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.
How do you update AWRS registration when your business changes operation (e.g., moving from contract production to own production), and what customer compliance checks are required?
**Updating AWRS registration:** Members report that AWRS changes are managed through the **Government Gateway** login you used when you first set up your AWRS account. Click on AWRS within the Gateway and update your information there. One member noted difficulty finding contact details, but this online process appears to be the standard route. **Customer compliance checks:** The community has settled on a pragmatic two-tier approach: - **For wholesale/trader customers:** Create a "New Trader Form" requiring AWRS registration, VAT number, and company registration details. Use the **Government Gateway AWRS check tool** (https://www.gov.uk/check-alcohol-wholesaler-registration) to verify their registration status. Follow up with a "Compliance sheet" where you record your own verification results: Companies House lookup, Creditsafe check, VAT check, AWRS registration confirmation. Request their accounts payable email and phone number for credit control purposes. - **For retail/on-premises customers (pubs, bars):** Ask for their **Premises Licence** and verify it against the local council register. The standard T&Cs and extensive ID/proof-of-residence forms are not universally applied to one-off retail customers. **What HMRC actually requires:** Members report that HMRC's practical requirement is verification of AWRS status for wholesalers and Premises Licences for retail outlets, supported by documented checks. One member emphasized that maintaining this diligence is "good practice and shows due diligence." **Caveat:** While no member reported being caught out for non-compliance, the tone suggests this is an area where regulatory risk is taken seriously, particularly for wholesale customers.
What licenses do I need to sell spirits B2B directly to retailers without a premises licence?
You do **not** need a premises licence to sell spirits B2B to retailers. However, you **do need AWRS (Alcohol Wholesaler Registration Scheme)** — this is mandatory. Key points: - **AWRS registration** is essential and non-negotiable for B2B spirit sales - You can sell off a vehicle (e.g. bike/cargo bike) and invoice from your business address without a premises licence - In some areas, you may need a **TEN (Temporary Events Notice)** to sell off the bike — this varies by local authority, so check with yours - The critical requirement is that duty is paid; the premises licence itself is not required for B2B wholesale Caveats: Local council rules on mobile sales can vary, so it's worth confirming TEN requirements with your local licensing authority before you start delivering from a vehicle.
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.
Do you need to notify AWRS when changing distribution partners or production partners?
The community's experience suggests notification requirements differ by partner type. - **Production partner changes** — Members recommend notifying AWRS when you change production partners, as this is considered a material change to your operation. - **Distribution partner changes** — The consensus is that you likely don't need to notify AWRS when switching distributors (at least one member didn't and had no issues), though one member suggested it's "worth notifying distributor change at the same time just in case" to cover yourself. **Caveat:** This is based on members' practical experience rather than formal confirmation. For absolute certainty on AWRS requirements, confirming directly with AWRS would be prudent, especially for production changes which are more likely to require notification.
When a company sells shares, does the AWRS registration remain valid and what must be notified to HMRC?
Share sales alone do not trigger AWRS re-registration; the key requirement is notifying HMRC of **changes to company directors** (officers). Members emphasised that HMRC's concern is whether directors are "fit and proper" in their eyes, not shareholder composition. Related timings: - **WOGWR (Warehousekeeper of Goods Without Duty Relief) approvals** typically take **2–3 months** from initial submission. Once you receive a reply and have a call with the case officer, the process moves quickly if all documents are complete. - Members noted you can speed things up by building a relationship with your assigned officer and nudging them once you know who's handling your case. Caveats: Legislation around WOGWR is in flux—members flagged that HMRC may eventually abolish it, though it remains in force currently. If you're considering changes to your business structure (such as adding a brewery operation to an existing gin-production AWRS), treat director changes as the primary notification trigger and allow several months for any linked approvals.
Do you need to be VAT registered to sell alcohol if your turnover is under the £90k threshold?
No, you do not need to be VAT registered to sell alcohol below the £90k threshold. Members clarified that **AWRS (Alcohol Wholesaler Registration Scheme) registration is separate and can be obtained without VAT registration**. However, a key consideration: if you estimate your sales will exceed £90k in the rolling 12 months ahead, you should register for VAT voluntarily *before* hitting that threshold, rather than waiting. You can also choose to be VAT registered even if you're under £90k if it suits your business. One member noted this would be "backwards" if VAT registration were mandatory for alcohol sales below the threshold, suggesting the regulatory intent is clear on this point.
What licenses and regulatory requirements are needed to set up an in-house cocktail blending and kegging operation?
To set up a cocktail blending and kegging operation (blending third-party spirits and juices rather than producing alcohol from scratch), members confirm you'll need several key licenses and registrations. **Core licenses and registrations:** - **Compounder's licence** — required for blending operations - **AWRS (Alcohol Wholesaler Registration Scheme)** — mandatory registration - **Premises licence** — required to sell through a website; requirements vary by location (confirmed as needed in Brighton but may differ elsewhere) - **Bonded site status** — valuable to have if possible, as it saves on duty costs **Caveats and next steps:** - The application forms can be unclear and require careful completion; members recommend getting expert help if possible - One member was arranging a call with a specialist to navigate the process and recommended sharing learnings with the community - Members who have recently moved distilleries and gone through licensing again offered to share tips on navigating the paperwork This is a regulated process with multiple overlapping requirements; getting specialist advice early is strongly recommended.
Do non-alcoholic drinks producers need to register for AWRS?
Non-alcoholic drinks producers do not need to register for AWRS (Alcohol Wholesaler Registration Scheme). Multiple members confirmed they have never been required to register, and when asked on forms about AWRS status, simply marking "NA" (not applicable) has been sufficient. The scheme applies only to alcoholic beverages, so non-alcoholic brands fall outside its scope entirely.
Do you need a premises licence for B2B spirit trading, or is AWRS registration sufficient?
AWRS registration alone is sufficient for B2B spirit trading—you do not need a premises licence for business-to-business sales. However, if you trade D2C (direct-to-consumer), a premises licence becomes mandatory.