Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The movement of products under a suspensive regime requires the protection of an electronic administrative document. In the case of e-cigarette liquids sent from the Peninsula or the Balearic Islands to the Canary Islands, the sender must submit a draft via EMCS and obtain an ARC to facilitate the identification of the transport. The use of this document is mandatory to ensure the control of the movement of products subject to excise duties.
The DGT's position remains constant in requiring an electronic administrative document for movement under a suspensive regime. Throughout the rulings, the cases of application have been specified, such as the distance in provisioning or specific documentation for navigation and new category products such as e-cigarette liquids.
Turning points
Establishes that the exception of not using an electronic administrative document in provisioning only applies to journeys of 50 kilometers or less.
Determines that, after July 1, 2019, supply during navigation must be documented with an electronic administrative document or a movement note.
Analysis based on 8 of 10 rulings with a stated position. Updated 28 September 2026.