Choose the firm that will secure your excise duties, your EORI number and your customs representation in 2026

Harmonised excise duties, EORI and customs representation

Harmonised excise duties apply to three broad families: alcohols and alcoholic beverages (consolidated Directive 92/83/EEC, CGI art. 302 B to 302 F), energy products and electricity (Directive 2003/96/EC, CGI art. 265 et seq., TICPE, TICGN and TICFE taxes), and manufactured tobacco (Directive 2011/64/EU, CGI art. 575 to 575 M). Since the reform introduced by Ordinance 2021-1843 and Directive 2020/262, excise management has moved from the customs administration to the DGFiP (French tax authority) for collection, while the DGDDI remains competent for movements under suspension. Transactions are documented by the e-AD (electronic accompanying document) via EMCS.

The EORI number, established by Regulation 2015/2447, is required of any operator filing a customs declaration in the European Union, acting as consignee for a shipment subject to formalities, or carrying out customs representation. In France, EORI is issued by the economic action division of the competent regional customs authority, in the format FR + SIREN + five-digit suffix. An operator may apply for the Authorised Economic Operator status (AEO-C for customs simplification, AEO-S for security, AEO-F combining both), which unlocks procedural facilitations.

Customs representation is based on article 18 of the Union Customs Code (Regulation 952/2013), which distinguishes direct representation (in the name and on behalf of the represented person) from indirect representation (in the representative's own name but on behalf of another, with joint and several liability for the customs debt). The registered customs representative (RDE) is registered with the DGDDI and holds a written mandate for each client. Specialised firms often combine RDE and AEO statuses to deliver an integrated service.

Operators concerned, thresholds and statuses

All operators that bring in, dispatch, store or market products subject to excise duties are concerned, as are, more broadly, all companies whose import or export operations require a customs declaration. Thresholds and statuses determine the organisation to put in place.

Frequent use cases include the wine trader shipping under duty suspension to an Italian warehouse, the energy products importer releasing diesel for consumption in France, the online wine merchant selling to individuals in other Member States under the distance sales regime for products subject to excise duty (article 36 of Directive 2020/262), the manufacturer of nicotine-containing e-liquids paying the levy on heated tobacco products, or the non-EU e-commerce platform mass-clearing H7 shipments below 150 euros.

Services of a specialised excise and customs firm

The engagement covers both day-to-day declarative production and strategic advice on suspensive regimes. Eight services structure the offering.

• Obtaining and maintaining the EORI number, SOPRANO enrolment, AEO file monitoring when the operator aims for full or partial certification, including pre-certification audit.
• Analysis of applicable regimes by product family, tariff classification (Combined Nomenclature, BTI, BOI), determination of harmonised or national excise regimes, duty optimisation through legal structuring.
• Production of DELTA G (standard import and export), DELTA X (simplification) and DELTA H7 (e-commerce shipments below 150 euros) declarations, and running of the EMCS system for movements under duty suspension.
• Maintenance of the stock accounts required for suspensive warehouses, packaging workshops and certified consignees, with periodic physical counts and justification of technical variances.
• Management of bonds and financial guarantees: flat-rate bond, comprehensive bond, guarantee waiver for AEOs, relations with banking and mutual sureties.
• Effective customs representation: filing in the client's name, signing of declarations, monitoring of liquidations, payment of duties and taxes, recovery of the fuel tax credit, handling of litigation on tariff reclassification.
• Interface with the DGFiP for the collection of excise duties and the liquidation of indirect taxes on non-alcoholic beverages (levy on beverages with added sugars, article 1613 ter of the CGI), and various health and environmental contributions.
• Monitoring and compliance: updating of the customs compliance plan, training of purchasing and logistics teams, management of customs audits, preparation for post-clearance controls (CPD).

Deliverables include the EORI and AEO file, daily declarations, stock accounts, internal control reports and an annual wrap-up note recapping the flows cleared, the duties paid and the optimisation avenues. The added value of a firm is measured in the reduction of the declaration rejection rate (target below 0.5 per cent), in the reliability of tariff classifications and in the optimisation of suspensive regimes.

Indicative breakdown of excise duties by family

The chart below shows the indicative breakdown of harmonised excise duty revenue collected in France, to clarify compliance priorities and the risks weighing on each product family. The orders of magnitude, expressed as a percentage of total excise revenue, help anticipate the intensity of DGDDI controls on each segment.

Criteria for choosing your firm

Four criteria shape the choice. First, dual excise and customs expertise. The French market has few firms that combine hands-on customs expertise with fine mastery of stock accounts for suspensive warehouses. Requiring a recent reference on a product family comparable to yours (wines, spirits, energy products) avoids a costly learning curve.

Second, geographic and port coverage. Import and export flows transit through Le Havre, Marseille-Fos, Dunkirk, Roissy, but also via the border offices of Antwerp or Rotterdam relocated to France through centralised clearance rules (CCL). A firm with offices in the major customs hubs speeds up incident resolution.

Third, IT capacity. The DELTA G, DELTA X, DELTA H7, EMCS and SOPRANO interfaces require permanent maintenance of EDI connectors. The best-equipped firms offer a real-time client portal, monitoring of quality indicators (rejection rate, lead times, damages) and traceability of mandates.

Fourth, legal robustness. A tariff classification dispute, a preferential origin challenge or an excise reclassification procedure can mobilise several thousand hours of advisory work. The availability of a dedicated legal team, able to argue before the Commercial Chamber of the Cour de cassation or before the Court of Justice of the European Union, sets the benchmark firms apart.

Comparative analysis and field feedback

The market features three families. Historic customs brokers (Geodis, Dachser, DB Schenker, Bolloré Logistics, Kuehne+Nagel, DHL Customs) offer an integrated transport and clearance service, with strong international coverage. Specialised advisory firms (Deloitte Douane, EY Indirect Tax, PwC Customs, Fidal Douane, Altius) bring deep legal expertise, useful for tariff reclassification cases and supply-chain structuring. Accredited Fiscal Representatives (Fiscal Partner, Fiscal Connexion, Experts TVA) add the excise and customs representation dimension to their VAT representation offering, particularly relevant for non-EU operators who combine both needs.

Field feedback highlights three success factors: the appointment of a customs referee on the client side, who centralises mandates and powers of attorney; the deployment of operational dashboards (rejection rate, clearance lead times, unit cost per declaration); and preparation for post-clearance controls through regular mock audits. Conversely, typical mistakes include mis-classification of the flagship product, underestimating the bonds required for a suspensive warehouse, diluted responsibilities between a fast forwarder and a distant legal firm, and forgetting to renew RDE mandates annually.

A company that has its excise and customs activity run by a firm aligned with its operations typically reports a 30 to 50 per cent reduction in DELTA rejections and a significant drop in the time spent by internal logistics teams on disputed files.

Fee ranges observed in 2026

Pricing usually combines a per-declaration fee and a management retainer. The average cost per standard DELTA G declaration is between 25 and 75 euros excluding tax depending on complexity and volume, falling to 8 to 18 euros for volumes above 5,000 declarations per month. DELTA H7 declarations for e-commerce run between 0.90 and 2.50 euros per shipment. A monthly retainer for running a suspensive warehouse for alcohols or energy products ranges from 1,500 to 6,000 euros excluding tax depending on the complexity of the stock accounting plan.

Specialised advisory services (tariff classification, BTI application, AEO preparation, litigation) are billed on a time-spent basis, between 220 and 450 euros excluding tax per hour. Building a complete AEO file ranges between 12,000 and 35,000 euros excluding tax. Representation during a post-clearance audit is priced between 6,000 and 25,000 euros depending on the depth of the audit and the number of declarations reviewed. A solid quote specifies the DELTA and EMCS scope, the volume-based decreasing pricing, the third-party costs (translations, apostilles, bonds) and the exit clause.