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 changes coming with WOWGR abolition and how will bonded goods movement be handled after March?
The WOWGR (Wholesale Own Brand Goods Regime) is being abolished in March. The replacement mechanism depends on whether you produce duty-suspended goods in your own warehouse. **For producers (own-brand production):** - You can apply for an **APPA (Alcohol Producer Premises Approval)** to operate a bonded/excise warehouse within your production facility - You will still need a movement guarantee to move goods, but the APPA allows this under the new regulations - This only applies if you have your own production facility **For non-producers (contract bottled, bought-in goods):** - You will still need to hold an **Excise Warehouse licence** as per current regulations - Contract bottled customers will still require a WOWGR or equivalent warehouse licence - You will need to apply for an Excise Warehouse licence if moving bonded goods **For buying duty-suspended spirits:** - Members asked about mechanisms to purchase duty-suspended spirits post-abolition; the excerpts confirm movement will still require a guarantee, but specific suppliers or processes were not detailed in the discussion **HMRC guidance:** - An HMRC webinar was held on 30 January 2025 at 15:30 covering WOWGR abolition details (Meeting ID: 368 234 148 018; Passcode: pt9uQ6wm). Members are advised to contact HMRC directly or attend such webinars for clarification on individual circumstances.
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.
What is the most cost-effective way to dispose of damaged bonded warehouse stock that has been registered for destruction with HMRC?
Once goods are registered with HMRC for destruction, disposal options are limited by regulatory requirements. Members report that £600–£650 is typical pricing for this service, though costs can reach several thousand pounds for larger quantities. **Disposal options:** - **Biffa** — Several members recommend them as a bonded goods destruction contractor. They handle HMRC-compliant disposal and appear to be willing to do ad hoc collections, though members note the cost is usually in the £600+ range per pallet. Worth getting a quote even if initial quotes seem high. - **Local waste management contractors** — One member mentioned having "a guy" for Wales-based disposal, suggesting regional specialists may exist. Worth asking your third-party bonded warehouse if they have preferred contractors, as they may have negotiated rates. - **Low-cost alternatives (high risk)** — One member mentioned that some destructions involve pouring low-ABV products down a drain and recycling containers separately, which costs around 10x less. However, this approach is only compliant if explicitly approved by HMRC and your warehouse operator, and third-party warehouses typically won't allow it. Not recommended unless you have explicit written approval. **Key caveats:** - Once registered for destruction with HMRC, the process is essentially irreversible—you cannot redirect goods as gifts or sales without potentially significant duty implications and HMRC re-approval. - The warehouse operator has significant control over the approved destruction method (time, place, contractor), so negotiating with them or asking for their preferred suppliers may unlock better rates. - Standard ad hoc waste disposal companies typically won't handle bonded goods; you need contractors experienced with HMRC-registered destructions.