Solera Winery Compliance Guide

Romania Winery Compliance & Reporting Guide (2026)

By Kevin Nesgoda, winemaker and founder of Solera ·

What does a Romanian winery need to report in 2026?

This answer summarizes the current consolidated rules in Order no. 144/2017, including amendments effective from 28 November 2025. Applicability depends on role, scale, products and transactions.

Romania winery reporting deadlines at a glance

Romania uses earlier national deadlines than the default windows in EU Implementing Regulation 2018/274. Use the Romanian dates below for Romanian filings. The calendar is based on the current consolidated Order no. 144/2017.

DeadlineReporting eventWho it generally concernsWhere / form
20 FebruaryQuarterly stock position at 31 JanuaryProducers, processors, bottlers, storage/depository operators, traders and certain retailersDAJ · Annex 4
20 MayQuarterly stock position at 30 AprilSame covered operator categoriesDAJ · Annex 4
15 AugustAnnual stock declaration for stock held at 31 JulyProducers, storage/depository operators and traders other than exempt retail activityDAJ · Annex 1
20 NovemberQuarterly stock position at 31 OctoberSame covered operator categoriesDAJ · Annex 4
10 DecemberGrape harvest declaration after harvest campaignGrape producers, subject to exemptionsDAJ where vineyard is located · Annexes 2 + 2a
10 DecemberWine production declaration after vinification campaignWine and other wine-product producers, subject to exemptionDAJ where vinification center is located · Annexes 3 + 3a
30 April following yearAnnual excise return, if the operator is an excise payerPersons liable for excise under the applicable excise rulesANAF · Form 120

The 3 December 2025 deadline sometimes shown for the first quarterly stock notification was a one-time transitional exception for the 31 October 2025 position. It is not the recurring 2026 deadline. The recurring October position is due 20 November.

Who must file Romanian wine declarations?

Order no. 144/2017 requires natural and legal persons that produce, store, acquire or market wine-sector products to prepare and file the documents that apply to their activity. It is not one universal return: the relevant declaration depends on what the operator actually does.

Core operator roles

  • Grape growers
  • Wine and wine-product producers
  • Processors and bottlers
  • Warehouse and depository operators
  • Wine traders
  • Certain retailers above the statutory threshold or using specialized storage

Before filing

  • Identify each role your business performs.
  • Confirm the vineyard, vinification center and storage locations tied to the declaration.
  • Reconcile stock, grape intake and production records before the reporting date.
  • Check whether a small-grower, family-consumption or retail exemption actually fits.

For the controlling language and exemptions, use Articles 2 to 5 of the current consolidated Order no. 144/2017.

The three core annual wine-sector declarations

1. Annual stock declaration: Annex 1

Snapshot: 31 July. Deadline: 15 August each year. Producers, warehouse/depository operators and wine traders generally report wine-sector stocks held on 31 July. Products derived from grapes harvested in the same calendar year are excluded from this annual stock declaration.

Retailers are exempt from the annual stock declaration unless they use specialized warehouses or market more than 2,000 liters of wine-sector products per year. This threshold comes directly from Article 3 of Order no. 144/2017.

2. Grape harvest declaration: Annexes 2 and 2a

Deadline: after the harvest campaign, no later than 10 December of the current year. The grape producer files with the DAJ in the county where the vineyard is located. Annex 2a identifies operators to whom grapes or must were sold or with whom they were vinified.

Article 4 exempts, among others, producers whose entire grape production is destined for unprocessed consumption, drying or direct grape juice, and certain holdings of no more than 0.1 hectare when the statutory conditions are met. A small parcel alone does not establish the exemption: commercialization and delivery conditions matter.

3. Wine production declaration: Annexes 3 and 3a

Deadline: after the vinification campaign, no later than 10 December of the current year. Producers file with the DAJ in the county where the vinification center is located. The declaration includes wine products sold before the declaration date, and the declared wine quantity is the total at the end of alcoholic fermentation, including lees.

Article 5 exempts producers obtaining no more than 10 hectoliters of wine through their own or contract vinification when that wine is intended for family consumption. Contract processors must record the resulting product and quantity in their own production declaration.

Filing format: Order no. 144/2017 says Annexes 1, 2, 2a, 3 and 3a are submitted and registered with the relevant DAJ in three copies. One is retained for inspection and centralization, one is routed to the territorial ONVPV inspectorate for DOC/IG/varietal wine where applicable, and one remains with the declarant.

New quarterly stock notifications: Annex 4

Romania added a separate quarterly stock notification to Order no. 144/2017 through Order no. 387/2025, published 28 November 2025. It applies to producers, processors, bottlers, storage/depository operators and traders, plus retailers that use specialized warehouses or market more than 2,000 liters of wine-sector products per year.

Stock positionRecurring deadlineFormSubmission detail
31 January20 FebruaryAnnex 4Two copies to DAJ; electronic transmission to DAJ is expressly allowed.
30 April20 MayAnnex 4Signed and dated; electronic filing is permitted.
31 October20 NovemberAnnex 4DAJ communicates the incoming registration number electronically after checks for an electronic submission.

Annex 4 captures the holder/operator type, stock location and wine stocks in hectoliters, with distinctions that include color, bulk versus bottled wine and quality categories such as DOC, IG and varietal wine. The quarterly notification does not replace the annual 31 July stock declaration.

How to prepare and file: practical sequence

  1. Map your obligations by role. Determine whether you are acting as grower, producer, processor, bottler, storage operator, trader or covered retailer for each reporting period.
  2. Reconcile vineyard and facility records. Confirm parcel, production-center and storage-location data before building the declaration.
  3. Close the reporting snapshot. Reconcile quantities by wine category, color, package state and applicable quality classification. For harvest and production returns, reconcile grape intake, origin, transformation and finished quantities.
  4. Use the correct Order 144 annex. Annual stock is Annex 1; harvest uses Annexes 2 and 2a; production uses Annexes 3 and 3a; quarterly stock uses Annex 4.
  5. File with the competent DAJ. For harvest, jurisdiction follows the vineyard location. For production, it follows the vinification center. Use the Ministry of Agriculture's official DAJ contact directory to identify the relevant office.
  6. Keep evidence of filing. Retain the declarant copy and registration evidence. For electronically submitted quarterly stock notifications, Order 144 requires the DAJ to communicate the incoming registration number through the same electronic channel after its checks.

Vineyard register, DOC/IG and varietal wine obligations

Romania manages vineyard production potential through the Registrul plantațiilor viticole (RPV), the national vineyard register. Under Article 5 of Law no. 164/2015, changes to vineyard-parcel data must be communicated by the owner or authorized representative to the competent DAJ within 30 days. Article 6 also requires the producer to maintain the vineyard holding file containing relevant authorizations, changes and mandatory declarations.

If you produce DOC, IG or varietal wine

The ONVPV authorization and certification guidance says grape producers seeking annual authorization for DOC, IG or varietal grapes apply by 30 June, while wine-production units seeking authorization for DOC, IG or varietal wine apply by 1 October. ONVPV's process includes annual authorization and certification conditions before qualifying wines are commercialized under those designations.

These ONVPV steps are additional to the Order 144 declaration cycle. Do not treat a DAJ declaration as a substitute for the product-specific authorization or certification process.

Romania wine excise in 2026 and EMCS

Form 120: annual excise return

If the winery is an excise payer under Romania's excise rules, Form 120 (Decont privind accizele) is the annual excise return. The current ANAF Form 120 page reflects the current form package, and OPANAF no. 1330/2024 sets the return framework. The annual filing deadline is 30 April of the following year. A corrective return uses the same model and is marked accordingly.

Do not infer Form 120 liability from the fact that wine has an excise rate alone. Liability depends on the operator's legal status and taxable events under the excise regime.

EMCS for covered excise movements

For wine movements that fall within the Excise Movement and Control System (EMCS), documentation must be created before dispatch. Romanian Customs explains the use of e-DA for applicable duty-suspension movements and e-DAS for applicable duty-paid movements in its official EMCS guidance. The European Commission's EMCS overview describes the corresponding e-AD and e-SAD documents across the EU system.

EMCS authorization, destination and document rules are movement-specific. Confirm the correct excise status and electronic document before the goods leave the premises.

Other Romanian digital tax systems that may affect a winery

Wine-sector declarations are not the whole Romanian reporting stack. Depending on the taxpayer and transaction, these general systems can also apply:

SystemWhy a winery should check itVerified current point
RO e-Factura Electronic invoice reporting for transactions within the statutory scope. For in-scope invoices, the 2026 transmission deadline is 5 working days from issue, subject to the statutory invoice-issuance limit. See OUG no. 120/2021 and ANAF's 2026 guidance.
SAF-T / D406 Accounting and tax data reporting for taxpayers within scope. Small taxpayers entered the SAF-T reporting timetable from 1 January 2025, subject to the statutory scope and exclusions. Frequency depends on the taxpayer's tax period. See OPANAF no. 1783/2021 and ANAF SAF-T guidance.
RO e-Transport Covered road movements can require a UIT code and shipment data before transport. Wine falls within CN 2204, inside the alcoholic-beverage grouping identified by OPANAF no. 802/2022 for high fiscal-risk goods. OUG no. 41/2022 also brings covered international road movements into RO e-Transport. Because scope, thresholds and exceptions depend on the movement, verify each shipment before dispatch rather than applying a blanket winery rule.

This section is a routing checklist, not a substitute for transaction-specific tax analysis. A winery can be in scope of one system and out of scope of another.

Records, corrections, confirmations and retention

What information should be reconcilable?

  • Taxpayer and establishment identifiers, including CNP/CUI where the form requires them
  • Vineyard parcels and bearing area
  • Grapes harvested, purchased, delivered or processed and their origin
  • Wine produced, including the production categories used by the declaration
  • Stocks in hectoliters, including color, bulk/bottled status and applicable DOC/IG/varietal categories
  • Counterparties used in the harvest and production annex schedules
  • Filing copies, incoming registration numbers and electronic acknowledgements

Retention

EU Implementing Regulation 2018/274 sets a minimum five-year retention period for accompanying documents and copies, counted from the end of the calendar year in which they were completed. It also requires inward and outward registers and the supporting operation documents to be kept for at least five years after the accounts to which they refer are closed. See Article 35 of Commission Implementing Regulation (EU) 2018/274.

Corrections and proof

Order no. 144/2017 makes incorrect, incomplete and late declarations sanctionable under Law no. 164/2015. If you discover an error, contact the competent DAJ promptly for the accepted correction procedure and preserve the original filing evidence, correction and subsequent confirmation. For Form 120, ANAF provides a formal corrective-return mechanism.

Common Romanian winery reporting mistakes

  • Using the EU default deadline instead of Romania's earlier deadline. Romania requires annual stock by 15 August and harvest/production by 10 December.
  • Missing the new quarterly stock cycle. Annex 4 is additional to the annual 31 July stock declaration.
  • Reusing the one-time 3 December 2025 transition date. The recurring October stock deadline is 20 November.
  • Assuming a small-vineyard exemption from size alone. Order 144 attaches destination, commercialization or delivery conditions to the 0.1 hectare harvest exemptions.
  • Using an outdated zero excise rate for still wine. The current 2026 rate is 11 lei/hl of product.
  • Treating DAJ declarations as a substitute for ONVPV authorization. DOC, IG and varietal production can require separate annual authorization and certification steps.
  • Dispatching a covered excise movement before creating the required EMCS document. Determine the excise status and movement document before dispatch.
  • Failing to retain filing evidence. Keep registered copies, electronic acknowledgements and the records that reconcile to reported quantities.

Romania winery compliance FAQ

When is Romania's annual wine stock declaration due?

The annual Annex 1 stock declaration is due by 15 August for stocks held on 31 July. Wine products made from grapes harvested during the same calendar year are excluded from that annual stock declaration.

Does Romania now require quarterly wine stock reports?

Yes. The current Order no. 144/2017 requires Annex 4 notifications for covered operators for stocks at 31 January, 30 April and 31 October, due 20 February, 20 May and 20 November respectively.

When are grape harvest and wine production declarations due in Romania?

Both are due after their respective campaign and no later than 10 December of the current year. Harvest uses Annexes 2 and 2a; production uses Annexes 3 and 3a.

Where does a Romanian winery file the wine-sector declarations?

With the competent county agricultural directorate, the DAJ. Harvest filing follows the vineyard location; production filing follows the vinification-center location. Quarterly Annex 4 may be sent electronically to the DAJ under the current Order 144 rules.

What is Romania's 2026 excise rate for still wine?

The Ministry of Finance's 2026 table lists 11 lei per hectoliter of product for still wine. Sparkling wine is listed at 83.81 lei per hectoliter of product. Applicability and excise-payment mechanics depend on the operator and taxable event.

Does every Romanian winery file Form 120?

No. Form 120 is an excise return for persons liable under the excise rules. Do not assume every winery files it merely because wine has an excise rate.

How long should winery movement and register records be kept?

EU Implementing Regulation 2018/274 requires accompanying documents and copies to be retained for at least five years from the end of the year in which they were completed, and inward/outward registers plus supporting documents for at least five years after the related accounts are closed.

Official sources and verification notes

Material compliance claims in this guide were checked against Romanian government, Romanian authority and EU primary sources. All links below were accessed and rechecked on 5 August 2026.

  1. Romania, Order no. 144/2017, consolidated form
    Portal Legislativ · current consolidated text including Order no. 387/2025 amendments · declarations, deadlines, exemptions, filing copies, Annexes 1-4.
  2. Romania, Order no. 387/2025
    Portal Legislativ · published 28 November 2025 · introduced the quarterly stock-notification framework and transition rule.
  3. Romania, Law no. 164/2015 on vines and wine
    Portal Legislativ · vineyard register, vineyard holding records, declaration contraventions and fines.
  4. Government Decision no. 512/2016
    Portal Legislativ · implementing rules for Law no. 164/2015 and the wine-sector framework.
  5. ONVPV: vineyard and producer authorization; DOC/IG/varietal certification
    Oficiul Național al Viei și Produselor Vitivinicole · official authorization and certification guidance.
  6. MADR: county agricultural directorates (DAJ) contact directory
    Ministry of Agriculture and Rural Development · official DAJ directory.
  7. Commission Implementing Regulation (EU) 2018/274
    EUR-Lex · wine-sector declarations, registers, deadlines and five-year record-retention rules.
  8. Commission Delegated Regulation (EU) 2018/273
    EUR-Lex · vineyard register, declarations, accompanying documents and wine-sector controls.
  9. Romania, Law no. 141/2025
    Portal Legislativ · amended the wine excise schedule, including rates that apply in 2026.
  10. Ministry of Finance: excise duty rates applicable in 2026
    Ministerul Finanțelor · official 2026 table, including still and sparkling wine.
  11. ANAF: Form 120, Decont privind accizele and OPANAF no. 1330/2024
    ANAF / Portal Legislativ · current excise return resources and filing framework.
  12. Romanian Customs: EMCS frequently asked questions and European Commission: EMCS
    Autoritatea Vamală Română / European Commission · electronic excise-movement documentation.
  13. OUG no. 120/2021, RO e-Factura and ANAF 2026 e-Factura guidance
    Portal Legislativ / ANAF · electronic invoicing framework and 2026 transmission timing.
  14. OPANAF no. 1783/2021, SAF-T
    Portal Legislativ · D406 / SAF-T framework, supplemented by current ANAF guidance.
  15. OUG no. 41/2022, RO e-Transport and OPANAF no. 802/2022
    Portal Legislativ · RO e-Transport framework and high fiscal-risk goods classification used to route winery transport checks.
Verification result: No unresolved material-source conflict remains in the claims published above. The most consequential conflict found during research was an outdated excise schedule showing still wine at 0 lei/hl; the later Law no. 141/2025 and Ministry of Finance 2026 table control the 2026 rate shown here. We also treated the 3 December 2025 first-quarterly-notification extension as historical, not as a recurring deadline.

Change log and next review

5 August 2026, v1.0: Initial English publication. Verified current Order no. 144/2017 consolidation, Order no. 387/2025 quarterly stock notifications, 2026 excise rates, Form 120, EMCS, RPV/ONVPV and supporting EU rules.

Recommended next review: by 1 November 2026, before the 20 November quarterly stock and 10 December harvest/production filing cycle, or sooner if MADR, ONVPV, ANAF, Romanian Customs or EU rules change.

Disclaimer: This guide is for operational planning and educational use. It is not legal, tax, excise or regulatory advice. Rules can depend on operator status, product classification, transaction type and local facts. Confirm current requirements with the competent Romanian authority and qualified professional before filing or moving excise goods.

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Disclaimer: This guide is for informational purposes only and is not legal, tax, or compliance advice. Verify all requirements with the relevant regulatory agency.