Ask the Collective
The questions independent drinks founders ask most — answered. Distilled from years of community knowledge so the good stuff never disappears in the feed again.
What is the process for obtaining FDA registration for a manufacturing facility to export spirits to the United States?
FDA registration for a canning/manufacturing facility is achievable but administrative. Most members use a US agent to handle the application, though it can be done in-house. **Key approaches:** - **Liberty Management Group** — members have used them as a US agent to handle FDA registration applications and act as your agent for a fee - **Self-service route** — members report their ops team has completed the registration themselves; it's doable but time-consuming - **Local US contacts** — some members have engaged individuals in the US (e.g. Texas-based) to manage the application locally **Essential requirement:** Your canning/manufacturing company must be set up as an FDA food facility registered. You will need a US agent regardless of whether you handle paperwork yourself or outsource it entirely. **Next steps:** Contact members directly for introductions to their FDA contacts or service providers — several members offered direct introductions within the community.
What are the red flags and common tactics used in carousel fraud and export scams targeting drinks producers?
Export fraud targeting drinks producers has become increasingly common. Members have encountered several recurring scam patterns that share telltale warning signs. **Common scam tactics:** - **Carousel fraud with large bulk orders** — Scammers approach via existing customers or direct outreach offering suspiciously large weekly volumes (e.g. 8 pallets/week of gin and vodka to Germany). These orders have "all the hallmarks" of carousel fraud schemes and should be declined. - **The import licence registration scam** — An importer (members cited Indonesia examples) appears semi-legitimate, quickly accepts commercial terms, then places a large PO (e.g. £40k for a container). They then ask you to register the product for a made-up import licence and introduce a local lawyer charging £500+ to "process" it. Members refer to this as "the old 411 scam." - **Fraudulent credit requests on large orders** — Companies accept high-value POs (e.g. £100k) but then request credit terms. The fraud only becomes apparent when you attempt third-party financing. - **Email and domain spoofing** — Watch for near-identical company names and domains with subtle differences (e.g. "musgrave-group.com" vs the real domain without the hyphen). Generic, well-written emails from unknown companies should be treated with suspicion. **Warning signs to watch for:** - Unable to find any online presence or company information via Google - Suspiciously quick acceptance of commercial terms - Requests for cash upfront or involvement of third-party lawyers for licensing - Offers of unusually large volumes - Email addresses or websites with slight variations from legitimate company names - Enquiries via Facebook from "Guest" accounts **Verification tactics:** Members recommend checking company websites carefully for domain authenticity and running any unfamiliar company names through the community before proceeding. When in doubt, decline and share the company name with others.
What are the key differences between UK and EU labelling regulations for alcohol products?
The UK and EU have broadly similar labelling rules for alcohol, but there are several important differences to be aware of: **Units and tax stamps:** - The EU does not require units to be displayed on labels, whereas the UK does - The UK requires a tax/duty stamp on labels; the EU generally does not (with exceptions including Italy) - If exporting from the UK to the EU with a UK label that includes a tax stamp, you must place a sticker over the duty stamp to comply - From 1 May onwards, there is no issue with obliterating the duty stamp when exporting from the UK **Practical approach:** Members recommend checking with your distributor or legal advisor about the specific requirements for your target EU markets, as rules can vary by country (e.g. Italy has its own tax stamp requirements). The similarity of most rules means a single label design can often work across both markets with minor modifications like the sticker solution for duty stamps.
Do you need to pay tax when exporting alcohol from the UK, and how should duty stamps be handled?
When exporting alcohol from the UK to anywhere outside the UK, you must obliterate the duty stamp under HMRC regulations. However, from 1 May onwards, this obligation changes and no longer presents an issue. Members flagged that it can seem counterintuitive to pay tax when moving product internationally—particularly when exporting to nearby markets like France—but the rule applies across all destinations. One member noted that if you're struggling with tax liability on exports, sourcing and purchasing stock locally in your destination country (rather than exporting from the UK) may be a more practical commercial solution, though this requires advance planning. The key takeaway: obliterate duty stamps on export shipments before 1 May; after that date, the requirement no longer applies.
Are non-standard spirit bottle sizes (e.g., 75cl) legal for exporting spirits to the UK?
Non-standard spirit bottle sizes are **not legal** for spirits in the UK market. Members' experience confirms that while you may not face immediate enforcement action, the regulatory risk is not worth taking. - **UK Weights and Measures regulations** require spirits to be sold in specified quantities only (typically 20cl, 35cl, 50cl, 70cl, 1L and larger standard sizes). 75cl does not meet these legal requirements. - **Member experience**: One founder launched with 250ml bottles and realised after 6 months it was illegal; they quietly switched to the compliant 200ml and 500ml sizes under the guise of a "new product launch" to avoid immediate enforcement. - **Risk profile**: You won't necessarily get "pulled up for it immediately," but relying on this is unwise for a legitimate export operation. **Caveats**: If your Arrack is currently bottled in 75cl in Sri Lanka, you will need to rebottle into a UK-legal size for UK distribution. This adds cost and complexity to your supply chain.
What icons, disclaimers and information are legally required on spirits labels for export?
Legal labelling requirements for spirits exports are less prescriptive than many assume. The essentials are **spirit type, ABV (alcohol by volume) and volume**—these are the core legal requirements across most markets. Beyond that, requirements vary significantly by destination market. Members recommend consulting **The Portman Group**, which provides comprehensive guidance on labelling. However, note that many Portman Group recommendations are suggested best practice rather than legal obligations. The key is to clarify your specific export destination(s), as different markets have different rules. Members emphasise checking requirements country-by-country rather than applying a one-size-fits-all approach.
Do importers' addresses need to be displayed on product labels when exporting to Denmark?
No, you do not need to put the importer's address on your product labels for Denmark exports. However, you **do need to display an EU address** on the label. This applies even if your importer is based outside the EU—you'll still need a European contact point visible on the packaging.
What is the process for claiming back UK duty on duty-paid stock for export, and what should exporters expect from HMRC?
Claiming back duty on duty-paid stock for export is a difficult and heavily scrutinised process. HMRC deliberately makes the procedure hard to prevent duty-avoidance fraud, so be prepared for extensive compliance checks and investigation. **Key guidance from members:** - **HMRC scrutiny** — The process attracts significant regulatory attention; exporters should expect HMRC to examine claims thoroughly. - **Use under-bond stock instead** — Members strongly advise exporting goods held under bond (which have not paid duty) rather than attempting to recover duty already paid. This avoids the complexity and scrutiny entirely and is the preferred route. **Caveat:** If you have any under-bond stock available, that is the recommended solution to avoid the difficulty and delays of duty recovery claims.
What is the correct format for displaying alcohol by volume (ABV) on labels for products exported to Australia?
Australia requires ABV to be written as **%Alc/Vol** rather than %Vol. Members confirm: - **%Alc/Vol** — This is the mandatory format according to an Australian distributor contact in the community. Conflicting information exists online, but direct feedback from someone operating in the Australian market confirms this is the required labelling standard.
Do I need food certification from my local council to export beverages?
Yes, local council food certification is typically required for export. Members report needing to obtain certificates from their local Environmental Health office before exporting to certain markets, particularly in Asia-Pacific regions like China. The process usually involves HACCP certification as part of the requirement. Contact your local Environmental Health department to initiate the process — they should be able to guide you through the specific requirements for your destination market.