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 are the UK commodity codes and customs procedure codes needed for importing spirits from the EU post-Brexit?
Post-Brexit spirit imports from the EU require both a commodity code and a customs procedure code (CPC). Members found the process significantly more complex than pre-Brexit. **Resources and codes:** - **UK Trade Tariff** (gov.uk/trade-tariff) — the official government tool for looking up commodity codes for imports; includes options for different container sizes (spirits over 2L have specific codes) - **Customs Procedure Code 0700000** — mentioned as the likely CPC for spirit imports, though members noted this is the area where complexity lies ("box 37" references suggest detailed customs declaration requirements) **Caveats:** Members found the CPC lookup particularly challenging and non-intuitive. The Trade Tariff tool is the authoritative source, but members recommend consulting it carefully and potentially seeking specialist customs advice if the procedural code isn't immediately clear. One member flagged that even experienced importers found box 37 (part of the customs declaration form) confusing.
What are the regulations and requirements for shipping alcohol samples to the US without an established importer?
Shipping alcohol samples to the US typically triggers requests for a COLA waiver and TTB import permit, though enforcement appears inconsistent. **Key findings from member experience:** - **COLA waiver and TTB import permit** — Usually required by couriers; your US importer would typically handle obtaining these, but enforcement is inconsistent and some members have shipped without being stopped - **Personal luggage** — Several members suggest the practical workaround of carrying samples personally in your suitcase when travelling to the US - **Courier account type** — DHL has indicated that samples *can* be sent without an importer via a specific account type, though details on setup were not discussed; FedEx reportedly offered a similar special US service at one point - **State-by-state variation** — Members noted that requirements may vary by US state and destination; one member sending to Miami faced requests after previous shipments to other companies had not been stopped - **Enforcement appears inconsistent** — The "luck of the draw" comment reflects member experience that some shipments go through without issue while others are flagged, making it hard to predict which will trigger regulatory requests **Caveats:** This is an area where outcomes seem to depend on courier, destination state, and individual account setup. If you're regularly shipping samples, establishing a relationship with a US importer or exploring specialist courier accounts may reduce friction.
Can a drinks producer qualify for Small Producers Relief on alcohol duty if their base alcohol is imported from a non-small producer?
The regulatory text suggests that imported base alcohol must also come from a qualifying small producer to access Small Producers Relief, which creates a challenge for RTD makers sourcing from large international suppliers. **Key findings from member experience:** - The official guidance (https://www.gov.uk/guidance/check-if-youre-eligible-for-small-producer-relief-on-alcohol-duty) appears to require the supplying producer to also be a small producer, which excludes most large US alcohol suppliers. - **HMRC's interpretation is unclear and inconsistent.** Members report that HMRC internally disagrees on what constitutes "alcohol production," suggesting the rules may be applied differently depending on who you speak to. - One member suggested a potential workaround: establishing a small UK SPV (special purpose vehicle) to purchase and re-supply the imported alcohol, creating a chain where the immediate supplier is a small UK entity. This is technically possible but members acknowledged it sits in ethically grey territory and its legitimacy is unverified. - No members confirmed successfully using this approach or obtained explicit HMRC clearance for it. **Recommendation:** Before committing to a restructuring, contact HMRC directly to confirm their current interpretation, as the scheme's definition of "production" appears to be under internal debate. Members suggest being cautious of workarounds without explicit written approval.
What is Extended Producer Responsibility (EPR) legislation and how does it affect imported drinks products into the UK?
Extended Producer Responsibility requires producers and importers to track and report packaging data. **Reporting thresholds:** You only need to formally report if you have turnover over £1 million and generate 25 tonnes of packaging waste annually (approximately 35,000 glass bottles at 700g each). **For imported products:** If you're importing drinks, you'll need to clarify responsibility with your importer — either you or they may be designated as the responsible party for reporting packaging data. Members noted that communication from HMRC about the Advanced Packaging and Packaging Waste Regulations (APPA) has been limited, and several discovered the requirements through industry bodies like the BDA rather than direct government outreach. Even if below reporting thresholds, importers should still be recording packaging data for compliance purposes.
Do RTD beverages need duty stamps or VAT stickers when imported to the UK?
RTD beverages do not require duty stamps when imported, even if they contain spirits fortification. Members clarified that duty stamps (which differ from VAT stickers) are not applicable to RTDs. For the definitive rules on which products require duty stamps, refer to the UK government's Excise Notice DS5 on the UK duty stamps scheme, particularly Section 3, which sets out the full list of products subject to the requirement. If your RTD is non-fermented and fortified with spirits, duty stamps do not apply based on community experience.
What CPC code should be used for customs clearance of underbond alcohol imports?
For alcohol in duty suspense being moved via EMCS to a bonded warehouse, members recommend using the CPC code **0700F06**. This code is used specifically for underbond alcohol imports processed through the Excise Movement and Control System (EMCS) with an MGN (Movement Guidance Note) to a bonded warehouse for duty suspension purposes.