Knowledge Base

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.

Regulation & Compliance25 discussions

What are the UK regulations on bottle fill tolerances and declared volumes for duty and trading standards purposes?

Fill tolerance in the UK is split between two regulators. HMRC allows a 5% tolerance on duty calculations, which applies to the litres of pure alcohol (LPA) declared—there is no tolerance on the duty itself, only on allowable losses in production. Trading standards and local authorities enforce weights and measures under packaged goods regulations via gov.uk/weights-measures-and-packaging-the-law/packaged-goods. The key distinction is whether you pack to a minimum or an average: if you declare a minimum (e.g. "70cl minimum"), you cannot go under that figure; if you pack to average (marked with an epsilon symbol €), there is a tolerance up and down. However, if you knowingly overfill beyond the stated volume, you cannot claim tolerance—you must keep records of your fill process. Some members have successfully used 75cl bottles underfilled to 70cl equivalent for UK sale without issues from trading standards, provided filling records are maintained and inspections have cleared them. Industry data suggests beer has tighter tolerances (around 0.5%) and spirits around 0.3%, though these appear to be best-practice rather than hard regulatory ceilings.

#duty#fill-tolerance#trading-standards#hmrc
Regulation & Compliance18 discussions

What duty changes on spirits are expected in the upcoming HMRC budget announcement?

Members anticipate a spirits duty increase of 30–35p per 70cl bottle of 40% ABV (roughly £0.20–£0.29 per litre), with the announcement expected on 27 October. However, there is uncertainty: if the government states "no change to government policy" on spirits duty, this will in effect trigger an automatic 4.9% rise in line with RPI. The government is expected to simplify the duty structure by targeting growth categories (pre-mixed drinks, seltzer) while being gentler on UK beer—the most vocal complainants. Members also highlight ongoing industry lobbying through the BDA and WSTA to scrap the duty stamp scheme, which was introduced post-Brexit to prevent cross-border duty arbitrage but is now seen as unnecessary bureaucracy. There is frustration that craft-producer relief schemes (similar to the US Craft Beverage Modernisation and Tax Reform Act model) remain blocked by lobbying from large spirits producers, despite years of campaigning.

#duty#budget#spirits#tax
Regulation & Compliance11 discussions

What are HMRC's current enforcement patterns for R&D tax relief claims, and are they reviewing claims retroactively?

HMRC's approach to R&D tax relief has shifted significantly and enforcement activity is increasing, particularly for claims submitted from 2020 onwards. **Current enforcement patterns:** - Among claims submitted for 2020 and later, the majority (13 votes) have been paid without challenge, but a material minority (4 votes) have been subsequently challenged by HMRC and are currently being fought, with at least one claim already overturned (1 vote) - For pre-2020 claims, challenges are rarer (1 vote challenged out of 11 total) but members note this may reflect "yet" rather than definitive safety - HMRC's stated basis for challenges includes narrower interpretation of what qualifies as "Science & Technology" — rejecting claims where the technology, whilst genuinely uncertain, isn't deemed groundbreaking enough **Shift in advisor stance:** - Professional advisors are now warning members off new claims. One accountant's explicit guidance: "unfortunately we do not believe that the claim would satisfy the definitions of R&D for tax purposes in the current climate. If HMRC were to reject a claim for the 22/23 financial year, they have the ability to impose penalties and review previous claims. As such, we would not want to process any new R&D claims." - Members describe previous claims that "would have qualified without issue" now carrying unacceptable risk **Member sentiment:** - "The glory days are over" - Perception that HMRC is "going after small companies who they can bully into repaying" while larger firms remain unchallenged - Members are actively choosing not to submit claims due to penalty risk, even for work that previously qualified **Caveat:** This reflects community experience to date; the pattern of retroactive review of earlier years (2019 and before) is still emerging.

#hmrc#r&d tax relief#compliance#enforcement
Regulation & Compliance9 discussions

What are the HMRC criteria for a product to qualify for draught duty rates instead of standard duty?

Draught duty rates apply to products meeting specific criteria set by HMRC, though members note the rules can feel ambiguous and enforcement is inconsistent. **Key criteria for draught duty eligibility:** - **Container size**: 20L and above (containers 20L and below do not qualify) - **Alcohol content**: Must be 8.5% ABV or below - **Delivery system**: Container must incorporate or be designed to connect to a pressurised gas or pump delivery system (this excludes bag-in-box formats) - **End use and venue type**: The critical factor is that the product must be for consumption **on-premise in a licensed venue**. If the same product is taken away for off-premise consumption (e.g., filled into growlers for takeaway), it loses draught duty status and must be charged standard duty rates **Practical application:** Members recommend applying labels to kegs and casks stating "for on-premise sale only" to avoid HMRC disputes, and note that the responsibility for correct duty classification then falls to the venue. One member highlighted that a firkin or keg sold to an individual for personal use or a private event would not qualify as draught for duty purposes, regardless of size. Members also flag uncertainty around whether small-pack formats can ever qualify for draught duty, and advise checking **HMRC's official guidance** (gov.uk/guidance/check-if-you-can-pay-less-alcohol-duty-on-draught-products#eligible-products). There's a general caveat that HMRC enforcement is loose and inconsistent—they "leave you to do your own thing" until an audit, when classification disputes can become serious.

#hmrc#duty#draught#compliance
Regulation & Compliance8 discussions

What should I expect during an HMRC fit and proper test for alcohol trading compliance, and how should I prepare?

An HMRC fit and proper test typically involves one or more officers visiting your premises to assess whether you understand your licence, excise duty obligations, and can demonstrate proper due diligence to prevent duty fraud. **What to expect:** - Officers will ask detailed questions about how your spirits business operates — expect to explain the same concepts multiple times - The focus is heavily on **security and due diligence processes** to ensure no duty fraud can occur - They will assess your understanding of the specific **licence you've applied for and excise duty** requirements - Be prepared for questions that may seem basic or repetitive; the officers may not be deeply familiar with how the spirits industry works **How to prepare:** - **Treat it like a detailed production tour for complete newcomers** — don't skip anything, and mention every number and figure you can - Have clear documentation ready demonstrating your due diligence procedures - Be ready to walk through your security and compliance processes in depth - **Expect a visit to your office/premises**, not just a phone call — at least one case involved two officers attending in person **Overall outcome:** Members who have completed the process report it was "scary but worked out well" — the test is designed to verify competence and fraud prevention capability rather than to trap businesses.

#hmrc#compliance#fit-and-proper-test#excise-duty
Regulation & Compliance7 discussions

What is the duty payment schedule when releasing spirits from duty-suspended to duty-paid status?

Duty is payable **on or before release** from bond, unless you have duty deferment set up (in which case payment is **monthly**). The process works as follows: - **W5 form (ATWD system)** — You must raise a W5 document within the Alcohol & Tobacco Warehousing Declaration (ATWD) system (accessed via Government Gateway login). This form tells HMRC the volume of alcohol at 100% ABV you're releasing, and HMRC calculates the duty owed. You then pay that amount to HMRC. - **W1 monthly report (ATWD system)** — At the end of each month, you must also submit a W1 document within ATWD. - **Timing** — Members report paying duty "on release, or within a few days." One member noted their Trade Facility Warehouse approval specifies all operations must be completed within 30 days of the rectifying/compounding process, but members have reported that HMRC has since removed time-limit restrictions on bonded storage, allowing unlimited storage regardless of original approval terms. Check your most recent warehouse approval and confirm current conditions with HMRC or the BDA. - **Duty deferment option** — If you have duty deferment set up, payment is deferred to **monthly** rather than on release. **Caveats:** HMRC does not proactively explain this process. Members strongly recommend reading HMRC Notice 196/197 to confirm current rules. If you need detailed guidance, reach out to members via DM — they've navigated this and can provide specific help.

#duty#spirits#bond#hmrc
Regulation & Compliance7 discussions

What is the process for updating HMRC records and licenses when moving production premises? Do AWRS and rectifier licenses need reapplication or just notification?

You do not need to fully reapply for AWRS or rectifier licenses when moving premises—notification is sufficient. However, the process is more involved than a simple update and will likely trigger an inspection. **The notification process:** - Send official letterheaded letters to HMRC at the addresses listed on your original certificates - AWRS can now also be updated via the gov.uk portal - Be prepared for an AWRS inspection at your new premises (typically 3+ hours) **Key caveats members raised:** - The experience varies significantly depending on your local HMRC case officer and their interpretation of the rules - Inspections are common and can be time-consuming - HMRC has a reputation for losing documentation, which can cause weeks or months of delays before the license change is formally approved - Members reported having to chase updated forms multiple times - Budget significant admin time and potential production downtime during the transition period The takeaway: while you're not reapplying from scratch, treat this as a formal process requiring proactive follow-up with HMRC rather than a quick administrative tick-box.

#licensing#hmrc#awrs#premises-change
Regulation & Compliance6 discussions

What is the HMRC APPA registration timeline and will we receive direct communications?

APPA registration appears to be largely automatic for currently registered firms. According to members' contacts at HMRC, **existing registered firms will be automatically registered and receive their APPA number mid-February**, so no action is required until then. Members have not yet received formal HMRC letters or communications about APPA—awareness has largely come through the BDA. Some firms are choosing to continue submitting returns as normal this month, then switching to monthly W5 submissions from March onwards once APPA numbers and portal information are available.

#appa#hmrc#compliance#registration
Regulation & Compliance6 discussions

What is the timeline and process for obtaining HMRC WOWGR (Warehousekeeper's Option Without Goods Record) approval?

WOWGR approval typically takes **2–3 months** from initial application to approval, provided all documentation is complete. The process moves quickly once you receive a reply and have a call with HMRC officers; members recommend getting to know your assigned case officer, as you can then nudge them to accelerate progress. **Key points on WOWGR:** - WOWGR is primarily for the movement and ownership of duty-suspended goods - It is still very much in force, though there are ongoing discussions about its future (HMRC has indicated it may be revoked) - Approval depends on whether HMRC considers the officers "fit and proper" for the role **Alternative approach (duty-paid route):** - You can choose to pay duty at the point of production rather than operate under duty suspension; this does not require WOWGR - This approach is **not quicker** than obtaining WOWGR, but offers faster operational freedom if you don't want to wait for approval - You can have both options available: hold a WOWGR and still choose to pay duty upfront on some products, or keep goods in bonded warehouses **Critical caveat:** Members note that WOWGR legislation may be revoked by HMRC in the near future, so the regulatory landscape is shifting. Confirm current status with HMRC before proceeding.

#wowgr#duty-suspended#hmrc#timelines
Regulation & Compliance6 discussions

What is the process for relocating a duty-suspended warehouse or distillery and how does HMRC handle the change of location?

The relocation process for duty-suspended facilities varies significantly depending on your HMRC officer and circumstances. There is no strict "one size fits all" procedure. **Process variation:** - Some moves are straightforward with supportive HMRC officers requiring only a couple of forms to be filled in or, for quick relocations within a short timeframe, potentially just an email notification with a site plan - Other relocations trigger a full review where HMRC may treat the move as almost a new application, conducting complete inspections, full scrutiny of production processes, and detailed questioning - Expect extended timelines: previous relocations have involved multiple zoom calls (especially during Covid) and in-depth discussions about technical production details (e.g. heads and tails procedures, aging requirements) **Key variables affecting difficulty:** - **The HMRC officer assigned** — described as "luck of the draw." Some are supportive and expedite the process; others are more stringent and demanding - **Timing of the move** — moving again shortly after a recent relocation may result in a simpler notification-only process rather than full re-inspection - **Novelty of the location** — being the first operation of its kind in a new area (e.g. first distillery in a specific neighbourhood) can introduce additional logistical and approval complexity **Recommended approach:** - Prepare detailed documentation of your production processes and be ready to explain technical aspects thoroughly - Proactively communicate with your HMRC contact officer early in the planning stage - If your previous relocation was recent, reference this when requesting a streamlined process **Caveat:** Members stressed the unpredictability of the process and recommended against frequent relocations, citing multiple moves as a significant operational burden even beyond the HMRC approval stage.

#hmrc#duty-suspended#relocation#compliance
Regulation & Compliance5 discussions

Can a spirits rectifier transfer an existing excise license to new premises, or must they apply for a new license?

You can transfer an existing excise license to new premises rather than applying for a completely new one. The process involves contacting the HMRC National Registrations Unit with your new premises details and submitting updated documentation (including new floor plans and equipment entry of plant specifications). However, members note that the exact requirements may vary depending on your local HMRC officer—one member experienced a situation where a new license was required instead of a transfer. Start by emailing the National Registrations Unit and referencing HMRC Excise Notice 39 (Spirits Production in the UK), which contains the formal guidance. The process typically takes some time, so factor this into your relocation timeline.

#excise license#rectification#relocation#hmrc
Regulation & Compliance5 discussions

What is the HMRC process and form for applying for small producers duty relief on low-alcohol drinks?

Small producers duty relief is a self-governing scheme rather than a formal application process requiring a specific HMRC form. The scheme applies to drinks under 8–9% ABV (such as RTDs and ciders). Members report that the approach is to **keep detailed production records** as proof of eligibility; if HMRC investigates, you present these records to demonstrate compliance. Guidance on the scheme is available from **SIBA** (the Society of Independent Brewers). The relief is not pre-approved; instead, you document your own production and retain evidence in case of audit.

#duty relief#low alcohol#hmrc#tax
Regulation & Compliance4 discussions

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.

#export#duty#tax#compliance
Regulation & Compliance4 discussions

How should small producers respond when HMRC rejects or reverses duty relief claims, and what documentation helps challenge denials?

HMRC claim reversals are a growing problem for small producers, with members reporting successful claims being demanded back months after payout, often after random selection for further checks. Here's what the community has experienced: **The problem:** - Claims are being reversed 12+ months after initial approval, with HMRC issuing minimal written justification (often one-liners like "Not qualifying") and providing no signed correspondence or named officer to engage with - Members have submitted extensive documentation (50+ pages in some cases) and still received blanket rejections - HMRC appears to target small businesses specifically because they lack resources to mount formal challenges or hire tax barristers - Hundreds to low thousands of small businesses are currently having reversals imposed **Recommended approach:** - **Document comprehensively**: Gather detailed records from producers, storage partners, and your own operations—members report HMRC requests information from the full supply chain, not just your own submission - **Prepare formal responses**: When challenged, submit written replies addressing each of HMRC's points explicitly, even if their feedback is vague - **Seek peer guidance**: Members share templates and documentation approaches via direct message; ask within the community for examples of successful rebuttals or WOGR (Wines, Spirits and Other Goods for Resale) clause submissions **Key caveat:** Correspondence is now unsigned and officers are unreachable, making it extremely difficult to escalate or discuss disputes directly. Small producers without tax representation are at a significant disadvantage. Members recommend connecting with others facing similar reversals to share strategies and evidence templates.

#hmrc#duty-relief#claim-disputes#compliance
Regulation & Compliance4 discussions

What is the duty treatment and HMRC claim process for liqueurs made from duty-paid spirits at lower ABV?

The duty system for lower-ABV liqueurs made from duty-paid spirits is complex and involves understanding the differential duty rates by alcohol content. **Key points from member experience:** - Members are using duty-paid NGS (neutral grain spirit) at 96% ABV and paying duty at that rate, then diluting to produce liqueurs at 20% ABV, which attracts a lower duty rate per litre of pure alcohol (£3.14 lower than spirits over 22%) - One member confirmed they do this but had not previously claimed back the duty difference—suggesting a potential avenue that may not be widely utilised - The mechanism is that duty is charged relative to the alcohol content in the final liquid; however, using pre-duty-paid spirit as the base complicates the claim process - Circumstance matters: one member explained they are forced to use duty-paid spirit because their premises sits within another producer's site, which affects their sourcing options **Caveat:** The discussion did not contain detailed step-by-step HMRC claim procedures or confirmation of eligibility criteria. Members appear to understand the duty rate differential but actual claim experience was minimal in this exchange. Recommend seeking specialist HMRC guidance or duty consultant confirmation before implementing a claim strategy.

#duty#liqueurs#spirits#hmrc
Regulation & Compliance4 discussions

Do you need HMRC approval and a certificate to claim alcohol duty small producer relief, or is it self-regulated?

The answer depends on your situation and the relief you're claiming. **Small Producer Relief (SPR) for made wine and cider under 8.5% ABV:** Members report conflicting information. Some believe it is self-regulated—you calculate and declare relief yourself on your tax return, with responsibility on you as the producer to fill it in correctly. However, others have been told by bonded warehouses (e.g., **Chichester Bond**) that you must apply to HMRC and obtain a tax certificate showing approval before you can use the relief code. The safest approach is to contact HMRC directly before claiming, as the certificate requirement appears to apply in practice, even if some treat it as self-regulated. **Key points:** - The relief applies only to produced alcohol under 8.5% ABV (made wine, cider, and bottled cocktails/RTDs) - If you are actually producing it yourself, the relief makes a material difference to duty payable - Spirits producers do not have an equivalent small producer relief—campaigns by the community to extend it have not succeeded - **Your bonded warehouse or tax adviser should confirm the current certificate requirement** before you apply, as practice may vary **Caveat:** Members noted conflicting guidance on whether this is truly self-regulated or requires pre-approval. Check with HMRC or your bonded warehouse for the current position.

#alcohol duty#small producer relief#tax compliance#hmrc
Regulation & Compliance4 discussions

What are the HMRC alcohol duty return procedures and timelines for APPA submissions?

HMRC requires alcohol duty returns to be submitted through APPA (Alcohol Packaging Producer Alliance) on a monthly basis, with specific deadlines tied to the product release period. **Key timelines:** - **By 15 March** – Alcohol Duty return submitted for product released in the previous month (e.g. February period) - **By 25 March** – Alcohol Duty payment due for the submitted return - Businesses must enrol in APPA as soon as possible after receiving their APPA ID, and by 15 March 2025 to submit their first return **Important caveats:** - Members noted that HMRC guidance can occasionally conflict or change; for example, some confusion arose around whether February returns would proceed via APPA or alternative W5 forms, though the standard practice remains APPA submission by the 15th of the following month - If you encounter queries or issues preventing timely APPA submission, you may need to file a NIL return via APPA and submit actual duty details via W5 (Excise Warehousing Remittance Advice) instead - For imports of underbond alcohol from abroad, you'll need to complete customs clearance documentation; CPC code **0700F06** applies to alcohol in duty suspense being moved via EMCS (Excise Movement and Control System) to a bonded warehouse

#hmrc#alcohol duty#appa#excise
Regulation & Compliance4 discussions

Can VAT payment be deferred on W5 returns when releasing goods from bond, or must it be paid immediately?

The standard practice among members is to pay VAT on W5 returns when releasing goods from bond. However, one member recently encountered a distiller who was deferring VAT payment into their quarterly VAT return while still paying duty immediately on the W5. **Current practice:** - Most bonded distilleries pay VAT on W5 returns immediately (not deferred) - Duty is typically not deferred either, as this keeps cashflow management simpler **Potential alternatives:** - Some members speculate VAT deferment may be possible under a specific VAT payment plan agreed directly with HMRC, though this remains unclear - One member reported receiving confirmation from HMRC that VAT deferment on W5s is possible, though they noted this was "mind blowing" and unexpected **Next steps:** Members recommend contacting HMRC directly to clarify the exact conditions under which VAT deferment is permitted on W5 releases, though the hold times are notoriously long. It may be worth asking whether the deferring distillery has a specific VAT payment arrangement in place that others could replicate.

#hmrc#vat#bonded-goods#w5-returns
Regulation & Compliance3 discussions

What is the best way to contact HMRC for guidance on duty compliance for made wine production, and who should I speak to?

HMRC can be a helpful resource for duty guidance if you reach the right person. Members recommend two primary contacts: - **Babajide Akiode, Higher Officer at HMRC Individuals and Small Business Compliance** — Phone: 03000 551 459; Mobile: 07977034 724; Email: Babajide.Akiode@hmrc.gov.uk; Address: BX9 1LE. Members found him knowledgeable and responsive. - **Philip Griffiths** (philip.griffiths@pgea.co.uk) — A specialist external advisor described as "the god of this sort of thing" and "very reasonable and knowledgeable," particularly for navigating made wine duty processes. The general advice is that HMRC staff on the phone can be "super helpful" once you connect with someone who understands your category, though getting through to the right person may require persistence.

#hmrc#duty#made wine#compliance
Regulation & Compliance3 discussions

What software do I need for inventory management to satisfy HMRC trade facility warehouse requirements?

HMRC requires trade facility warehouses to declare what software they'll use for stock management, but members confirm that **Excel** is acceptable—you don't need specialised inventory software. One member initially worried spreadsheets wouldn't meet HMRC's expectations, but the consensus was that basic Excel tracking is sufficient for compliance purposes.

#inventory#hmrc#compliance#trade-facility
Regulation & Compliance3 discussions

What is the process for claiming back excise duty on drinks products when exporting to the EU?

The community acknowledges this is a legitimate but time-intensive process. Members recommend weighing the administrative burden against the financial return before pursuing a claim. **Getting expert help:** Rather than navigating HMRC claims alone, members suggest connecting with someone who handles excise duty claims regularly. Members have offered to introduce contacts who manage this process for drinks businesses. **Key consideration:** The effort required to gather documentation and manage the claim process may not justify the recovery amount for smaller export volumes. Factor in your time cost against the actual duty reclaim value before committing resources.

#excise duty#exports#eu#compliance
Regulation & Compliance3 discussions

What are the current requirements and risks around R&D tax relief claims for drinks brands?

R&D tax relief claims for FMCG drinks brands are increasingly scrutinised by HMRC and require careful consideration before submission. **Current situation:** - HMRC now requires R&D claims to be filed via an approved agent rather than directly - Government has become "much stricter" on what qualifies; members report increased investigation activity and repayment demands on previous claims - Several brands are choosing not to proceed with claims this year due to heightened risk **Qualification rules:** - **Data Fox** was used by members but is now "much more cautious" given stricter enforcement - New variants, bottle designs, and cosmetic changes do **not** qualify — claims require "proper science involved" - Members strongly advise exercising caution and understanding exactly what HMRC will accept before claiming **Caveats:** - Many FMCG brands (not just drinks) are currently under investigation for previous claims, with significant repayment demands - The landscape has shifted materially in recent months; historical claims that passed may no longer meet current criteria

#r&d tax relief#hmrc#compliance#fmcg
Regulation & Compliance3 discussions

How do UK drinks brands obtain duty stamps from HMRC, and what changes are coming in 2025?

Duty stamps are currently free to request directly from HMRC; they are category-specific and can be applied to bottles before shipment to the UK. However, this system is being phased out. **Current process:** - Request duty stamps directly from HMRC at no cost - Stamps are category-specific (spirits, wine, etc.) - Overseas brands can apply stamps before shipping or have UK distributors apply them on arrival **Regulatory change:** - Duty stamps will be discontinued in May 2025, ending the requirement entirely - Until then, brands can continue using stamps or have Licensed Customs Brokers (LCBs) apply them on import - Members noted that stamp application (whether manual or via LCB) adds cost and process friction; using an LCB to handle this until the April 2025 deadline is a practical option if stamps are not pre-applied **Context:** Members flagged that the stamp system has had limited impact on grey-market reduction and is considered by some a bureaucratic process of questionable value—hence the planned abolition.

#duty-stamps#hmrc#regulation-change-2025#spirits
Regulation & Compliance2 discussions

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.

#duty-recovery#export#hmrc#compliance
Regulation & Compliance2 discussions

What are HMRC's specific requirements for duty stamp placement on spirit labels?

Duty stamps must not be touching any other labels on your bottles. Members learned this requirement directly from HMRC during compliance checks, and discovered it matters enough that production errors can cause significant delays. One member caught a placement error before HMRC involvement, but it required corrective action on the production line.

#hmrc#duty-stamps#labelling#compliance
Regulation & Compliance2 discussions

What is the correct HMRC tax code for spirits over 22% alcohol?

The tax code for spirits over 22% alcohol has changed. **Code 345** is now the correct code to use when submitting W5 forms to HMRC. This replaced the previous code 451. If you're experiencing issues submitting with the new code, check you're referencing the current version of the HMRC guidance, as some members found they were initially reading outdated information.

#hmrc#tax-codes#spirits#alcohol-duty
Regulation & Compliance2 discussions

What should I do if I receive multiple conflicting APPA IDs with different addresses or business names?

Members have reported receiving multiple APPA IDs with inconsistent information—different addresses, incorrect business names, and vague address details. This appears to be a known issue with HMRC's processing. **What to do:** - Contact **mailbox.alcoholpolicy@hmrc.gov.uk** as soon as possible to report the discrepancy. Provide your correct business name, up-to-date business address, and details of all current licenses and registrations you hold. - If you've already chased HMRC once without resolution, follow up again with the same contact details and reference your warehouse authorisations and HMRC records as the source of truth for your correct address. - Be aware that HMRC's IWG (Implementation Working Group) has flagged this as a priority issue ahead of the February 2025 mailshot deadline for new approval, returns and payments changes. Getting your APPA ID corrected before then is important to ensure you receive future communications. **Caveat:** Members report this can take 2+ weeks to resolve even after chasing; persistence may be required.

#appa-registration#hmrc#compliance
Regulation & Compliance1 discussion

What is the process and timeline for getting HMRC duty stamp codes incorporated into label artwork?

HMRC duty stamp incorporation requires coordination between you, HMRC, and your label printer, and typically takes 2–3 weeks total. **Process overview:** - Register with HMRC to obtain your duty stamp codes - HMRC will send you a disc containing your registered codes - Pass your artwork (with the duty stamp code and number incorporated) to your label printer - Printers can typically print within 10 days of receiving final artwork **Recommended printers:** - **Label Apeel** (Leicester) — Members report they are "very good", competitively priced, and offer quality work. Ask for Craig Goodman. Multiple members confirmed they use them and describe them as "a very nice gang". **Timeline:** Expect 2–3 weeks from HMRC sending you the disc to receiving printed labels, depending on how quickly HMRC processes your registration and how you coordinate artwork handoff.

#duty stamps#labels#hmrc#production