Modernization of Excise Framework: Adoption of New Regulations on Excise Stamps and the Introduction of the E-Excise System

In the Official Gazette of the Republic of Serbia No. 78/2024, dated September 27, 2024, two important regulations were published:

• Regulation on the Design of Control Excise Stamps, Control Excise Stamps with a QR Code, Types of Information on the Stamp, Procedures for Approval and Issuance of Stamps, Keeping Records on Approved and Issued Stamps, and Labeling of Excise Products with Control Excise Stamps or Control Excise Stamps with a QR Code, as well as the Types of Individual Packaging for Coffee for Final Consumption Labeled with a Control Excise Stamp (“Regulation on the Design and Labeling of Excise Products”);
• Regulation on the Conditions, Methods, and Procedures for Registering Users of the E-Excise System, the Content and Manner of Retrieving Data from Other Registers Maintained by Competent Authorities, as well as Data Related to Excise Products, Excise Taxpayers, and Participants in Trade, Procedures for Managing Business Processes within the E-Excise System, and the Exchange of Data and Information between Users of the E-Excise System Concerning Excise Products, the Recording, Storage, and Processing of Data Related to the Movement of Excise Products (“Regulation on the E-Excise System”).

These regulations came into force on September 28, 2024, and have been applied from October 1, 2024, with the following exceptions:

• Provisions of the Regulation on the Design and Labeling of Excise Products, relating to the labeling of excise products with control excise stamps, will be applied from January 1, 2025. Until then, the previous Regulation on the Design of Control Excise Stamps, the Type of Information on the Stamp, and the Procedure for Approval and Issuance of Stamps, Keeping Records of Approved and Issued Stamps, and Labeling Cigarettes, Alcoholic Beverages, and Coffee (Official Gazette of RS Nos. 137/2004, 11/2005, 29/2005, 56/2005, 75/2005, 88/2005, 108/2006, 83/2011, 113/2015, 9/2017, and 108/2017) will be applied;
• Provisions of the Regulation on the E-Excise System related to the scanning of control excise stamps with a QR code, production codes, and tracking of the movement of excise products for which QR code scanning on the control excise stamp is mandatory, will also be applied from January 1, 2025.

The adoption of these new excise regulations introduces significant changes regarding the labeling of excise products and the digitalization of the system for user registration and reporting, with the aim of improving control and efficiency in managing excise product trade.

In the following text, we provide an overview of the most significant provisions of each of the mentioned regulations.

1. Regulation on the Design and Labeling of Excise Products

This Regulation provides detailed rules regarding the design and content of control excise stamps, including the introduction of stamps with QR codes, as well as the procedures for approval, issuance, and record-keeping of these stamps, improving the labeling of alcoholic beverages and coffee intended for final consumption. The key provisions of the Regulation on the Design and Labeling of Excise Products cover the following aspects:

• The required information that a QR-coded stamp must contain;
• The information to be included within the printed QR code on the stamp;
• The design of QR-coded stamps for labeling alcoholic beverages;
• A new method for labeling excise products;
• The procedure for printing, approving, and issuing stamps through the National Bank of Serbia, as well as the pre-approval process by the Ministry of Finance;
• The procedure for handling damaged or unused QR-coded stamps.

Violations of the provisions of the Regulation on the Design and Labeling of Excise Products will result in misdemeanor liability, with fines ranging from RSD 100,000 to RSD 2,000,000 for legal entities, and from RSD 50,000 to RSD 500,000 for entrepreneurs and responsible persons in legal entities. Fines will be imposed in cases of:

• Failure to return damaged or unused stamps, including QR-coded stamps, within the prescribed period, or failure to calculate and pay excise duties in the manner and timeframe prescribed by this regulation;
• Failure to submit reports through the e-excise system within the prescribed period;
• Failure to conduct an inventory or submit Form SZ within the prescribed period;
• Failure to return unused stamps within the prescribed period, or failure to calculate and pay excise duties in the prescribed manner and timeframe.

2. Regulation on the E-Excise System

This Regulation governs the conditions, procedures for registering users of the e-excise system, retrieving data from other registers, as well as the exchange and processing of data related to excise products and taxpayers to enhance the management of business processes and tracking the movement of excise products.

Users of the e-excise system register for access and use of the system in accordance with the Law on Excise Duties and technical instructions published on the Ministry of Finance’s website. Registration in the e-excise system is done through a web portal using an electronic identification scheme with a high level of reliability.

The users of the e-excise system include the Ministry of Finance, excise taxpayers, the National Bank of Serbia, the Tax Administration, the Customs Administration, the Tobacco Administration, as well as wholesale and retail tobacco traders. The system includes modules for managing requests and reporting on QR-coded control stamps, production codes, excise licenses, and warehouses, as well as tracking the movement of cigarettes and non-combustible tobacco.

The Ministry of Finance retrieves and exchanges data with relevant authorities, and system operations are conducted in accordance with the User Manual.

The establishment of the e-excise system marks a significant step toward the complete digitalization of the excise system, aiming for faster procedures, reduced administrative costs, and increased efficiency in the supervision and control of excise products. Whether these goals will be achieved remains to be seen.

Sonja Stojčić

Senior Associate

sonja.stojcic@prlegal.rs; legal@prlegal.rs;