The transition to fully electronic document management in alcohol transportation runs into two unresolved technical barriers. The first is the lack of approved XSD schemas for reporting forms on the turnover and production of alcoholic products. The schemas are approved by industry regulation, and until they appear, market participants physically cannot prepare software solutions.
The second barrier is self-pickup. When a supplier delivers products with its own transport or the buyer collects them, EGAIS has no mechanism to process such an operation electronically. This entire segment of transportation is currently documented exclusively on paper.
E. Suslova-Novozhilova, a representative of the Chamber of Commerce and Industry, stated the industry's position directly:
"Either we need to somehow see these schemas and prepare, or the deadline needs to be extended. There are no other options here."
Market participants also lack clarity on combining formats. How to issue a paper waybill when there is an electronic one — together or separately — remains an open question.
"And the question of how we issue paper waybills when there is an electronic waybill, whether we issue them together or in some other way, is very pressing, and we would like to sort it out," Suslova-Novozhilova noted.
If EGAIS is not upgraded to support self-pickup, the industry will face a hard choice. Either the deadline for abandoning paper shifts again, or self-pickup as a delivery scheme effectively drops out of legal circulation.
"The EGAIS system needs to be upgraded somehow, and until this issue is resolved, we cannot say that we will abandon paper on March 1, 2027. Or, together with paper, we abandon self-pickup," the chamber representative explained.
The most realistic option under consideration is extending the right to use paper waybills until September 2027. This would give the regulator time to approve the XSD schemas and EGAIS developers time to adapt the system to all delivery schemes. Specific deadlines and a decision on the extension have not yet been officially adopted.
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