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

Wine leaves Italy with a set of paperwork no other food carries. Not because it costs more, but because it's closely monitored.

This piece is part of the guide to export operations for small food producers and covers wine in general, not any particular country. For what wine has in common with any other food, meaning the shipping paperwork and the rules of the destination market, see the documents that go with a shipment and the country pages linked below.

What changes compared with any other food

Three things, and none of them appears in a general food export guide. Wine is an excise product, so its movements are tracked by a system of their own. It has a compulsory accompanying document other foods don't have. And it has its own labelling rules, which the EU applies even when the wine leaves the Union.

Everything else is the same: export invoice, packing list, transport document, customs declaration, proof of preferential origin where there's an agreement. If you come to wine after exporting olive oil or preserves, half the work is already done, and you just need to add the tax layer.

The duty is zero, and that's exactly what confuses people

The table of national rates published by the Italian Customs and Monopolies Agency, 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. For comparison, in the same table ethyl alcohol is €1,035.52 per hectolitre of pure alcohol and intermediate alcoholic products €88.67 per hectolitre.

A zero rate doesn't mean outside the system. Wine is still an excise product, and the practical consequence is that, for the tax authorities, a winery is a tax facility. The Agency makes this clear when it lists the facilities that can operate under the tax warehouse regime in the alcohol sector: among them are wineries and production sites for wine and for fermented beverages other than wine and beer.

The suspension regime, the same source explains, covers the production, processing, holding and movement of excise goods up to the point where the duty becomes payable. Opening a tax warehouse requires an authorisation, and for products other than tobacco a licence as well: the procedure ends with the assignment of an excise number.

If you bottle and sell wine in Italy, you already have this piece in place, and you often don't connect it with export. It's that number that makes the electronic document accompanying the goods work, all the way to their exit from the EU.

The accompanying document, and why it counts twice abroad

Article 8 of Delegated Regulation (EU) 2018/273 states that every transport of wine products between growers, producers, processors, traders and retailers must be accompanied by an accompanying document, which the operator must be able to show at any point during transport. The document covers a single consignment.

The exemptions in Article 9 are narrow and cover internal movements: transport from the vineyard to the winery, or between two premises of the same business, as long as there's no change of ownership, the distance is within 70 kilometres by road, and it stays inside one Member State. A shipment to a buyer doesn't fall into any of them.

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

In practice: the document you need anyway to move the wine can be the same one the destination country demands as a certificate. The consignor certifies that the information is accurate and enters it in a specific box on the document. If you don't know this, you'll do two sets of paperwork where one would do, and only discover the duplication by the third order.

The EU label doesn't stop at the border

This is the difference that most surprises people coming from the rest of the food sector. For any other food heading outside the EU, the label normally follows the rules of the destination market. 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”

There are ten particulars, and two arrived with the revision that has applied 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 product category, the PDO or PGI where there is one, the actual alcoholic strength, the provenance, the bottler, the importer for imported wines, the sugar content for sparkling wines, and, for dealcoholised wines below 10%, the date of minimum durability.

One practical point follows from this: 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 export labelling, market by market, and that page's rule applies here too: check before printing the batch, because the only really expensive mistake is the one you find 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 you actually need it. This is the wine's paperwork, and it applies both within the EU and for non-EU countries, with the differences marked row by row.

Document	Who issues it	When to use 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 cover internal movements within 70 km.
Certification of origin and vintageArt. 11 of Reg. 2018/273	The consignor, who certifies its accuracy, within the accompanying document.	For a non-EU country, when that country's authority asks for it. No separate paperwork needed: it can sit in the document that's already travelling.
Export invoiceand packing list	The producer.	Always outside the EU. The same description of the goods on both, and on the accompanying document.
Customs export declarationand proof of exit	The customs broker, on the exporter's behalf.	Only for non-EU countries. This is where proof that the goods have left the EU 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.	For countries linked to the EU 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's 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 apply.
Health certificatesif that country requires them	The local health authority (ASL) for your area, on Ministry of Health forms.	Depends on the country, and the lead times don't shrink: ask at the start of the negotiation. The procedure is in how to apply for the health certificate.

Country by country, what wine adds

What each market has in common is already on its own page and isn't repeated here. What follows is just the extra line wine adds, and where it can't be checked from outside, we say to ask the importer rather than guess.

Market	What's common to all food	The extra line for wine
United States	FDA facility registration, US Agent and Prior Notice, covered in labelling market by market.	Above 7% by volume the importer must hold a TTB COLA before taking the goods out of customs custody. Bulk wine doesn't need one at import: the bottler gets it.
China	Registered facility and Decree 280, in force since 1 June 2026: exporting food to China.	Requirements vary by product category and have to be read on the portal with your category in hand. Ask the importer about the Article 11 certification.
Switzerland	Duty by weight, reduced VAT on food and the three languages: exporting food to Switzerland.	A non-EU country with an agreement, so proof of preferential origin is worth money to the buyer. You still need the accompanying document.
Canada	Importer's licence, preventive control plan, bilingual label: exporting food to Canada.	Alcohol is sold through the provincial liquor boards, which are buyers before they're regulators: ask on day one which province.
United Kingdom	Agreement in force and a REX number above the threshold: exporting food to the United Kingdom.	Since 2021 Italian wine enters as a product from a non-EU country, and it's the importer who asks for the certification: agree it with them before loading.
Japan	Economic Partnership Agreement with the EU: the preference only applies if the proof of origin travels with the goods.	With proof of origin the duty is zero; without it you pay 15% or 125 yen per litre. The liquor tax of 100 yen per litre applies either way.
Australia	Label in English, with three items the EU label doesn't require.	Pregnancy warning, standard drinks, and alcohol content accurate to within 1.5%, plus 29% WET on the value.
Emirates and Brazil	Emirates and Brazil, each with its own registration.	These are the two markets where alcohol has import and sales rules separate from the food ones. The question for the buyer is whether they have a licence for alcohol, not just for food.
Albania	A non-EU country: export declaration and proof of origin for the preference, as for any shipment outside the EU.	Albania's rules on wine imports can't be checked from outside against an open primary source: ask the importer in writing about documents, label and duty before making an offer.

One rule holds all these rows together: label approval and the licence to import alcohol are almost always the buyer's obligations, not yours. They only become your problem when the buyer doesn't have them, and at that point the deal stalls before it starts. It's the first question to ask, as with any buyer you need to qualify.

When the paperwork outgrows the person holding it

With two shipments a year and one wine, you fill in the accompanying document and memory holds up. It breaks down with combinations: four labels, three vintages, six markets, and each 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's when the list needs to come out of someone's head and into a place where an alert arrives when it's time to request a document, not when it's time to have it. With one rule that matters more than the technology, set out in Ethics: the system prepares and flags, but no document goes out until a person has read and approved it. On a certification of vintage and variety, that sign-off is substance, because the consignor is the one certifying its accuracy.

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