies identically here: check before printing the batch, because the only really expensive mistake is the one discovered afterwards.

The table: which document, who issues it, when

Seven rows. On the left the document, in the middle who issues it, on the right when it is really needed. It is the wine folder, and it applies both within the Union and towards a third country, with the differences marked row by row.

Document	Who issues it	When you need it
Accompanying documente-AD, e-DAS or MVV	The consignor, from their own tax warehouse, through the electronic excise system.	Always, for every transport between operators. One consignment, one document. The exemptions concern internal movements within 70 km.
Certification of origin and vintageArt. 11 of Reg. 2018/273	The consignor, who certifies its accuracy, inside the accompanying document.	Towards a third country, when that country's authority asks for it. No separate procedure is needed: it can sit in the document already travelling.
Export invoiceand packing list	The producer.	Always outside the Union. The same description of the goods on both, and on the accompanying document.
Export customs declarationand the proof of exit	The customs broker, on behalf of the exporter.	Only towards third countries. It is where the proof that the goods have left the Union comes from.
Proof of preferential originEUR.1 or invoice declaration	Customs endorses the EUR.1; below the threshold the exporter writes the declaration on the invoice.	Towards countries linked to the Union by an agreement, and it saves duty for the buyer. The difference between the documents is in EUR.1 or certificate of origin.
Label approvalwhere it exists	The importer, not you. In the United States it is the COLA issued by the TTB.	Before the goods leave customs custody. You provide the label and the data: without them, the importer can't submit the application.
Health certificationsif that country asks for them	The ASL competent for the area, on Ministry of Health forms.	It depends on the country, and the timing can't be compressed: ask at the start of the negotiation. The procedure is in how to request the health certificate.

Country by country, what wine adds

The common part for each market is already on its own page, and isn't repeated here. What follows is only the line wine adds, and where it can't be checked from outside it says so and points to asking the importer instead of guessing.

Market	The common part	The wine line
United States	Facility registration with the FDA, US Agent and Prior Notice, covered in the label market by market.	Above 7% by volume the importer must hold a TTB COLA before removing the goods from customs custody. For bulk wine it isn't needed at import: whoever bottles it obtains it.
China	Registered facility and Decree 280 in force from 1 June 2026: exporting food to China.	Requirements change by product category and are read on the portal with your own category in hand. The Article 11 certification is requested from the importer.
Switzerland	Duty by weight, reduced VAT on food and the three languages: exporting food to Switzerland.	A third country with an agreement, so proof of preferential origin is worth money to the buyer. The accompanying document is needed anyway.
Canada	Importer licence, preventive control plan, bilingual label: exporting food to Canada.	Alcohol sales go through the provincial monopolies, which are buyers before they are authorities: which province, ask on day one.
United Kingdom	Agreement in force and REX number above the threshold: exporting food to the United Kingdom.	Since 2021 Italian wine enters as a third-country product, and the importer asks for the certification: agree it with them before loading.
Emirates and Brazil	The Emirates and Brazil, each with its own registration.	They are the two markets where alcohol has import and sale rules separate from food ones. The question to the buyer is whether they hold the licence for alcohol, not just for food.

The rule that holds the six rows together is just one: label approval and the licence to import alcohol are almost always obligations of the buyer, not yours. They become your problem only when the buyer doesn't have them, and at that point the negotiation stops before it starts. It is the first question to ask, as for any buyer to be qualified.

When the folder outgrows the person holding it

With two shipments a year and one wine, the accompanying document gets filled in and memory holds up. The breaking point is the combination: four labels, three vintages, six markets, and every combination with its own certification, its own origin threshold and its own deadline. At that point the problem stops being knowing what you need and becomes remembering it at the right moment.

That is when the list should be taken out of someone's head and put where an alert arrives when it is time to request a document, not when it is time to have it. With a constraint that matters more than the technology, written in Ethics: the system prepares and flags, but no document goes out without a person having read and approved it. On a certification of vintage and variety that signature is substance, because it is the consignor who certifies its accuracy.

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