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.
Can a US-based company hold AWRS and WOWGR registrations, or must they be UK-registered?
A US-based company cannot directly hold AWRS and WOWGR registrations—these require a UK-registered business entity. AWRS requires UK VAT registration, which in turn requires a UK-registered business. To hold bonded stock in the UK as an overseas business, you must appoint a UK duty representative, typically a paid service offered by bonded warehouses. Key options if you want to centralise operations to the US: - **Appointing a UK duty representative** — Bonded warehouses like Cadus Vaults can act as duty representatives for overseas businesses, though note this is typically offered for cask storage rather than finished goods inventory. - **Using a logistics-focused distributor** — Members recommend exploring partners like **Proof Drinks** or **Tortuga**, which operate logistics business models (rather than pure agency) and may be able to hold and manage your stock in bond under their UK registration. - **Retaining a UK subsidiary** — If you self-distribute and need to hold stock in bond, you currently cannot shut down your UK subsidiary and retain that stock under a US-only structure. Caveats: The regulations around duty representation and bonded stock are strict. Self-distribution with a centralised US operation appears incompatible with holding bonded inventory in the UK under current arrangements.
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.
How do you prepare for and pass the WOWGR (Wholesaler Own Brand Growth Registration) process?
The WOWGR process is lengthy but straightforward to prepare for. Members report the actual assessment takes around 3 hours and doesn't require complicated preparation. **Approach options:** - **DIY preparation** — Members have successfully prepared and passed on their own, though it requires significant time investment - **Phil Griffiths** — Multiple members recommend working with this compliance specialist who helps with due diligence pack preparation. He has experience with WOWGR and can also handle AWRS simultaneously. Described as "amazing" and offering reasonable fees for what members characterize as "a horrible process" **Key takeaway:** While it's possible to go through WOWGR alone, members who used Phil Griffiths as a guide found the process much smoother, particularly if handling multiple compliance requirements at once.
Can you pay duty upfront on beer production instead of using duty-suspended arrangements, and is it faster?
Yes, you can pay duty at the point of production rather than using duty-suspended arrangements. However, **paying duty upfront is not faster than duty suspension** — both routes take similar time to operationalise. **Key options:** - **Pay duty upfront** — you produce beer, pay the duty immediately to HMRC, and are then "free as a bird" to move and sell the product without WOWGR. No requirement for bonded warehouse or movement permits. - **Duty-suspended arrangement (WOWGR)** — move goods without paying duty upfront; pay duty later when the goods leave the warehouse or are released into the market. Requires Warehousekeeper of Wines & Spirits or similar approval. - **Hybrid approach** — obtain WOWGR approval but still choose to pay duty upfront on some or all production, giving you flexibility. You can also keep goods in a bonded warehouse while holding WOWGR status. **Caveats:** The main trade-off is cash flow: paying duty upfront requires immediate capital outlay but simplifies logistics and removes the need for duty-suspended permits. Members note that neither approach is materially quicker than the other operationally. For specific advice on WOWGR logistics and recent legislative changes, members recommend contacting specialists in this area.
What do I need to do with my WOWGR licence when relocating my drinks business to a different location?
You must update your WOWGR (Wholesale of Alcohol and Online Sales) registration **before** you move premises. This is a critical step that cannot be done after relocation — plan the WOWGR amendment as part of your relocation timeline to avoid any compliance gaps or suspension of your ability to operate.